Home / Solutions / NIS2 and DORA

Solution · NIS2, the Cyber Security Act and DORA

Phishing-resistant MFA that withstands a NIS2 or DORA audit.

NIS2, the Cybersecurity Act, and DORA make strong authentication a board-level priority. Ciptor converts this into hardware-bound authentication, mapped requirement by requirement, with verifiable evidence for supervisory authorities.

Does the Cybersecurity Act require multi-factor authentication?

Yes, where required. The Cybersecurity Act (2025:1506) has applied since 15 January 2026 and implements NIS2 in Sweden. Under Chapter 2, Section 3, covered entities must implement authentication solutions as part of their security measures. This aligns with Article 21.2(j) of the NIS2 Directive. Management must also receive training on these security measures pursuant to Chapter 2, Section 4.

Does DORA require strong authentication?

Yes. DORA applies to financial entities in the EU as of 17 January 2025. Article 9 requires policies and protocols for strong authentication mechanisms as part of ICT risk management.

Requirements map

What the regulations require, what Ciptor delivers, and what you can demonstrate.

Requirements

What Ciptor delivers

Evidence provided

NIS2 Art. 21.2(j) · CSL Ch. 2, Section 3, Item 10

Multi-factor authentication

FIDO2 security keys and hardware passkeys for all users, administrators, and consultants

Coverage report: who uses which authentication method

NIS2 Art. 21.2(i) · CSL Ch. 2, Section 3, Item 9

Access control and asset management

Security keys are issued following identity verification, with workflows for onboarding, replacements, and offboarding.

Key register and revocation log

NIS2 Art. 21(2)(d) · CSL Ch. 2 Section 3 Item 4

Supply chain security

Corporate-issued security keys for third parties with privileged access

Third-party access register

NIS2 Art. 21.2(f) · CSL Ch. 2, Section 3, Item 6

Assessment of control effectiveness

Red Team exercise before and after deployment

Penetration test report for the board

NIS2 Art. 20 · CSL Ch. 2 Section 4

Management responsibility and training

Board briefing and risk analysis in plain English

Approved control description

DORA Art. 9

Strong authentication

Hardware-bound authentication with risk-based step-up

Documentation of policy and protocol

Why phishing-resistant

"MFA" on paper is not MFA that an attacker respects.

SMS, authenticator codes, and push approvals meet compliance criteria, but are routinely bypassed by phishing kits. Regulators and insurers increasingly ask which type of MFA you deploy. Hardware-bound authentication provides a clear answer.

SMS / authenticator app code

Vulnerable to phishing

Can be entered on a spoofed site and relayed.

Push approval

Vulnerable to phishing

Can be approved by a fatigued or misled user.

FIDO2 security key

Phishing-resistant

Bound to the authentic domain. Nothing to type, nothing to forward.

Questions regarding NIS2 and DORA

Does this apply to our organisation?

NIS2 and the Cybersecurity Act apply to medium and large entities across 18 sectors. These include energy, transport, healthcare, digital infrastructure, manufacturing, and public administration, as well as selected smaller critical operations. Book a walkthrough with us to quickly determine if you are in scope.

Are passkeys on a phone considered phishing-resistant?

Device-bound passkeys are phishing-resistant. Synced passkeys are a significant improvement over codes. However, for administrators and regulated roles, we recommend security keys.

Can we start with administrators only?

Yes. Many clients start with privileged accounts and third parties. They then roll it out to all staff.

See how your login withstands a real attack.

30 minutes with a Ciptor specialist. No slides you have already seen.

Book a walkthrough (30 min)