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Implementation of NIS2, SOC, and SIEM for Funds

Cybersecurity that protects not only the fund but also the value of the entire portfolio

As an investment fund, you are responsible not only for your own security but also, indirectly, for your portfolio companies’ compliance with the NIS2 Directive. Non-compliance by a portfolio company in a critical sector poses a real risk today to valuation, the due diligence process, and a secure exit. ITH supports organizations at every stage of NIS2 implementation. We provide 24/7 security monitoring (SOC) and a SIEM system that detects threats before they disrupt business continuity.

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What is the NIS2 Directive?

The NIS2 Directive harmonizes cybersecurity requirements across the EU and introduces stronger oversight and enforcement mechanisms than the previous NIS Directive from 2016.
In Poland, the regulation was implemented as an amendment to the Act on the National Cybersecurity System. The new NIS2 provisions have been in force under Polish national law since April 3, 2026. Companies that met the criteria on the date the Act entered into force have until April 3, 2027, to implement the required procedures. Critical entities are additionally required to conduct their first security audit by April 3, 2028.

Who is affected by NIS2—critical sectors, including financial market infrastructure

The NIS2 Directive covers 18 economic sectors that are critical to the functioning of the state and classifies entities as either critical or important. These include financial market infrastructure and the banking sector.

For an investment fund, it is crucial that NIS2 applies not only to financial institutions that manage capital, but above all to portfolio companies operating in the following sectors: medtech and healthtech startups, digital infrastructure companies, medical device manufacturers, and service providers to public administration. Even micro and small portfolio companies may be indirectly subject to NIS2 through the supply chain of a larger counterparty in a critical sector.

Don't risk fines. Check whether NIS2 applies to your company

Fill out the survey What is NIS2?

New Obligations for Funds Under NIS2

NIS2 imposes obligations on both the fund itself and the companies in your portfolio that operate in key sectors. The most important of these include:

  • Implementation of Risk Management Measures

    commensurate with the estimated risk and actual threats to which the IT systems and the networks and IT systems used to serve customers are exposed.

  • Regular audits

    that demonstrate compliance with safety requirements. You are required to provide up-to-date audit documentation upon request by the competent authorities.

  • Reporting incidents to the CSIRT within strictly defined timeframes:

    1. Initial report: within 24 hours of the incident being detected;
    2. supplementary report: within 72 hours of becoming aware of the incident;
    3. Final report: within one month of the incident’s conclusion.

  • Business Continuity and Crisis Management

    disaster recovery plans and response procedures that must withstand the test of a real-world attack, not just a paper audit.

  • Supply chain security as a mandatory element of compliance.

  • Regular training and raising awareness among employees throughout the organization.

    A portfolio company’s failure to comply with regulations poses not only the risk of administrative sanctions for the fund, but also operational and reputational risks that directly affect the value of the investment.

Penalties and Personal Liability for Noncompliance

Failure to comply with NIS2 regulations carries real risks—not only financial, but also personal for senior management:

  • The maximum administrative fine for key entities may be up to 10 million euros or 2% of the organization’s annual turnover. The higher amount applies.
  • The management board bears personal responsibility for any failure to properly implement compliance measures. Penalties for the management board include a ban on holding executive positions. Additional sanctions may include fines of up to 300% of their compensation.
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Why should investment funds make NIS2 a priority?

Cybersecurity has become part of due diligence

Institutional investors and buyers in exit transactions are increasingly asking directly about compliance with NIS2 and whether the company has a SOC or SIEM system...

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An incident at a single portfolio company affects the entire fund

A data breach or ransomware attack at a company in a critical sector creates reputational risk that spreads across the entire portfolio.

Compliance increases a company's value upon exit from an investment

An information security management system, audits, and a track record of incident reporting are a strong selling point in discussions with potential investors.

Comprehensive protection for funds—four pillars of a single offering

ITH will guide your fund through the entire implementation process: a single audit, a consistent process managed by a single provider.

1. NIS2 Implementation —From Audit to Certification

We start with an audit to identify cybersecurity vulnerabilities. The next step is to prepare comprehensive documentation ready for inspection and to train the entire team. We conclude the implementation process with a final report and the launch of ongoing monitoring.

2. SOC - Your infrastructure protected 24/7/365

Our team of analysts monitors your infrastructure around the clock. We provide real-time threat detection and support your organization in responding to incidents, even at night and on weekends.

3. SIEM - Full Visibility of the Infrastructure

This system collects and correlates events from servers, network devices, and endpoints in a single location and detects potential threats before they disrupt your business operations.

4. Cybersecurity Training — An Informed Team as the First Line of Defense

The goal of these training sessions is to prepare organizations for compliance audits and to increase their overall resilience against cyberattacks. Don’t let your company become an easy target. Regular training helps employees respond effectively to constantly evolving threats.

