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Cybersecurity

NIST CSF 2.0

We assess your maturity against the NIST Cybersecurity Framework 2.0 and then close the gaps with you, from the initial assessment through a well-founded target profile to the control that actually works in operations. This works on its own, alongside an ISMS based on ISO 27001, with the CIS Controls as the technical layer, or as an organizing framework for the obligations under NIS2 and DORA.

The Big Picture

Why, what and how: where the NIST CSF fits

Before we get to the framework itself, some context. NIS2, ISO 27001, CIS Controls, NIST CSF: these names are constantly mentioned in the same breath, even though they do not belong to the same category at all. They answer three different questions, and the quickest way to understand this is a single example that runs through all three levels.

One question, three levels: is multi-factor authentication required?Click an instrument to see its answer
Why
Do we have to at all, and who is liable?
Laws and requirements

Section 30(2) no. 10 BSIG explicitly requires entities in scope to use “solutions for multi-factor authentication or continuous authentication”. Which access paths it applies to, which method to use and how compliance is measured are not in the law.

What
What must be achieved in the end?
Framework and management system

The CSF states outcome PR.AA-03 as: “Users, services, and hardware are authenticated.” Six words, no method. The same outcome applies to a craft business with twelve computers and to a bank; only the path there differs.

How
What do we actually use to implement it?
Control catalog

MFA for all externally exposed applications, your own and third-party ones, where supported. Enforcement through a directory service or SSO provider explicitly counts as fulfilled. A sentence that can be answered with yes or no.

The law establishes the obligation, the framework translates it into an outcome, and the control catalog makes it verifiable. Anyone who only reads the law does not know when they are done. Anyone who only works through the catalog cannot explain why.

The Point
It doesn’t always have to be ISO 27001

This chain works entirely without a certificate. The BSIG requires appropriate measures and their documentation; international standards are to be taken into account, not acquired. Even the obligation to provide evidence under Section 39 BSIG applies only to operators of critical facilities and explicitly allows security audits and inspections in addition to certifications. So if you are not under hard pressure to provide evidence to customers, regulators or insurers, you will reach demonstrable security faster with the CSF as the structure and the CIS Controls as the implementation: no purchase of standards, no audit cycle, no ISMS administration.

You need a certificate when someone wants to see one. You need effective security either way.

Our own illustration. Sources: Section 30(2) BSIG, Article 9(4) DORA, NIST CSWP 29 (PR.AA-03), ISO/IEC 27001:2022 Annex A 8.5 and CIS Controls v8.1 (Safeguards 6.3 to 6.5).
The Basics

What is the NIST Cybersecurity Framework?

The NIST Cybersecurity Framework 2.0 is not a catalog of controls but a common language for cybersecurity: 106 desired outcomes, organized into six functions from Govern through Identify, Protect, Detect and Respond to Recover. It describes what must be achieved and deliberately leaves open how.

It is published by the National Institute of Standards and Technology, the US standards agency. Version 2.0 was released on February 26, 2024, the first fundamental revision since 2014. The former title “Framework for Improving Critical Infrastructure Cybersecurity” has been dropped: the framework is now explicitly aimed at organizations of any size and sector. It is free to use.

This is where most misunderstandings begin. The CSF does not prescribe controls, and NIST says so in the document itself: the outcomes are not a checklist of actions to perform. Outcome PR.AA-03 reads in full: “Users, services, and hardware are authenticated.” There is nothing there about multi-factor authentication. That is intentional: the same wording has to work for a craft business with twelve computers and for a bank.

Function
PROTECT (PR)1 of 6 functions
Safeguards to manage the organization’s cybersecurity risks are used
Category
PR.AA1 of 22 categories
Identity Management, Authentication, and Access Control
Outcome (Subcategory)
PR.AA-031 of 106 outcomes
Users, services, and hardware are authenticated
This is where the framework ends
Not in the frameworkprovided by the CIS Controls, ISO 27001 Annex A or your own decision
MFA on all externally exposed access points, conditional access, passkeys
Our own illustration based on NIST CSWP 29, Appendix A. From general to specific, but only down to the outcome: how it is achieved is up to the organization.

