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Security Awareness & Training

NIS2 Management Training: What Boards Must Know

Akash Kumar
Last updated: October 18, 2026 2:47 pm
Akash Kumar
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Under NIS2, cybersecurity is no longer something a board can hand to IT and forget. The people who sign off the budget now have to approve the security measures, oversee them, and take training themselves, and they can be held liable if the measures fall short.

Contents
What Article 20 actually saysArticle 20(1): approve, oversee, be accountableArticle 20(2): trainingWho counts as the “management body”?Liability: why boards should take this seriouslyItaly: duties that cannot be delegatedWhat good board training coversMake it practicalQuestions every director should be able to askHow often should boards train?How to document board trainingExtending training to staffFAQDoes every board member have to be trained, or just one?Can the CISO take the training on the board’s behalf?Does a certificate from an online course satisfy Article 20(2)?Does training protect directors from liability?Sources

This article explains what Article 20 of the NIS2 Directive requires of management bodies, what good board training looks like in practice, how often to run it, and how to document it so it stands up to a supervisor’s review.

This is general guidance, not legal advice.

What Article 20 actually says

Article 20 of Directive (EU) 2022/2555 has two parts.

Article 20(1): approve, oversee, be accountable

Member states must ensure that the management bodies of essential and important entities:

  • approve the cybersecurity risk-management measures the entity takes under Article 21;
  • oversee their implementation; and
  • can be held liable for infringements of Article 21 by the entity.

National rules on the liability of public institutions and public officials still apply alongside this.

Article 20(2): training

Members of management bodies are required to follow training. Member states must also encourage entities to offer similar training to their employees on a regular basis. The stated purpose is for people to gain enough knowledge and skills to identify risks and to assess cybersecurity risk-management practices and their impact on the services the entity provides.

Two points stand out. First, board training is mandatory, while staff training is encouraged under Article 20(2), though basic cyber hygiene and cybersecurity training for staff is separately one of the minimum measures in Article 21(2)(g). Second, the goal is judgement, not technical skill. Directors need to be able to challenge what they are told, not configure a firewall.

Who counts as the “management body”?

The directive does not define it in detail, so national law and company structure decide. In Italy, ACN’s FAQs say entities must list the members of their management bodies: all members of the board of directors where there is one, the sole director where there is not, and always the legal representative. Managers, the point of contact or the CISO are not listed unless they also sit on that body.

Liability: why boards should take this seriously

ProvisionWhat it means for managementApplies to
Art. 20(1)Management bodies can be held liable for the entity’s infringements of Article 21Essential and important entities
Art. 32(6)Natural persons responsible for, or legally representing, the entity must have the power to ensure compliance and can be held liable for breaching their dutiesEssential entities
Art. 32(5)(b)As a last resort, authorities can request a temporary ban on a person at chief executive or legal representative level from exercising managerial functionsEssential entities
Art. 34(4)–(5)Entity fines of at least EUR 10m or 2% of worldwide turnover (essential) and at least EUR 7m or 1.4% (important), whichever is higherThe entity

Training does not shield a director from liability. But a board that has been trained, has asked the right questions and has recorded its decisions is in a far better position than one that cannot show it engaged at all. Training is how directors make their oversight credible. For the wider legal picture, see NIS2 Directive explained.

Italy: duties that cannot be delegated

Italy transposed Article 20 in Article 23 of Legislative Decree 138/2024. ACN’s FAQs on management bodies (most recently updated in July 2026) make two practical points:

  • The training and approval duties are strategic-direction obligations and cannot be delegated, either to individual members or to other bodies. Operational implementation can be delegated, but oversight and approval stay with the board.
  • Management bodies must promote a periodic training offer for employees consistent with the training they follow themselves, and the training plan required under ACN’s basic measures must be approved by the management bodies.

What good board training covers

The directive does not prescribe a syllabus. A useful test is the purpose stated in Article 20(2): after the session, can each director identify the main cyber risks to the business and judge whether management’s response is adequate? Build the content around that.

ModuleKey contentWhat directors should be able to do afterwards
1. The legal frameNIS2 scope, essential vs important status, Articles 20, 21 and 23, national law, supervision and fines; overlaps with DORA and GDPRExplain the entity’s obligations and their own personal accountability
2. Threats to your businessThe threats most relevant to your sector, such as ransomware, phishing and social engineering, supplier compromise and outagesName the scenarios that would hurt the business most
3. Risk and risk appetiteHow the risk assessment is built, how to read the risk register, setting risk appetite, accepting residual riskApprove or challenge risk treatment decisions
4. The Article 21 measuresThe ten minimum measures (a)–(j) at oversight level: what “good” looks like and how it is evidencedAsk whether each measure is in place and how management knows
5. Incidents and crisisThe 24-hour early warning, 72-hour notification and one-month final report; the board’s role in a crisis; communicationsMake decisions quickly under pressure; know who notifies the authority
6. Supply chainDependence on cloud providers, MSPs and software vendors; contract terms; concentration riskChallenge supplier risk decisions
7. Metrics and questionsA short set of board-level KPIs and the questions to ask at each meetingRun effective oversight between incidents

Make it practical

Directors learn most from scenarios. A two-hour tabletop where the board works through a ransomware attack, decides whether to notify the authority within 24 hours, and agrees what to tell customers will teach more than a slide deck. Our upcoming cyber tabletop exercise guide explains how to run one.