SOC for Funds

ITH SOC is a team of analysts that takes on the responsibility of continuously monitoring the fund’s infrastructure and real threats before they lead to serious financial and reputational damage:

  • 24/7/365 Monitoring — ITH ensures your organization’s security around the clock.
  • Real-time threat detection, with a response time of less than 15 minutes and immediate isolation of compromised systems.
  • Ransomware protection involves detecting characteristic file-encryption patterns before any loss of transaction data or investor data occurs.
  • Detection of phishing and BEC, including attempts to impersonate fund partners or the management of portfolio companies in communications regarding wire transfers.
  • Complete incident documentation in accordance with NIS2 requirements and timely reporting to the relevant authorities.
  • Periodic Report (Monthly and Quarterly Risk Overview) — a document that the fund can use in its reporting to investors and the investment committee.
Learn more about SOC ITH

SIEM - A Single View of Fund Security

The ITH SIEM system collects logs from various sources, correlates security events, and delivers real-time security alerts.

SIEM collects data from:

  • EDR/XDR systems and the team’s client workstations (Windows/Linux/macOS),
  • servers and IT systems used to manage investor data,
  • firewalls, IDS/IPS systems, and network devices,
  • backup systems and data recovery procedures,
  • cloud environments and third-party integrations.

A managed SIEM eliminates the need to invest in licenses, infrastructure, or your own cybersecurity specialists. You receive a ready-to-use environment maintained by ITH experts.

See the full capabilities of ITH SIEM

Cybersecurity Training for Funds and the Management Boards of Portfolio Companies

Even the best-secured infrastructure won’t help if a team member opens a malicious attachment or provides login credentials in response to a fraudulent phone call. Our training programs combine theory with practice. The hands-on components of the training help employees understand that their everyday decisions matter for the security of the entire company.

Choose the plan that's right for your organization:

2 HOURS

Basic Security Training

The perfect introduction for all employees. Raising awareness of everyday hazards.

  • Due Diligence in Data Protection—Legal Basis
  • Password Creation and Multi-Factor Authentication (MFA)
  • Recognizing Phishing
  • No limit on the number of participants—the ability to train the entire organization at once
I choose
MOST POPULAR
4 HOURS

Standard Security Training

It expands participants' knowledge of the practical aspects of information security. Each participant receives training materials and a certificate.

  • Data Security for Data Processed in the Cloud and on Mobile Devices
  • Legal obligations (NIS2, GDPR)
  • Social Engineering in Business Relationships
  • Training materials and a personalized certificate for each participant
I choose
6 HOURS

Premium Security Training

Advanced incident response procedures and crisis management for IT and security personnel and executive management.

  • Attack simulations—deepfakes, spoofing
  • Documentation as evidence of due diligence before the supervisory authority
  • "Before" and "After" Knowledge Tests
  • +1 hour of consultation in areas requiring improvement
I choose

Why do funds choose ITH?

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One partner, a complete security ecosystem

Audits, NIS2 and SOC implementation, SIEM, training, as well as internet services, colocation, backup, and managed firewalls—all from a single...

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Operator with its own network

ITH is not only a security integrator but also an electronic communications provider with full visibility into network traffic. This...

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Scalability without renegotiating the contract

Is the fund's portfolio growing, with more companies being added to the coverage? The scope of our service grows along...

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Over 20 years of experience

The ITH team has many years of experience in the IT and telecommunications markets—we design, maintain, and secure networks and...

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Compliance that can be demonstrated to an investor

The documentation, reports, and procedures prepared by ITH serve as ready-to-use evidence during security audits, funding rounds, and exit processes.

Don't wait for the first inspection or the first incident

Implementing NIS2 is a process that takes time. The sooner you start preparing, the better your chances of avoiding costly consequences.

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    FAQ

    It depends on the fund’s structure and whether its investment activities qualify as part of the financial market infrastructure within the meaning of the Act on the National Cybersecurity System. Regardless, the obligations under NIS2 almost certainly apply to some of the companies in the portfolio. In most cases, it is these companies that generate the risk, which ultimately falls on the fund.

    Yes, this is one of the most common scenarios when working with funds. ITH applies a single, consistent audit methodology to all companies in its portfolio, which allows the fund’s partners to compare compliance levels and risks across investments and prioritize corrective actions.

    In accordance with NIS2 security requirements, a multi-stage model is in place: an early warning within 24 hours of detection, a detailed incident report within 24–72 hours, and a periodic report within one month. The ITH SOC maintains this documentation on behalf of the organization, ensuring compliance at every stage.

    Yes—the monthly and quarterly risk overview reports, as well as the NIS2 documentation, are materials that effectively shorten the due diligence process conducted by a prospective investor or buyer.