The CSF thus answers two questions: what must be achieved and how good you are at it. The third, how to do it, it deliberately leaves open. That is why it does not compete with ISO 27001 or the CIS Controls: it is the map, not the to-do list.

The Framework

Six functions, 22 categories, 106 outcomes

The Core has three levels and leads from general to specific: six functions as a language for senior management, 22 categories for thematic structure, and 106 outcomes that the specialist team can discuss.

Govern frames the other five: the function has no protective effect of its own but determines which outcomes take priority in the first place. According to NIST, order and size say nothing about importance. With eleven outcomes, Detect is the smallest function, yet in practice it is regularly the biggest gap. Click a function to see its categories:

GOVERN6 categories · 31 outcomesframes the other five and sets their prioritiesIDIDENTIFY3 categories21 outcomesPRPROTECT5 categories22 outcomesDEDETECT2 categories11 outcomesRSRESPOND4 categories13 outcomesRCRECOVER2 categories8 outcomes
The 22 categoriesClick a function above to filter
GV.OCOrganizational ContextGovern
GV.RMRisk Management StrategyGovern
GV.RRRoles, Responsibilities, and AuthoritiesGovern
GV.POPolicyGovern
GV.OVOversightGovern
GV.SCCybersecurity Supply Chain Risk ManagementGovern
ID.AMAsset ManagementIdentify
ID.RARisk AssessmentIdentify
ID.IMImprovementIdentify
PR.AAIdentity Management, Authentication, and Access ControlProtect
PR.ATAwareness and TrainingProtect
PR.DSData SecurityProtect
PR.PSPlatform SecurityProtect
PR.IRTechnology Infrastructure ResilienceProtect
DE.CMContinuous MonitoringDetect
DE.AEAdverse Event AnalysisDetect
RS.MAIncident ManagementRespond
RS.ANIncident AnalysisRespond
RS.COIncident Response Reporting and CommunicationRespond
RS.MIIncident MitigationRespond
RC.RPIncident Recovery Plan ExecutionRecover
RC.COIncident Recovery CommunicationRecover
Bars = outcomes per category. Colors = function. Click a category for details.
Our own illustration based on NIST CSWP 29. Govern is the new addition in version 2.0 and determines which outcomes of the other five functions take priority. According to NIST, order and size say nothing about importance.
What’s New

Govern: why version 2.0 thinks differently

Version 1.1 had five functions. The sixth is more than an addition: Govern covers 31 of the 106 outcomes, almost a third of the framework. NIST shifts the focus from the technology in use to the question of who decides on what basis and who is accountable for it.

Two categories are decisive for mid-sized organizations. GV.RR explicitly holds senior leadership accountable. GV.SC dedicates ten outcomes of its own to supply chain risks, from prioritizing suppliers and contractual requirements to involving third parties in contingency planning. In version 1.1, this was a side issue.

Anyone implementing NIS2 will recognize a lot here. The CSF replaces neither the applicability assessment nor the legal obligations, but it places them in a framework that a supervisory board can also read, and it makes the state of implementation comparable from year to year.

The Working Mechanism

Tiers and profiles: where the real work happens

The framework is often reduced to its six functions. That leaves out the part that turns a taxonomy into a management tool. Tiers first, because this is where the most persistent misconception lives. Four levels describe how rigorously an organization governs its cybersecurity risks: ad hoc or by policy, case by case or organization-wide, by gut feeling or based on threat data. What they explicitly are not: a maturity model in which level 4 would be the goal for everyone.

