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How Can Expired Certificates Lead to NIS2 Non-Compliance? 

January 28, 2025
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Written by Marijana Mišić Mikulić, Product Manager at ASEE

With the rise of cyber threats, the NIS2 Directive was introduced to strengthen cybersecurity across the EU. It demands stricter security requirements, risk management measures, and incident reporting obligations for essential and important entities. 

A key aspect of NIS2 compliance is ensuring secure authentication and data protection, where Public Key Infrastructure (PKI) and digital certificates play a crucial role. Proper certificate management is essential to maintaining security and regulatory compliance. 

But what happens when certificates expire? How can expired certificates lead to NIS2 non-compliance? 

The Role of PKI and Certificates in NIS2 Compliance 

One of the fundamental security principles outlined in NIS2 is ensuring secure communication and authentication. Public Key Infrastructure (PKI) and digital certificates serve as the backbone of secure digital identity verification, encryption, and data integrity. They help organizations authenticate users and devices, encrypt sensitive information, and prevent unauthorized access – aligning directly with NIS2 security mandates 

Use Cases for PKI Certificates in NIS2 Compliance 

Public Key Infrastructure (PKI) certificates play a crucial role in securing multiple aspects of an organization's digital ecosystem. Some of the most critical use cases for certificates usage to ensure NIS2 compliance include: 

  • TLS/SSL – Encrypts web traffic and secures communication between servers, applications, and users, preventing data interception. 
  • Email Encryption (S/MIME) – Protects email communications by encrypting messages and ensuring sender authenticity through digital signatures. 
  • Data Encryption – Ensures that sensitive data remains protected from unauthorized access and breaches. 
  • Code Signing – Verifies the integrity and origin of software, ensuring that applications and updates are not tampered with. 
  • Digital Signatures – Enables legally binding electronic signatures, ensuring document authenticity, integrity and compliance with regulatory requirements. 

By implementing these security measures, organizations can reduce cybersecurity risks, protect critical infrastructure, and meet NIS2 compliance obligations

Mandatory Requirements and Regulatory Compliance 

To comply with NIS2, organizations must fulfill several key security obligations, including: 

  • Strong authentication mechanisms – Ensuring that only authorized users and devices can access critical systems. 
  • Data encryption – Protecting sensitive data to prevent unauthorized disclosure. 
  • Certificate lifecycle management – Monitoring and renewing certificates to avoid security gaps. 
  • Incident reporting – Detecting and responding to security incidents promptly. 

Failure to manage PKI certificates properly – such as allowing them to expire – can lead to security vulnerabilities and regulatory violations, potentially resulting in fines and reputational damage

How Can Organizations Ensure Compliance? 

To avoid NIS2 non-compliance and strengthen their cybersecurity posture, organizations should follow best practices in PKI and certificate management: 

  • Implement Strong Policies – Enforce strict policies for key management, encryption standards, and authentication procedures. 
  • Regular Audits & Compliance Checks – Conduct periodic audits to ensure all certificates are valid and configured properly. 
  • Use Secure Hardware for Key Storage – Employ Hardware Security Modules (HSMs) to store private keys securely. 

By integrating PKI best practices and automation tools, organizations can enhance security, maintain compliance with NIS2, and prevent disruptions caused by expired or mismanaged certificates

Wrap Up

NIS2 sets strict guidelines for security, risk management, and compliance. PKI certificates play an important role in fulfilling these requirements by enabling secure communications, authenticating identities, and protecting sensitive data.  

Also, compliance is not just about implementing certificates—it’s about managing them properly. Expired or misconfigured certificates can lead to security vulnerabilities, service disruptions, and regulatory penalties. Organizations must take a proactive approach by automating certificate lifecycle management, enforcing strict security policies, and conducting regular audits

By implementing PKI best practices and automation tools, businesses can not only meet NIS2 obligations but also strengthen their overall cybersecurity posture. The question is: Is your organization prepared to manage its certificates effectively and stay compliant? 

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