Cybersecurity Act (Cbw) & NIS2
The new law for registration, notification and duty of care is final. Nestor Security helps you comply on time and demonstrably.
The new law for registration, notification and duty of care is final. Nestor Security helps you comply on time and demonstrably.
Cbw declaration
More and more clients are asking whether you comply with the Cyber Security Act (Cbw), the Dutch implementation of NIS2. With an independent statement, you show in black and white that your security is in order.






















Since August 15, 2026, the Cyber Security Act has been in effect, without a transition period. Organizations that fall under it must be able to prove that their security is in order. They also require their suppliers to provide this proof.
Does this look familiar?
You register your organization with the NCSC. This way the government knows that you are covered by the law and can alert you quickly in the event of a threat.
You take appropriate measures based on an up-to-date risk analysis. The law lists ten topics, including the security of your suppliers.
Report serious incidents to the NCSC in three steps, from a first warning to a final report.
The board approves the measures, monitors their implementation and provides mandatory training.
The Cbw does not issue a certificate or declaration. You choose for yourself how to demonstrate that your measures are in order, and your customers decide which evidence they accept. The three most commonly used forms of evidence are related to each other in this way.
| Cbw declaration | ISO 27001 or NEN 7510 | NIS2 Supply Chain certification | |
|---|---|---|---|
| What you receive | A report with the opinion of an independent auditor | A certificate, with annual control audits | A certificate at the achieved level |
| Tested by | Special requirements for the Cbw, tailored to your organization | A fixed international standard, not specific to the Cbw | Fixed NIS2 requirements per level, from SC10 to SC30 |
| Who is checking? | An EDP auditor register (RE) | An accredited certifying body | An audit company recognized by the certification mark |
| Lead time | 16 weeks, or 8 weeks if the evidence is ready | Often 4 to 6 months or longer | Usually 2 to 6 months |
| Fits especially well with | Organizations under the Cbw and their suppliers | Organizations that want to ensure security on a structural level | MKB suppliers with limited risk |
If you are a supplier with limited risk, the SC10 level certification may suffice. If you have access to systems or sensitive customer data, or your customer requests the opinion of a RE, a tailored statement is a better fit. Nestor Security also guides projects for ISO 27001, NEN 7510 and the NIS2 Supply Chain certification. In the initial consultation, we will discuss together which form best suits you.
A statement is not a certificate, but an opinion from an auditor. In Denmark, suppliers already show their customers that they comply with NIS2 with such a statement. That’s how your statement is structured.
The international standard by which auditors issue an independent statement. Your client’s auditor recognizes him immediately, and there is room to adapt the requirements to your organization.
A formal assessment by an independent auditor of your measures, so not a statement you make yourself. This gives it weight with customers, management and regulators.
In the report, this is referred to as the object of research. What falls under it, we determine together during the initial meeting, so that the explanation aligns with the questions of your customers.
This is called the standard framework, the set of requirements that the auditor checks against. We’ll keep it short and align it with the Cbw and your working methods. This usually results in fewer incorrect findings.
A RE is bound by the professional rules of NOREA, the professional organization of IT auditors. On route 1, an external RE draws up the contract, on route 2 an RE from Nestor Audit.
If you need help drafting the requirements and collecting evidence, Nestor Security can guide you through the process. If you have your own security or audit team that will provide the evidence, Nestor Audit will carry out the audit alone.
We set the requirements, collect and verify the evidence together with you, arrange the contact with the external auditor and guide the audit.
We conduct the audit in collaboration with your security or internal audit team. The statement is signed by a registered EDP auditor from Nestor Audit.
Nestor Security provides guidance, Nestor Audit performs the audit. Since advice and audit are never provided by the same people, the independence of your statement is guaranteed.
A clear approach in four stages, with a fixed contact person. With guidance, you have the signed declaration within 16 weeks. If you choose route 2 and the proof is ready, that takes 8 weeks. In the initial meeting, we make the planning for you concrete.
Your statement contains an independent assessment of your measures. You share it with customers, management, and regulators and renew it every year. Upon completion, you can choose a one-year contract, with a mid-term check after six months and a repeat audit after twelve months.
Your certificate already covers much of what the Cbw requires. With a declaration, you show that your existing measures also cover the additional Cbw requirements, such as the reporting obligation and the role of the board. We use your certificate and measures as proof in this process.
