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Why Does NIS 2 Redefine Board Risk for Financial Market Infrastructures?

Financial Market Infrastructures (FMIs) are navigating a regulatory landscape fundamentally reshaped by NIS 2. This directive places cyber and operational resilience squarely on the board’s agenda, treating it as a live duty, not a technical afterthought or a quarterly box to tick. The stakes go well beyond fines-recent pan-European outages and ECB-led stress tests demonstrate that the market now measures stability by groupwide resilience, not isolated control sign-offs. What your local audit didn’t catch, a supplier vulnerability or a group entity’s overlooked weakness can expose in hours, dragging your board onto regulatory radars-and, more importantly, onto front-page news (ECB 2022).

Your controls must defend against invisible threats that start at the network’s edge but land in the boardroom.

Board-Level Shift: From Passive Assurance to Active Accountability

NIS 2 introduces “living accountability”-transforming board members from passive recipients of assurance packs to active stewards of group resilience. Today, a clean local audit is not enough; supervisors scrutinise group incident drills, linked evidence, and cross-entity notification logs. Eurofi’s 2024 overview reminds boards: failure to simulate market-impactful scenarios or run live incident drills, especially on supplier-related vulnerabilities, risks not only penalties and operational restrictions but market trust (Eurofi 2024). Now, resilience is measured in hours, not months-and every member of the board must navigate this shift from “sterile sign-off” to “dynamic proof.”

Converging Duty-ISO 27001, DORA, and NIS 2 in One View

FMIs must harmonise across intersecting frameworks, ensuring operational pressure-points flagged under NIS 2, DORA, and ISO 27001 are mapped in groupwide practise. Expectations now include:

Expectation How FMIs Must Prove It ISO 27001 / NIS 2 / DORA Reference
Group Incident Escalation Cross-entity live scenarios; documented linkage ISO: A.5.24 / NIS 2: Art. 23 / DORA: II
Supplier/TTP Resilience Updated, logged SLAs and real-world runbooks ISO: A.5.19 / NIS 2: Art. 4, 21 / DORA: V
Board-Grade Evidence, Any Site Timestamped SoA flows, centrally exportable logs ISO: 9.2; A.5.36 / NIS 2: Art 32 / DORA: III

Immediate checklist for the CISO or operational lead prepping the next board session: Are incident notifications group-synchronised? Are TPRM and supplier weaknesses logged as instant market-impact, not slow lessons learned months later? Can the board retrieve evidence in hours? These are baseline expectations, not stretch goals.

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How Can FMIs Survive the NIS 2 24/72-Hour Incident Reporting Mandates?

Regulators are now clocking your every move from the moment an event emerges. NIS 2’s 24/72-hour incident reporting doesn’t just serve compliance-it stress-tests your organisation’s information muscle and decision agility (ENISA NIS 2 Resource). If a crisis forces your team to scramble, rewrite spreadsheets, or chase down “who knew what, when?” gaps, it exposes the very weaknesses supervisors want to find. Reporting requirements bite not just IT, but legal, risk, operations, and the board itself.

When a critical incident strikes at 3am, automated response scripts-and evidence-ready workflows-matter far more than assurance language.

Where FMIs Fail: The Drills No One Spotlights

Most organisations believe their workflows are solid-until tested by incidents with cross-border or third-party triggers. Trouble usually hits in familiar ways:

  • Manual escalation (phone trees, email chains) break down when fatigue or ambiguity spikes.
  • Exporting incident logs and tying them to SoA controls is painfully slow, especially after timezone handoffs.
  • Teams discover too late that evidence was never centralised or linked, sending board members scrabbling for last-minute justifications to regulators or investors.

By contrast, leading FMIs have embraced scenario-driven reporting drills. They map workflows from “trigger event” to “board-ready evidence” and automate each step to reduce error and reporting latency.

Traceability Table: Trigger to Board Proof-No Breaks, No Delays

Automated traceability means every detected risk moves seamlessly from real event through to logged evidence, always audit-grade and ready to extract. Here’s what excellence looks like:

Trigger Immediate Risk Update Linked Control (SoA) Evidence Logged
Cross-border outage Group risk escalation, board notification ISO: A.5.24; NIS2: 23 Incident log & export bundle
Vendor breach TPRM/contract trigger, urgent review ISO: A.5.19; NIS2: 21 Vendor alert, contract clause
Regulator delay Policy owner + board review and alert ISO: A.5.36; NIS2: 32 Audit log, notification file

Every manual handoff adds risk. Automating logs, playbook escalations, and notification steps hardens your response-ensuring you meet regulatory windows, not just for compliance, but for market stability.

