Cyber Fundamentals

Important: Certification or self-assesment under Cyber Fundamentals is optional. Compliance with NIS2 will always be a matter determined by the relevant National Competent Authority (NCA) empowered by legislation. CyFun is one recognised way to organise and evidence your controls, not a statutory presumption of compliance.

Ireland has joined the Cyber Fundamentals Framework (CyFun), originally developed in Belgium, as a scheme co-owner. The CyFun frameowork provides a structured, risk-based approach for essential and important entities to help entities organise and evidence their NIS2 security measures.

The NCSC recommends the CyberFundamentals (CyFun) framework (NIST CSF 2.0 version) as a well-recognised, structured, voluntary tool to assist entities in meeting their NIS2 obligations. CyberFundamentals provides a tiered, standards-based framework grounded in the NIST Cybersecurity Framework v1.1, soon to transition to v2.0 (Q3 2025). Version 1 is available for use now, however we will be using the second version due September 2025. Further information is available at CyberFundamentals Framework | CCB Safeonweb

Certification through CyberFundamentals will be optional but is seen as a strong and credible route to support compliance and can also serve as a business enabler and trust-building mechanism in supply chains and regulatory contexts.

A national certificationsystem will take 18-24 months to establish due to the need for legal agreements, resourcing, and accreditation infrastructure.
In the mean time, entites are encouraged to use the framework internally and being preparations.

How the Cyber Fundamentals Scheme Works

CyFun is a structured framework designed to provide a risk-based approach to cybersecurity, built around a model that allows organisations to be assessed at different levels of maturity. It is fundamentally based on the NIST Cybersecurity Framework (CSF), which is widely recognised internationally, and serves as the foundation for many cybersecurity assurance schemes.

At the core of the scheme is an initial selection tool that enables an organisation to determine its cybersecurity maturity level. This assessment considers factors such as the organisation's size, sector, risk exposure, and the potential impact of a security incident. Based on this assessment, the organisation is assigned one of three levels (Small, Basic, Important, Essential) of security maturity, ranging from foundational cybersecurity controls at the lower levels to more stringent requirements for high-risk entities.

For organisations classified as important or essential under NIS2, CyFun provides a pathway to certification or formal assurance. This ensures that organisations with a high degree of societal or economic importance can demonstrate compliance through a structured, externally validated process. Once the forthcoming update is released, the scheme's reliance on NIST CSF V2.0 provides a well-established framework structured around six key cybersecurity functions:

By structuring compliance around these core principles, CyFun provides a flexible but comprehensive framework that can be adapted across multiple sectors.
CyFun is currently being updated to reflect the NIST CSF v2.0 changes. The NCSC is contributing to this update, which is expected to be completed by Q3 2025.

The Role of CyFun in Ireland's Compliance Framework

The development of Ireland's NIS2 compliance framework will be underpinned by the requirements set out in the National Cyber Security Act (once published), and any subsequent associated statutory instruments. The primary legislation will establish the overarching security obligations, while subsequent statutory instruments will provide more detailed requirements, including the risk management measures essential and important entities must implement. CyFun will serve as a key component of this compliance structure, both informing the statutory instrument and acting as a recognised means by which entities can clearly demonstrate compliance.

The scheme does not, however, represent the sole route to compliance, and will be optional and voluntary. The NCSC will continue to recognise other internationally accepted standards such as ISO 27001 for information security and ISO 62443 for industrial control systems. Similarly, direct assessments carried out by National Competent Authorities (NCAs), or self-assessments for lower risk entities may also occur where appropriate. This approach is designed to provide flexibility, ensuring that organisations can meet their obligations in a way that aligns with their existing security frameworks while maintaining consistency with the Directive's core requirements.

Cyber Fundamentals Resources

While the NCSC will develop specific resources and guides for the operation of CyFun in Ireland, there is already signifiacnt amount of tooling and supports availble from the CCB on their CyFun home page.
There is also an FAQ page available here: CyFun FAQs.

Centre for Cybersecuirty Belgium

Safe on Web

NIS2: RMMs & CyFun

NIS2: CyFun & RMMS Videos

Video frame from CyFun introduction

Risk Management Measures

The Risk Management Measures (RMMs) published by the NCSC provide detailed guidance on the measures the NCSC believe are the minimum required to meet the obligations of NIS2 for essential and important entities.

The RMMs are aligned with the Commission's Implementing Regulation for cross-border entities from the Digital Infrastructure and Digital Service Provider' sector. The RMMs represent the minimum baseline of compliance and represent the ‘what' organisations need to do. Organisations can use various frameworks, like ISO 27001, COBIT, NIST or their own Information Security Management System to meet these requirements. However, the NCSC is recommending CyFun as the preferred method to demonstrate compliance.

NIS2 National Competent Authorities may wish to use CyFun as a preferred method for compliance to be demonstrated by the respective essential and important entities. The NCSC's National Competent Authority for Public Administration proposes to use CyFun as the preferred approach with public administration entities in scope of NIS2.
Further details on the Risk Management Measures are in the guidance document.

Front Cover of Draft Risk Management Measures Guide