Tier 1
Partial
Risk governance
The risk strategy is applied ad hoc; prioritization follows no objective and no threat landscape.
Risk management
Cybersecurity risks are barely recognized at the organizational level, and supplier risks usually not at all.
Tier 2
Risk Informed
Risk governance
Practices are approved by management but not established as organization-wide policy. Prioritization is already guided by objectives and the threat landscape.
Risk management
Risks are known, but an organization-wide approach is missing. Assessments take place, but not in a repeatable way.
Tier 3
Repeatable
Risk governance
Practices are formally approved and expressed as policy, implemented, reviewed and adapted when the situation changes.
Risk management
Organization-wide approach, regular exchange up to senior leadership, formal management of supplier risks.
Tier 4
Adaptive
Risk governance
Cybersecurity risks are considered in the same context as financial risks, and the budget is aligned with the expected risk environment.
Risk management
The organization continuously adapts its practices, based on lessons learned and predictive indicators, largely in real time.
Paraphrased from NIST CSWP 29, Appendix B. Deliberately not shown as a pyramid: the tiers are not a maturity model, and Tier 4 is not a goal for everyone. The right tier follows from risk and requirements.

For many mid-sized organizations, Tier 3 is the sensible target state; Tier 4 would be expensive symbolism. What matters is not the number but whether the tier fits the threat landscape and the requirements.

The second tool is the organizational profile, and it is the real engine. A profile is not a document but a distance: the Current Profile records which of the 106 outcomes are achieved today, the Target Profile which ones should be. The difference is the roadmap. NIST describes five steps for this:

Current ProfileWhere are we today?Which of the 106 outcomes are achieved,and to what extent?Target ProfileWhere do we need to be?Justified by the threat landscape,regulations and customer expectations.The gapPrioritized action planImpact before completenessupdates
  1. STEP 1
    Define the scope
    What does the profile cover? The whole organization, a business unit, or specifically a scenario such as ransomware.
  2. STEP 2
    Gather information
    Policies, risk registers, business impact analysis, applicable requirements, tools in use and roles.
  3. STEP 3
    Create the profile
    Write out the Current Profile and Target Profile. A Community Profile for your own industry can serve as a template for the target.
  4. STEP 4
    Analyze the gaps
    The distance between current and target becomes a prioritized action plan, not a list of deficiencies.
  5. STEP 5
    Implement and update
    Work through the plan and update the profile. NIST explicitly sees this as a cycle, not a project with an end date.
Our own illustration based on NIST CSWP 29, Section 3.1. NIST explicitly sees the process as a cycle that is repeated as often as needed.
The Difference

A target profile that is justified, not wished for

The weak point of the process lies in step 3: where does the Target Profile come from? Derived from gut feeling or from the wish to look good everywhere, it becomes a wish list with 106 items. This is exactly where our core approach comes in. Which adversaries are targeting your industry and your size, which techniques do they use according to MITRE ATT&CK, and which of the 106 outcomes address exactly these techniques?

This turns a prioritized target state into a justified one, and a maturity assessment into a basis for decisions. NIST provides for this in the framework itself: the Target Profile should take trends from threat data into account. Most assessments still do not.

And where does your organization stand?
We capture your Current Profile across all 106 outcomes, justify the Target Profile from your threat landscape and close the gaps with your team.
The Comparison

NIST CSF, ISO 27001 or CIS Controls?

If you have to choose between the three, here are the differences side by side:

NIST CSF 2.0ISO 27001:2022CIS Controls v8.1
TypeVoluntary frameworkManagement system, certifiableVoluntary control catalog
CharacterTaxonomy of 106 outcomes, deliberately not prescriptiveManagement system with 93 Annex A controlsPrescriptive catalog with 153 safeguards
PrioritizationDerived by you via the target profileDerived from your own risk assessmentBuilt in via three Implementation Groups
MaturityFour tiers for how rigorously risk is governedNo maturity model; conformity is auditedMeasurable implementation level per safeguard
CertificationNoneAccredited and internationally recognizedNone
Cost of the frameworkFreePurchase of the standard, audit costs, ISMS upkeepFree
Typical driverAssessing where you stand, board reporting, group mandateObligation to provide evidence to customers or regulatorsFast, measurable risk reduction

For your choice, this means: choose by the driver, not by the framework. If a customer or a regulator demands proof, there is no way around ISO 27001. If the goal is fast, measurable risk reduction, the CIS Controls are the shorter route. And the CSF is right if you first need to know where you stand, or need a language in which the specialist team and management can discuss the same situation.