Your competitors will run the same regulatory clock. The fastest to evidence and board confidence set the bar.

Practical tip: Map a recent incident workflow from detection to regulator report; document every gap, then script or automate the slowest handoff before your next board drill. Confidence is built by defending evidence, on demand, at any hour.




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Are Your Technical, Procedural, and Human Controls Truly Resilient-Or Just an Audit Illusion?

Many FMIs have become expert at “passing the audit,” only to feel exposed when a real incident or supervisory review lays bare the weak links among their technical, procedural, and human controls. Passing an ISO assessment or local audit gives only a momentary illusion of resilience if “defence in depth” is implemented as isolated artefacts-not as a living, tested, cross-functional system (BIS 2024; EBA).

Audit compliance is a shadow; real resilience is proven only when policies, communications, and logs navigate the chaos of a high-pressure drill.

Where FMIs Falter: Siloes and Paper Controls

The most significant vulnerabilities show up not in technology itself, but in the seams-misaligned responsibility, outdated runbooks, supplier privileges lingering in forgotten systems, and roles without enforceable segregation. These are areas where NIS 2 and DORA zero-in with unforgiving clarity.

  • Siloed Logs and Permissions: Technical controls may be pristine, but if evidence doesn’t “travel” with events or roles, board confidence collapses.
  • Third-Party Haemorrhage: A single change at a supplier can invalidate otherwise clean evidence, creating a regulatory liability lag.
  • Human Factor Weakness: “Separation of duties” on paper, without digital traceability, is regulatory quicksand.

Drill Scenario Table: Belief Inversion for Modern FMIs

Outdated Belief NIS 2/DORA Reality Board-Level Action
“Audit pass = ready” Only live, linked logs count Scenario testing, trigger-to-evidence flow
“IT handles risk” Board/legal bear survivor liability Full-role mapping, escalation live-drilled
“Supply chain = docs” Supplier breach triggers board investigation Quarterly incident drills, contract exports

Action Plan: After every simulation, require that evidence chains-logs, communications, decision points-are reconstructed as they would be presented to a regulator. This “reality check” ensures control coherence and hardens the board’s trust in what resilience actually means.

The next time a supervisor asks to walk through a real tabletop, will your logs and evidence prove seamless compatibility across disciplines?




Where Does Supply Chain Risk Now Peak Under NIS 2 for FMIs?

The regulatory perimeter has expanded well past your own technical environment. NIS 2 draws a direct line from third-party and vendor shortcomings to your group’s reputation, audit readiness, and ultimately, financial integrity. FMIs are expected not only to contractually oblige their suppliers to respond-but to prove, via live runs, that detection and escalation workflows truly span the entire supply chain (ENISA 2024; Accenture; Clifford Chance). The weakest supplier is now your most likely regulatory trigger point.

If you can’t prove your vendor’s breach feeds your board in minutes-not days-you aren’t resilient.

Building Proof, Not Plausibility

The days of “checkbox” supplier management are finished. Now, real supply chain resilience means:

  • Requiring live scenario testing and evidence export as part of onboarding and renewal.
  • Mandating that contracts embed not just 24/72 hour incident clauses, but working notification pathways tied to real playbooks and incident logs.
  • Ensuring every key supplier can participate, on-demand, in breach notification drills and evidence exports.

Traceability Example Table: From Vendor Alarm to Board Evidence

Vendor Trigger Immediate FMI Action Linked Control Board/Regulator Proof
SaaS breach alert 24h EU-wide escalation NIS 2: Art. 23, 32 Board notification, full log
Vendor audit fail TPRM update, risk mapping ISO: A.5.19; DORA: V Contract, clause record

Quick diagnostic: Choose a critical vendor. Can you simulate a breach and trace evidence-notifications, logs, escalation steps-from the vendor through to your group board, exportable in seconds? Where gaps or slow steps appear, document and automate. That’s evidence of resilience-documentation alone no longer suffices.

When every supplier in your critical chain can run the drill digitally, you shift from hope to defendable compliance-market and regulator alike see the difference.




