Chief Information Security Officer in 2026: Mandatory Checkbox or Strategic Weapon?
Chief Information Security Officer in 2026: Mandatory Checkbox or Strategic Weapon?
In the context of NIS2 compliance, many organizations today still think primarily in technological terms: systems, logs, access rights, incidents. However, the regulatory environment has made it clear that information security is not exclusively an IT responsibility. It is also an organizational, governance, and accountability issue—and at its center stands the Chief Information Security Officer (CISO).
The role of the CISO is not new, but expectations have changed significantly. In the past, it was sufficient to keep the role separate from day-to-day IT operations and designate someone to “keep an eye on” cybersecurity. In the world of NIS2, this approach is no longer sustainable.
From Regulation to Operation
Decree 17/2025 (VII. 24.) of the Ministry of the Interior provides clear frameworks: the Chief Information Security Officer must have appropriate qualifications, recognized certifications, and ongoing professional training. The legislator did not intend the CISO to be an administrative role, but rather a professional who can understand organizational risks and ensure long-term compliance.
Establishing compliance can be treated as a one-off project. Maintaining it, however, requires continuous attention, regular reviews, and decision support. In this operational model, the CISO is not an “auditor” but one of management’s most important allies: providing an objective view of risks, managing incidents, liaising with authorities, and ensuring that regulatory requirements remain aligned with daily operations.
Internal or External Solution?
The legislation allows time until the end of December 2026 to meet the requirements, which presents a dilemma for many organizations. Is it worth training internal resources, obtaining certifications, and financing continuous professional development—or is it more efficient to entrust this responsibility to an external, contracted CISO?
From a business perspective, the question is straightforward: lack of compliance is a risk, while maintaining compliance is an ongoing cost. With an external CISO, this cost is predictable, professional compliance is assured, and responsibilities are clearly defined. There is no need to worry about the unavailability of a key employee, outdated expertise, or delayed reactions to regulatory changes.
What Does the Presence of a CISO Mean in Practice?
A well-functioning Chief Information Security Officer regularly reviews risks, keeps policies and controls up to date, manages security incidents, and ensures that the organization truly complies with NIS2 requirements—not just on the day of an audit. In addition, the CISO provides continuous feedback to senior management, ensuring that information security is not a blind spot but a controlled and measurable business factor.
Why Choose Régens’ External CISO Service?
Régens’ External CISO Service removes the professional and regulatory burden of compliance from your organization. We provide a fully compliant expert with proven experience in the practical implementation of NIS2 requirements—someone who not only establishes information security compliance, but also maintains it over the long term.