Keep the language plain and the material specific to your organisation. Generic awareness videos built for staff do not meet the purpose of Article 20(2) for directors, because they do not equip them to assess risk-management practices.

Questions every director should be able to ask

  • What are our five biggest cyber risks, and who owns each one?
  • When did we last test restoring our critical systems from backup, and did it work?
  • If we were hit tonight, who decides whether to send the 24-hour early warning?
  • Which suppliers could stop our service if they were compromised?
  • Where do we not use multi-factor authentication, and why?
  • What did the last audit or penetration test find, and what is still open?

How often should boards train?

Article 20(2) requires management bodies to follow training but does not set a frequency for them. For employees it refers to training “on a regular basis”. Italy’s ACN FAQs likewise do not fix a frequency. That means you set it, and you should be able to justify it.

A defensible pattern, which is our recommendation rather than a legal requirement, looks like this:

TriggerFormatTypical length
New director joinsOnboarding briefing covering all seven modules2–3 hours
AnnuallyRefresher with updated threats, regulatory changes and a scenario exercise2–3 hours
Each board meetingShort security report with KPIs and decisions needed15–30 minutes
After a major incident, regulatory change or new business lineTargeted updateAs needed

How to document board training

If a supervisor asks how you comply with Article 20(2), you need a paper trail. Keep:

RecordWhat it should show
Training planWho is trained, on what, how often, by whom; approved by the management body (in Italy, explicitly required)
Attendance recordsName, role, date, duration and format for each director; catch-up sessions for absences
Content and materialsAgenda, slides or handouts, scenario used; version-dated so you can show what was covered when
Learning checkA short quiz, discussion record or exercise output showing understanding
Trainer detailsInternal or external provider and their qualifications
Board minutesApproval of the Article 21 measures, security reports received, questions asked and decisions taken
Follow-up actionsActions arising from training or exercises, with owners and closure dates

Store these with your other NIS2 evidence. Our NIS2 compliance checklist covers the full evidence pack.

Extending training to staff

Article 20(2) encourages similar regular training for employees, and Article 21(2)(g) lists basic cyber hygiene and cybersecurity training among the minimum measures. Board training and staff training should be designed together, so the board understands the programme it approves. A good staff programme combines short, regular modules with realistic phishing simulations and role-based training for IT, finance and anyone with privileged access. See our security awareness program guide and our guide to protecting against social engineering.

If your board has not yet had NIS2 training, or last year’s session was a generic slide deck, AceFortis can help. We run practical sessions for boards and management teams built around your sector and your real risks, with a scenario exercise and documentation you can file as evidence. Get in touch to plan a session.

FAQ

Does every board member have to be trained, or just one?

Article 20(2) refers to the members of the management bodies, so plan to train all of them. In Italy, ACN’s FAQs state that the training duty cannot be transferred to specific members.

Can the CISO take the training on the board’s behalf?

No. The requirement is for members of the management body to follow training themselves. The CISO can help design or deliver it, but cannot replace it.

Does a certificate from an online course satisfy Article 20(2)?

The directive does not require a specific certificate. What matters is whether the training gives directors enough knowledge to identify risks and assess risk-management practices in your organisation. Generic courses can help, but tailored content and a scenario exercise make a much stronger case.

Does training protect directors from liability?

Not by itself. Liability attaches to infringements of Article 21. Training helps directors carry out effective oversight and shows they took their duties seriously, which is the best protection available.

Sources

  • Directive (EU) 2022/2555 (NIS2), Articles 20, 21, 32 and 34 – EUR-Lex
  • ACN – NIS FAQ: roles and procedures (management bodies)
  • ACN – NIS (Network and Information Security)
  • ENISA – NIS2 Technical Implementation Guidance

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NIS2 Compliance Checklist: Article 21 Evidence Guide
NIS2 Directive Explained: Scope, Duties and Fines
NIST CSF 2.0 Explained: Functions, Tiers, Profiles
ISO 27001:2022 Implementation Roadmap for SMEs
TAGGED:Article 20Board trainingCyber governanceManagement liabilityNIS2

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ByAkash Kumar
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Akash Kumar, founder of AceFortis. Penetration tester and cybersecurity trainer based in Milan, and cybersecurity instructor at DEMOS Fondazione ITS. Expertise: penetration testing, red teaming and Active Directory security. I offer security awareness training, phishing simulations and courses on NIS2, DORA and ISO 27001 for companies and institutions, in English and Italian. Certifications: CPENT, CRTA, eJPT, PT1.
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