The short answer: yes – if proper preparation is lacking.

The longer answer, however, goes beyond this, as compliance is not merely a technological issue but also a matter of comprehensive operational and managerial responsibility.

What is a NIS2 Audit?

A NIS2 audit – also known as a compliance assessment – is an external evaluation process during which an independent auditor examines whether an organization meets the cybersecurity requirements set out by law. The audit typically scrutinizes the following aspects:

• Risk management and incident handling practices
• Presence of technical and organizational protection measures
• Supply chain security
• Business continuity assurance
• Management involvement and accountability

How Can You “Fail” an Audit?

Although the term “fail” doesn’t appear in the official documentation, in practice, insufficient or inadequate compliance can have serious consequences. In cases of severe or repeated violations, authorities may impose the following sanctions:

• Significant financial penalties
• Operational restrictions
• Personal liability of executive officers

According to Government Decree 1/2025 (I. 31.) SZTFH, compliance is evaluated using an objective, points-based system. A total of 100 points can be earned, and the compliance threshold is set at 70 points. If an organization scores below this threshold, it is officially deemed non-compliant with the NIS2 requirements, which in itself can trigger sanctions.

Thus, NIS2 compliance is not just an “IT task” but a strategic and business-critical priority that directly impacts an organization’s stability, reputation, and lawful operation.

Preparation: The Key to a Successful Audit

Compliance cannot be achieved overnight. The implementation of NIS2 is not a one-time project but requires ongoing operational improvement and a conscious shift in organizational culture. Key elements of successful preparation include:

1. Gap Analysis – Mapping the differences between the current security level and the NIS2 requirements
2. Action Plan – Developing a scheduled and measurable plan to address deficiencies
3. Structured Processes – Implementing documented procedures for risk and incident management and business continuity
4. Awareness Building – Regular staff training and internal education
5. Documentation – Keeping all measures and controls up to date and auditable
6. Drills and Testing – Conducting regular exercises and technical tests to assess emergency response readiness

Feel free to contact us and entrust your NIS2 preparation to our experienced experts! Let’s start working together today!

Executive Responsibility: A Strategic Requirement

One of the most significant innovations in NIS2 is that it explicitly names top management as responsible for cybersecurity compliance. This means leadership cannot fully delegate the responsibility to the IT department. Ensuring compliance is a strategic task for management that requires broad organizational coordination, oversight, and commitment.

Legally Defined Audit Methodology: No Room for Interpretation, Only for Compliance

The necessity of preparation is further underscored by the fact that the audit evaluation process and criteria are now detailed in legislation. According to Decree 1/2025 (I. 31.) SZTFH, the audit is not a subjective review but is conducted according to a strictly regulated and objective scoring system.

The decree clearly defines:

• Audit criteria (e.g., risk management, incident handling, business continuity, supply chain security, awareness building)
• Evaluation logic (each area has specific score thresholds and minimum requirements)
• Compliance levels, i.e., what score qualifies as non-compliance
• Audit documentation requirements, including the structure of the report and feedback process

This detailed methodology effectively eliminates flexibility in interpretation or audit execution. There is no room for "explaining away" a deficiency or "scoring leniently" based on good intentions – compliance must be quantifiable, measurable, and auditable. The regulation’s goal is to ensure that audit results are comparable and standardized across the country.

This also means that targeted, thorough preparation is more critical than ever: organizations cannot rely on a "we’ll clarify it during the audit" mindset. Every requirement, every point must have a concrete answer, control, or document – otherwise, points are automatically deducted.
This strict and detailed evaluation system sends a clear message: compliance cannot be accidental or partial. Only a consciously built, comprehensive cybersecurity system can lead to a successful audit outcome.

Preparing for the NIS2 audit? Discover key tips and requirements in our NIS2 Audit Guide: Tips, Requirements, and the Audit Process

Maintaining Compliance: A Continuous Obligation

It’s important to emphasize that compliance does not end with the first successful audit. NIS2 introduces an ongoing obligation for compliance, which requires regular internal checks and cooperation with authorities. This includes:

• Incident reporting – Significant events must be reported to the authorities within 24 hours
• Periodic reporting – In some cases, annual risk assessment and protection reports must be submitted
• System updates – Security systems must be kept current in response to emerging threats and technological changes
• Regulatory cooperation – Organizations must provide full documentation and collaboration during inspections
• Biennial re-audit – The regulation mandates a re-certification audit every two years to verify ongoing compliance with current requirements

Even a single missed incident report can result in significant financial and legal consequences, regardless of the organization’s technical preparedness. The biennial re-audit ensures that compliance becomes a sustained operational standard, not a one-off goal.

The Real Question

So the real question is not whether you can fail the audit – but whether you can afford not to be prepared in time.