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Can Your FMI Deliver Audit-Grade Evidence-Or Only Promises-on Request?

NIS 2, DORA, and sector regulations have reversed the burden of proof. You are not only responsible for owning your audit pack-you must be able to produce it, live, for regulators and NCAs at any time, in any jurisdiction, often within an hour (EBA 2024; BIS). The benchmark now is whether your evidence chains display live traceability-not policy shelves or static archives, but real connections between controls, events, and staff acknowledgements.

Audit readiness is no longer a sprint to printouts. It's a living, always-on portfolio that defends you at an audit, not days or weeks after.

From Theory to Defence-Actively Proving Compliance

To achieve this, FMIs are embedding live test evidence and audit-grade exports into routine operations. That means:

  • Each staff attestation, policy update, SoA revision, or drill is automatically linked to event logs and timestamped as board-grade evidence.
  • Re-usable, cross-jurisdictionally harmonised audit packs are assembled quarterly, stress-tested during scenario drills, and logged as part of board briefings.
  • Automation replaces the scramble-ensuring evidence is anywhere, for anyone, on demand.

Audit Readiness Table: Request to Evidence Path

Audit Request Trigger Required Evidence Bundle Rule Reference Target Retrieval
Regulator on-site audit SoA logs, event history, test proof ISO: A.5.24, NIS 2: 32 < 1 hour
Board/partner due diligence Scenario logs, board sign-off report NIS 2: 23, DORA: III < 4 hours

Forward step: Schedule quarterly “evidence sprints”-simulate audit requests, push staff and systems to gather full packs live, and document any friction points for automation. Audit stress shrinks; confidence rises proportionally. When statutory pressure looms, you’re already standing at proof-not at the starting blocks.

Readiness is tested not in the prepping, but in your team’s ability to show proof the moment it’s asked for.




Are You Prepared for Quantum and AI Threats-Or Will FMIs Be Caught Flat-Footed?

Quantum risk and AI-driven attacks are no longer theoretical-they’re scenario-tested, regulator-monitored, and market-relevant. Recent ECB policy and industry reviews show that FMIs will be measured, in 2025 and beyond, by live simulation logs, quantified cryptography audits, and AI-fraud team drills as rigorously as by routine incident management (ECB 2025; FS-ISAC).

Supervisors aren’t waiting-your next audit-ready evidence pack must feature cryptographic upgrade plans and logged human-factor drills.

Proving Quantum and AI Resilience-Beyond the Boardroom

Modern FMIs:

  • Map quantum-vulnerable systems, review and log progress on robust cryptography upgrades.
  • Conduct annual “deepfake” and AI-driven scam simulations across both technical controls and key roles, logging outcome and staff responses.
  • Ensure scenario outcomes are packaged, exportable, and ready for both board and regulator on demand.

Bridge Table: Quantum/AI Scenario Closure Example

Threat Simulated FMI Action Taken Regulator Ref. Audit Evidence Asset
Quantum breach drill Crypto inventory, upgrade timeline NIS 2: Art. 23, DORA: III Crypto test logs
AI-driven fraud Staff drill & scenario export NIS 2: Art. 20, FS-ISAC Training audit, simulation log

Immediate step: Select your highest-value payment or exchange system; schedule a quantum resilience and AI-fraud tabletop in the next board quarter; log proof of closure and remedial actions. This preparation is now a routine bar to clear for FMIs, not an aspirational stretch.

Proactivity is the new minimum; quantum and AI audits will expose your readiness or lack thereof before the next regulation lists it as mandatory.




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How Can FMIs Standardise Resilience Protocols Across Borders-and Boardrooms?

FMIs spanning EU and UK borders face a reality: one weak protocol-often at a small subsidiary or remote office-creates risk and regulatory drag for the entire group. NIS 2, DORA, and sector initiatives demand market-wide readiness, not “patchwork” local compliance (Eurofi 2024; Clifford Chance). If your slowest escalation or least harmonised drill lags, your group may bear collective scrutiny-and fines that echo from smallest to largest entity.

Your market standing is now set by the group’s slowest responder, not its best-prepared board.

