What the decree prescribes
To implement the duty of care you take at least the measures in Articles 6 to 18 of the Cyberbeveiligingsbesluit [1]. Almost every measure carries the same formula: you have established policy, record it in writing and demonstrably apply it [2].
The documents at a glance
- policy on the security of your network and information systems, with the roles, responsibilities and powers [2]
- policy on risk management, with a methodology, criteria for risk acceptance and an overview of the risks [3]
- policy on incident handling [4]
- business continuity policy, a business continuity plan, a recovery plan and a crisis management plan [5]
- policy on the security of the supply chain [6]
- policy for acquiring software, hardware and services [7]
- policy on the use of cryptography [8]
- policy on logical and physical access [9]
- policy for asset management, with a complete and up-to-date inventory [10]
What else you record
If you receive a targeted warning about a vulnerability or cyber threat, you record whether your measures must change [11]. You also record the periodic evaluation of your measures in writing [12]. The management body approves the measures [13].
One document or several
The decree does not prescribe what the exact scope and content of the policy must be [14]. According to the explanatory memorandum, you may work out the policy in one or more documents or place it in an information security management system [15]. If you are a transport company, then as part of that management system you also record how, when and by whom the effectiveness of the measures is measured and evaluated [16]. The transport regulation additionally asks for recorded backup procedures with recovery times, recovery points and retention periods [18], the justification if you do not apply a security patch or apply it later [19], the results of vulnerability scans and the justification if you do not remedy a vulnerability or remedy it later [20], and policy for privileged accounts and system administrator accounts [21]. For, among others, postal and courier services and food, equivalent regulations apply [22].
Does this apply to everyone?
Not to cloud and IT service providers and other digital providers under Article 4 of the decree: Articles 6 to 18 do not apply to them [17]. They follow Implementing Regulation (EU) 2024/2690.