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Continuous Monitoring for ISO 27001 and NIS 2

Written by Maiky | Feb 4, 2026 5:43:20 PM

Many organisations treat ISO 27001 and NIS 2 as projects with a finish line. In reality, both frameworks require continuous oversight of security controls, risks and operational processes. Supervisory authorities across the EU are making it clear that compliance must be active, not static. This means organisations need mechanisms that detect changes, flag deviations, verify effectiveness and guide improvement throughout the year.

This article explains what continuous monitoring means within the ISO 27001 standard and the NIS 2 Directive. It also describes how SMEs, enterprises and public-sector organisations can apply it in a practical and measurable way.

 

Understanding continuous monitoring in ISO 27001

ISO 27001 presents the information security management system as a cycle. It requires regular measurement, review and correction. The standard does not expect organisations to implement controls once and assume they remain effective. Instead, controls must be monitored for fitness, accuracy and performance over time.

Continuous monitoring applies to several parts of ISO 27001:

1. Risk monitoring

Risks evolve as systems change, vendors introduce new dependencies, employees join or leave, and threat actors develop new techniques. ISO 27001 requires organisations to:

  • Reassess risks whenever significant changes occur.
  • Maintain a risk register that reflects current reality.
  • Ensure risk owners evaluate treatment plans regularly.

Many organisations treat risk assessments as annual exercises. This creates blind spots. Continuous monitoring means adopting a predictable schedule and complementing it with on-demand reviews triggered by changes in technology, operations or regulation.

2. Control monitoring

Annex A controls must be monitored for effectiveness. This includes technical controls such as logging, authentication and access restrictions, but also administrative controls including onboarding processes, physical access rules and supplier review mechanisms.

Examples of continuous checks include:

  • Ensuring logs are being collected properly.
  • Reviewing privileged access lists and validating necessity.
  • Confirming backups have completed successfully.
  • Verifying that outdated systems are decommissioned.
  • Reviewing supplier security documentation.

Monitoring must be documented to provide auditors and regulators with evidence that controls function as intended.

3. Performance measurement

ISO 27001 requires organisations to define metrics for their ISMS. Continuous monitoring means tracking indicators that show whether security activities produce the intended results.



  • Percentage of completed security awareness training.
  • Mean time to detect and respond to incidents.
  • Frequency of failed access removal after employee departure.
  • Changes in backup success rates.
  • Number of overdue supplier reviews.

Metrics are essential to understanding trends and identifying weak points before they become incidents.

4. Internal audit follow-up

Internal audits highlight nonconformities and improvement opportunities. Continuous monitoring requires:

  • Tracking corrective actions to completion.
  • Reassessing problem areas to confirm effectiveness.
  • Ensuring improvements are embedded into processes and not simply documented.

 

What continuous monitoring means for NIS 2

NIS 2 creates higher expectations for ongoing oversight. It requires essential and important entities to maintain ā€œappropriate and proportionateā€ security measures and to demonstrate their effectiveness to supervisory bodies.

Continuous monitoring under NIS 2 typically involves the following areas.

1. Operational security and event logging

NIS 2 stresses timely detection of security incidents. Organisations must:

  • Collect logs from critical systems.
  • Monitor events for anomalies.
  • Integrate security tools so information flows to the right teams.
  • Maintain retention periods that support investigations.

Continuous monitoring helps detect potential breaches early, which aligns with the incident reporting obligations in NIS 2.

2. Incident handling and reporting preparedness

Incident response capability must be maintained at all times. Continuous monitoring verifies:

  • That the incident response plan is up to date.
  • That on-call procedures function correctly.
  • That communication lines with authorities and partners are defined.
  • That playbooks align with national CSIRTs.

It also ensures testing takes place and lessons learned are incorporated into future exercises.

3. Business continuity and service availability

NIS 2 requires organisations to maintain resilience. Continuous monitoring includes:

  • Testing backup restoration regularly.
  • Reviewing disaster recovery plans.
  • Assessing the availability of critical services.
  • Validating redundancies across infrastructure.