Our Service

From assessment to implementation

We work along the process NIST provides, with an addition at the decisive point. And we do not stop at the roadmap:

What you getFour steps, four results
01Initial assessment
Result
Current Profile across all 106 outcomes
  • Gathered in interviews with the people who run the systems
  • Only what someone actually does day to day counts as achieved
02Target state
Result
Target Profile with a defined tier
  • Justified by your threat landscape rather than a template
  • Even if the right tier turns out to be Tier 3
  • Agreed between senior leadership and the specialist team
03Roadmap
Result
Prioritized action plan
  • With effort and ownership for each measure
  • Impact before completeness
  • Repeatable and comparable in twelve months
04Implementation
Result
Closed gaps instead of concept binders
  • We implement with your team, not alongside it
  • Technically backed by the CIS Controls
  • Compatible with an ISMS based on ISO 27001
  • Contributes to the obligations under NIS2 and DORA
No tool lock-in: you receive the profile and roadmap in a format you can keep using, not in a system you have to rent.

If you are heading toward an ISMS based on ISO 27001 anyway, the target profile gives you the prioritization that the standard itself does not provide. If you fall under NIS2 or DORA, you get a structure in which the obligations can be evidenced year after year. And if you only want to know where you stand, our work ends after the roadmap.

FAQ

Frequently asked questions about the NIST CSF

What is the NIST Cybersecurity Framework?

The NIST Cybersecurity Framework 2.0 is not a catalog of controls but a common language for cybersecurity: 106 desired outcomes, organized into six functions from Govern through Identify, Protect, Detect and Respond to Recover. It describes what must be achieved and deliberately leaves open how. It is published by the National Institute of Standards and Technology; version 2.0 was released on February 26, 2024 and is free to use.

What changed in version 2.0 compared with 1.1?

The new sixth function, Govern, accounts for 31 of the 106 outcomes, almost a third of the framework, and puts the responsibility of senior leadership at the center. Supply chain risks get their own category, GV.SC, with ten outcomes. In addition, the framework no longer applies only to critical infrastructure.

Are the four tiers a maturity model?

No, and that is the most common misunderstanding. The four tiers describe how rigorously an organization governs its cybersecurity risks, not how well it is set up technically. NIST recommends moving up only if risks or requirements increase or a cost-benefit analysis supports it. Tier 4 is therefore not a sensible goal for most organizations.

What is the difference between the Current Profile and the Target Profile?

The Current Profile records which of the 106 outcomes are achieved today. The Target Profile describes which ones should be achieved, taking into account new requirements and the threat landscape. The distance between the two is the roadmap. A Community Profile for your own industry can serve as a template.

Can you get certified to the NIST CSF?

No, there is no accredited certification as there is for ISO 27001. What is possible, and often sufficient, is a documented assessment against the 106 outcomes that can be presented to a parent company, a cyber insurer or customers.

NIST CSF or ISO 27001: which fits us?

The driver decides, not the framework. If a customer or a regulator demands proof, you need ISO 27001, because only there is an accredited certificate available. If it is about assessing where you stand, board reporting or a requirement from a parent company, the CSF is the better fit: faster, free of charge and in a language that is understood outside IT as well.

How long does a NIST CSF maturity assessment take?

That depends on the scope. For a mid-sized organization with a clearly defined scope, the Current Profile, Target Profile and roadmap can usually be completed in a few weeks. Closing the gaps takes considerably longer, and that is exactly what the prioritization is for.

Daniel Thomas Heessel
Daniel Thomas Heessel
Founder & Managing Director, Threat-Informed Cybersecurity Solutions GmbH

Daniel Thomas Heessel was named CISO of the Year 2026 and, as the security lead of an international group of companies, steered security programs along real threats. Daniel is a certified ISO 27001 Senior Lead Auditor, CISSP, CISM and MITRE ATT&CK Defender and regularly translates maturity assessments into two things: a roadmap for the specialist team and a threat picture for senior leadership.

Reviewed in September 2026. All figures, categories and quotations come from the primary source NIST CSWP 29, “The NIST Cybersecurity Framework (CSF) 2.0”, of February 26, 2024.