Published on: 2025-11-28

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Intelligence Report: After NIS-2 Takes Effect New Study From Data Reverse Shows Only 4 of German Companies Have an External Data Recovery Partner in Their Emergency Plans

1. BLUF (Bottom Line Up Front)

The recent study by Data Reverse highlights a significant gap in compliance with NIS-2 regulations among German companies, with only 4% having an external data recovery partner. This suggests a widespread underestimation of cybersecurity risks and potential legal liabilities. The most likely hypothesis is that companies are inadequately prepared due to a lack of awareness and resources. Overall confidence in this assessment is moderate, given the limited scope of the data.

2. Competing Hypotheses

• Hypothesis A: German companies are not fully compliant with NIS-2 requirements due to a lack of awareness and understanding of the regulations. Supporting evidence includes the high percentage of companies unaware of their obligations and the absence of external data recovery partners. Key uncertainties involve the actual level of awareness and the effectiveness of internal recovery measures.
• Hypothesis B: Companies are aware of NIS-2 requirements but are deliberately non-compliant due to cost-saving measures or perceived low risk. This is contradicted by the reported lack of realistic self-assessment and the significant deviation from regulatory requirements.
• Assessment: Hypothesis A is currently better supported due to the evidence of widespread ignorance and inadequate self-assessment. Indicators that could shift this judgment include new data on company awareness campaigns or changes in compliance rates following regulatory enforcement actions.

3. Key Assumptions and Red Flags

• Assumptions: Companies have the capability to comply if aware; NIS-2 enforcement will increase compliance; external data recovery is critical for effective disaster recovery.
• Information Gaps: Detailed data on company size and sector-specific compliance; effectiveness of internal data recovery processes.
• Bias & Deception Risks: Potential bias in survey responses due to self-reporting; risk of companies overstating compliance to avoid penalties.

4. Implications and Strategic Risks

The lack of compliance with NIS-2 regulations could lead to increased vulnerability to cyber incidents, legal liabilities, and reputational damage for German companies.

• Political / Geopolitical: Potential for regulatory scrutiny and pressure from the EU on Germany to enforce compliance more strictly.
• Security / Counter-Terrorism: Increased risk of cyber-attacks exploiting weak recovery processes, potentially affecting critical infrastructure.
• Cyber / Information Space: Greater exposure to ransomware and data breaches due to inadequate disaster recovery planning.
• Economic / Social: Financial losses from cyber incidents could impact economic stability and public trust in digital services.

5. Recommendations and Outlook

• Immediate Actions (0–30 days): Conduct targeted awareness campaigns to educate companies on NIS-2 requirements; initiate audits of high-risk sectors.
• Medium-Term Posture (1–12 months): Develop partnerships with cybersecurity firms to enhance recovery capabilities; implement regular compliance checks.
• Scenario Outlook:
  • Best: Rapid increase in compliance following awareness efforts, reducing cyber risks.
  • Worst: Continued non-compliance leading to significant cyber incidents and regulatory penalties.
  • Most-Likely: Gradual improvement in compliance as awareness and enforcement increase.

6. Key Individuals and Entities

• Data Reverse (Study Conducting Entity)
• Jan Bindig (Managing Director, Data Reverse)
• Not clearly identifiable from open sources in this snippet.

7. Thematic Tags

Cybersecurity, NIS-2 compliance, data recovery, German companies, regulatory enforcement, business continuity, disaster recovery

Structured Analytic Techniques Applied

• Adversarial Threat Simulation: Model and simulate actions of cyber adversaries to anticipate vulnerabilities and improve resilience.
• Indicators Development: Detect and monitor behavioral or technical anomalies across systems for early threat detection.
• Bayesian Scenario Modeling: Forecast futures under uncertainty via probabilistic logic.
• Network Influence Mapping: Map influence relationships to assess actor impact.

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