Aligning Protocols: From Patchwork to Pan-European Defence

The path to harmonised resilience across FMIs requires:

  • Identifying the strictest local requirements-and enforcing them as the default for all group entities.
  • Visual protocol mapping: scenario drills across locations, jurisdictions, and roles to trace escalation and notification in “real time.”
  • Building and maintaining a cross-jurisdiction incident log-automated, filterable, and export-ready for each board or local supervisor.

Border-to-Board Table: Harmonisation Playbook

Cross-Border Trigger Protocol Harmony Step NIS 2 / DORA Reference Board/Regulator Asset
Multi-country incident Instant group log export NIS 2: 23/32 Unified log bundle, alert flow UX
Regulator overlap Live Q&A, scenario reporting NIS 2: Art. 32, Eurofi Multi-board Q&A module, evidence pack

Practical ask: Map your escalation workflow between two contrasting locations. Where translation, policy mismatch, or timezone lag appears, document and automate. Regular cross-entity drills convert latent weaknesses into strengths before external review exposes them.

Resilience is no longer a local project; it’s a living market standard scored in boardrooms and by supervisors across every jurisdiction you serve.




Empower Audit-Ready Resilience: Book Your ISMS.online Group Check

The difference between regulatory pain and market leadership lies in your FMI’s ability to deliver audit-ready resilience as a living practise-not merely a project for next quarter or the next board meeting. As financial infrastructures evolve, regulatory heat, operational fatigue, and cyber disruption will only rise. Those that make evidence generation, scenario testing, and groupwide workflow integration routine define the pace for both their own board and the broader market.

  • Book your ISMS.online Resilience Check: Experience a full resilience mapping-see your scenario drills, incident notifications, supply chain logs, and board escalation mapped, live, across every group entity.
  • Bring your stakeholders: Security, procurement, legal, risk, TPRM, and board representatives unite in one system, witnessing their part in the compliance loop-zero duplication, instant retrieval, exportable at the click.
  • Step through the living interface: Watch evidence build from first incident trigger, travel up to board dashboards and straight through to regulators or NCAs, all in an environment purpose-built for global regulatory demands.

The FMIs who define market stability in 2025 will not just pass audits; they’ll set evidence, resilience, and cross-jurisdiction transparency as the new standard for trust.

Ready to turn evidence from a burden into board-level capital? Schedule your ISMS.online group check and demonstrate audit-ready stewardship before the market or regulator even asks.*



Frequently Asked Questions

What is the NIS 2 Directive and why does it fundamentally change FMI boards’ responsibilities for cross-border resilience in 2025?

NIS 2 is the European Union’s new, legally binding directive that directly holds boards of Financial Market Infrastructures (FMIs)-including payment systems, trading venues, and clearing houses-personally accountable for group-wide cyber and operational resilience as of October 2024. Unlike ISO 27001’s management “commitment,” NIS 2’s regime compels directors to prove, with live and exportable evidence, that both core operations and critical supply chains across your entire group can withstand and recover from broad, market-impacting incidents. Gone are annual, static policies: your board must champion a system that tracks controls, logs, and incident responses across all sites and subsidiaries in real time, demonstrating to regulators and clients not just intent, but execution.

Live, group-wide evidence of resilience is the new currency for trust-from the boardroom to the trading floor.

How does NIS 2 move beyond iso certifications and past regulatory norms?

NIS 2 makes resilience a living, monitored legal mandate-not a paperwork exercise. Boards face obligations to oversee drilled playbooks, continuous monitoring, and supplier participation in stress tests, with up to €10M or 2% of annual turnover at risk if evidence is late, fragmented, or fails under cross-border review. Unlike previous regimes, pan-EU regulators can quiz any entity, at any time, on evidence that controls are tested and functioning.

Timeline What’s Required What’s at Stake
Oct 2024 NIS 2 live; group-wide enforcement Regulatory audits, legal fines
24 hours Incident report to NCA/CSIRT €10M/2% fines, reputation hit
72 hours Detailed technical report, update Regulatory intervention risk

In 2025, “passing an audit” won’t shield your board-real-time resilience and audit-ready evidence are non-negotiable.


Which events trigger NIS 2’s strict reporting clock, and how should FMIs respond?

NIS 2 requires FMIs to report to national authorities or CSIRTs within 24 hours of any incident that can disrupt market confidence or operations-including cyberattacks, payment or settlement outages, or supplier failures, even if only one part of the group is affected. Within 72 hours, a technical root cause and management update must follow, and within one month, a full final report. Importantly, material incidents now include systemic threats-think deepfake fraud, quantum cryptography exploits, or supplier ransomware-that introduce “plausible systemic” risk, not just direct losses.