Supervisory authorities often examine evidence of such tests during compliance reviews.

4. Supply chain monitoring

Supply chain security is one of the most emphasised areas of NIS 2. Ongoing compliance requires organisations to:

  • Conduct regular supplier assessments.
  • Monitor contract compliance.
  • Validate that vendors follow secure development and operational practices.
  • Review sub-processor lists and dependencies.

Continuous oversight ensures you identify new risks introduced by suppliers.

 

Why ongoing compliance matters more in the EU than ever

The shift toward continuous monitoring is driven by three EU-specific factors.

1. Regulatory expectation

NIS 2 and GDPR place increasing emphasis on accountability. Regulators expect organisations to demonstrate that controls remain effective all year. Evidence of past reviews, reports and metrics is often requested during inspections.

2. Threat landscape evolution

European organisations face threats from criminal groups, state actors, hacktivists and supply chain compromises. Static controls cannot address these evolving risks.

3. Dependency on critical digital infrastructure

Most EU sectors, particularly energy, finance, healthcare, logistics and government, rely on interconnected systems. Continuous monitoring ensures that small issues do not escalate into widespread outages.

How organisations can implement continuous monitoring in practice

Implementing continuous monitoring does not require complex tools, although automation helps. The following practical steps apply to organisations of all sizes.

1. Define a monitoring calendar

Develop a schedule that covers:

  • Monthly system health checks.
  • Quarterly access reviews.
  • Quarterly risk register updates.
  • Semi-annual supplier evaluations.
  • Annual tests of disaster recovery and incident response.

A calendar provides predictability and supports resource planning.

2. Automate where possible

Automation reduces effort and improves reliability. Relevant areas include:
  • Log analysis.
  • Vulnerability scanning.
  • Configuration monitoring.
  • Privileged access tracking.
  • Backup success notifications.

Automation tools provide alerts that feed into ISMS processes and produce evidence for auditors.

3. Establish clear ownership

Continuous monitoring is successful only when responsibilities are clearly assigned. Define who reviews access, who validates backups, who maintains metrics and who reports deviations.

4. Align monitoring with risk

Not all assets require the same frequency of checks. Critical systems require more rigorous oversight, while low-impact systems may be monitored less frequently. This approach supports proportionality and keeps efforts manageable.

5. Record evidence of activities

Auditors and regulators will ask for proof of monitoring activities. This includes:

  • Logs of reviews.
  • Screenshots of backup validation.
  • Records of supplier assessments.
  • Output from vulnerability scans.
  • Meeting minutes for risk discussions.

Evidence demonstrates that your ISMS is functioning rather than simply documented.

 

How continuous monitoring strengthens ISO 27001 and NIS 2 alignment

ISO 27001 and NIS 2 share several overlapping areas where continuous monitoring provides structure and clarity.

1. Governance and accountability

Monitoring demonstrates leadership involvement and supports management reviews required by ISO 27001 Clause 9 and governance expectations in NIS 2.

2. Incident detection and reporting

ISO 27001 A.8.15 (Logging), A.8.16 (Monitoring activities), and A.6.8 (Information security event reporting), along with NIS 2 Article 23 on incident reporting, require timely detection and reporting. Continuous monitoring ensures issues are identified before they escalate.

3. Operational resilience

Both frameworks place importance on business continuity. Continuous monitoring provides evidence of resilience and readiness.

4. Supply chain oversight

Continuous supplier assessments address ISO 27001 Annex A.5.19 to A.5.23 and NIS 2 Article 21 on supply chain security.

Conclusion: continuous monitoring creates real compliance and real security

For EU organisations, ongoing compliance is not optional. ISO 27001 requires it. NIS 2 demands it. Customers and partners expect it. Continuous monitoring transforms information security from a point-in-time exercise into a living system that responds to change and demonstrates trustworthiness.