Still no certificate?
No problem. With a Cbw declaration, you demonstrate that you comply with the Cbw requirements, without having to set up a complete management system first.
Organizations that fall under the Cbw register themselves in the NCSC register via MyNCSC. After that, you will also have access to the services of your CSIRT, the team that helps with digital incidents.
The duty of care also applies to your suppliers. You assess their risks and establish security arrangements in contracts.
An ISO certificate sometimes applies to a part of the organization. The duty of care applies to all network and information systems that you use for your work and your services.
ISO 27001 requires a process for incidents, but not legal deadlines. Under the Cbw, you report a serious incident within 24 hours to the NCSC, with a follow-up report within 72 hours and a final report within one month.
The board approves the measures, monitors their implementation and undergoes training, as evidenced by a certificate. Board members are in office until August 15, 2028.
The Cbw explicitly mentions multifactor authentication, secure communication and emergency communication. Under ISO 27001, such choices depend on your own risk analysis.
You are in good company with Nestor.
The communication lines with Nestor Security were short. The organization has a pragmatic mindset and is a down-to-earth party to do business with. As a result, the process went smoothly and fairly quickly.
We prefer to work together as much as possible regionally and like to hold meetings face-to-face. When you look at partners in the North, there are still a few left, and Nestor Security stands out above the rest.
Nestor Security has provided the internal audits of ISO 27001 and ISO 27701 for us. They really hit the mark for us with a good combination of quality and practicality. They are pragmatic, think well with our needs, and the audits are well-managed.
Nestor Security helps organizations use information securely and practically. We advise and implement, with an approach that puts your core activities at the center.
Through Nestor Audit, we have three registered EDP auditors who carry out the audits. You work with short lines and a fixed point of contact, without the complexity and fees of a large accounting firm.
Register of EDP Auditors (RE)
Guidance to the declaration (route 1) costs from €12,500. If you choose only the audit by Nestor Audit (route 2), you pay from €6,500. All amounts are exclusive of VAT.
The exact price depends on what we are investigating and how many requirements there are. After the initial meeting, you will receive a proposal with scope, planning, and price within two working days.
No. The Cbw does not issue any statements or certificates. However, you must be able to demonstrate that you are taking appropriate measures, including with your suppliers.
An independent statement is the clearest way to demonstrate that. The regulator itself will assess whether you comply with the law.
You renew the statement every year so that your evidence remains up to date.
Upon completion of the installation, you can choose a one-year contract, with a mid-term check after six months and a repeat audit after twelve months.
The Cbw applies to organizations in 18 sectors, such as energy, transport, healthcare, digital infrastructure, ICT services, waste management, production and food. Within those sectors, it concerns organizations with a minimum of 50 employees, or an annual turnover and balance sheet total of more than 10 million euros. Some organizations are included regardless of their size.
That is up to you to decide. The government does not usually designate organizations. The NIS2 self-assessment by the NCSC will help you determine whether your organization is subject to the law.
Yes. The statement is intended to be shared with customers, management and regulators.
This way you answer customer questions with an independent judgment, instead of having to fill in every questionnaire again.
Advice and audits are never given by the same people. An auditor therefore never assesses work that he or she has personally contributed to.
Therefore, you choose beforehand for guidance by Nestor Security or for the audit by Nestor Audit. This ensures the independence of your statement, also for your clients and the supervisory authority.
NIS2 is a European directive. Each EU country translates it into its own legislation, and in the Netherlands that is the Cyber Security Act. Your obligations therefore come from the Cbw, not directly from the directive.
The specific requirements are set out in the Cyber Security Decree and in sector-specific regulations. The Cbw replaces the Network and Information Systems Security Act (Wbni).
You have a considerable advantage, but you don't automatically qualify. The law also requires registration with the NCSC, reporting deadlines of 24 and 72 hours, and a board that approves, monitors, and undergoes training.
With a declaration, you show that your existing measures also meet the Cbw requirements. We use your certificate and measures as proof.
With route 1, we help you resolve any findings. That is standard part of the guidance.
With route 2, Nestor Audit performs the audit in collaboration with your own team. We do not resolve findings, as advice and audit remain strictly separate.
With guidance, you have the signed declaration 16 weeks after the initial meeting. If you already have ISO 27001 or NEN 7510, that is 10 weeks.
If you choose route 2 and your own team provides the proof, you will receive the certificate within 8 weeks.