A glitch in one city may trigger a group-wide audit-only real-time, connected evidence and board-level engagement will satisfy regulators.

What does a compliant response look like?

  • Automated escalation from detection to board-level notification
  • Time-stamped digital logs and live Statement of Applicability (SoA) linkage at every step
  • Notification packs and templates, ready for multi-language, cross-border use
  • Inclusion of supplier/third-party event triggers-contract language must require participation
Step Required Action Evidence Output
Detection Instant alert to response managers Dated, time-stamped log
Escalation Notify board, record cross-jurisdiction flow SoA update, playbook assignment
Notification Report to NCA/CSIRT, export log in 24h Signed, exportable notification

Quarterly live drills-and automated, signed evidence at each stage-are now standard.


How do NIS 2, DORA, and ISO 27001 intersect-and what’s newly required of FMIs?

NIS 2 and the EU’s Digital Operational Resilience Act (DORA) require not just documented controls, but operational proof across supply chains and group entities-both in place and under stress. Board legal liability is explicit, fines automatic: “local” compliance is obsolete when an outage or breach crosses borders.

Requirement NIS 2 DORA ISO 27001:2022
Board-level legal liability YES YES Implied (Clause 5.4)
Incident report: 24/72 hrs YES YES No
Group evidence, on demand YES YES Partial
Mandatory supply chain proof YES YES Encouraged, not forced
Fines for late/gap evidence €10M+ €10M+ None

What’s different?

  • Operationalise technical and procedural controls: -e.g., live endpoint, network segmentation, privilege management, monitored across the group.
  • Drilled scenario playbooks: that include third parties and subsidiaries, not just IT.
  • A living, centrally managed SoA: -group-level, flexible enough for local/NCA requests, but unified.

Resilience is a system to prove, not a badge to claim-fragmented audits or slow entity responses are public penalties.


How must FMIs now manage supply chain and third-party cyber risk under NIS 2 and DORA?

FMIs are mandated to treat all key suppliers as operationally embedded: that means every cloud provider, software vendor, and critical IT outsourcer must appear on your group’s resilience dashboard. They’re required to contractually commit to notification, participate in incident playbooks, and provide evidence (not just a policy statement) during drills and crises.

What does “embedded” mean in practise?

  • Maintain a live, group-wide supplier dashboard-contract status, drill logs, and NIS 2/DORA terms attached.
  • Practise joint cyber scenarios with vendors-no tick-boxes, every critical vendor must appear in at least one annual evidence log.
  • Escalate every vendor-side incident/alert as a group event within 24 hours-regulators now reject “supplier delays” as a defence.
Vendor Trigger Leadership Response Evidence You Must Log
Cloud breach Immediate group escalation Vendor alert, SoA, exportable log
Payment processor DDoS Board notification, drill test Playbook log, signed supplier attendance
Quarterly TPRM review Contract check, supplier test Updated SoA, contract amendment snapshot

Manual, spreadsheet-driven supplier logs are a regulatory liability-automation and integration are now board-level concerns.


What will regulators scrutinise during cross-border audits, and where do weaknesses commonly appear?

Supervisors now expect real-time, unified audit packs-fragmentation by country or business line, or any “slowest jurisdiction,” is a compliance failure. Regulators look for:

  • Live SoA exports (not point-in-time)-with clear control status, assignment, and jurisdiction.
  • Integrated evidence spanning incidents, controls, supplier events, and board log-offs, available in English and local languages.
  • Time-stamped, board-signed logs for all risk, scenario, and incident events.

Audit packs must move at group speed, not just local pace. Cross-jurisdictional evidence and notification define your board’s credibility.

Key exposure points:

  • Lagging or incomplete logs-failure to provide within 24/72 hours
  • Evidence trails with gaps between staff activity and board approval
  • Workflow siloes-when drills, SoA, and incident registers don’t reconcile across all entities
Exposure Pattern Control / SoA Reference Mitigation
Outdated logs SoA, A.5.31, 5.26 Quarterly evidence sprints
Staff action–board gaps SoA, board sign-off Centralised dashboard
Separate audit/export process Incident playbook, A.5.24 Unified workflows

Operational assurance and evidence delivery speed-the fastest entity is now the benchmark for all.


How do quantum, AI, and deepfake threats-and impending new laws-heighten FMIs’ obligations now?

Supervisory bodies (e.g. ECB, ENISA, FS-ISAC) now expect routine board-level review and logging of quantum-vulnerable cryptography, AI-driven threats (deepfakes, synthetic phishing), and third-party exploits within the group. Crucially, NIS 2 expects you to act before new rules are finalised: catalogue, train, and drill-while logging and reporting each step.

Threat / Trigger Required Action Loggable Evidence
Quantum cryptography risk Inventory, migration planning Board minutes, registry exports
Deepfake or AI fraud attempt Staff drill, scenario log Training log, playbook document
Third-party breach Vendor notification, test Drill log, regulator submission

Due care now means anticipating and practising for threats ahead of regulation-demonstrable readiness must precede legal deadlines to protect trust and compliance status.


How can FMIs harmonise cross-border compliance and avoid being slowed down by the weakest link?

Each EU country now adds its nuances to NIS 2 or DORA, but FMIs must rise to the strictest rule as their de facto baseline-then prove uniform compliance via exportable evidence and practised notification drills. Regulators will interrogate the slowest, not just the “successful” HQ.

Trigger Event Response Required SoA/Contract Reference Audit Evidence
Multi-jurisdiction breach Dual NCA/CSIRT notification, export SoA, incident playbook Exported log, drill record
Regulatory overlap Apply highest rule group-wide Group SoA, scenario mapping Drill log, local language

Get audit-ready packs and a harmonised response into every market’s hands before regulators ask-make uniform compliance the group advantage.


What actionable steps must FMIs’ boards and legal/operational leaders take today to ensure resilience, not just compliance?

  • Run a Resilience Mapping drill with ISMS.online: Bring board, legal, IT, and your key suppliers together for a scenario-based test-trace every event from detection through escalation and evidence export, in all languages required.
  • Operationalise quarterly “board dashboard” reviews: Task compliance, IT, legal, and risk teams with simulating evidence export and cross-market notification, particularly for your slowest country or supplier.
  • Update supplier contracts to enforce drill participation and evidence handoff: Don’t accept promises-evidence and logs must be export-ready.
  • Automate evidence capture and approval processes: Integrate live SoA, incident, and drill logs-assignable to board, audit, or regulator at any moment.

Demonstrate your board’s live readiness, not just static compliance, to supervisors, markets, and partners. Scheduling a resilience mapping is not a tick box-it’s a reputational signal to regulators, investors, and clients that you are always on guard and export-ready.

ISO 27001 Bridge Table: Turning Regulatory Demands Into Evidence

Expectation Operationalisation ISO 27001 / Annex A Reference
Board accountability Management sign-off, live SoA, logs Clause 5, 9.3, Annex A.5.4
24/72-hour incident deadlines Pre-built automation, scenario playbooks A.5.24, A.5.26
Third-party/supply chain Live TPRM dashboards, evidence logs A.5.19–A.5.22, A.5.9
Cross-border compliance Export-ready SoA, registered in all markets Clause 4.3, A.5.31, A.5.36

Traceability Table: Risk-to-Evidence

Trigger Risk/Action Control / SoA Reference Logged Evidence
Supplier or cloud breach Group escalation, NCA alert TPRM, incident playbook Audit log, board sign-off, SoA
Market entry/expansion Jurisdiction review, harmonise SoA, legal contract Audit/export pack, drill logs
Quantum/AI/deepfake Inventory, drill, board review Asset managers, staff training Registry, training log, report

Delivering live, harmonised resilience evidence is now a reputational and regulatory safeguard. If you want your board, legal, and operational teams to command readiness-not just respond to demand-begin with a resilience mapping session in ISMS.online and turn cross-border complexity into your group’s competitive, audit-proof advantage.



Mark Sharron

Mark Sharron leads Search & Generative AI Strategy at ISMS.online. His focus is communicating how ISO 27001, ISO 42001 and SOC 2 work in practice - tying risk to controls, policies and evidence with audit-ready traceability. Mark partners with product and customer teams so this logic is embedded in workflows and web content - helping organisations understand, prove security, privacy and AI governance with confidence.

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