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Proportionate Cybersecurity for Micro-SMEs: A Governance Design Model under NIS2

Roberto Garrone

TL;DR

The paper addresses the vulnerability of micro-SMEs to cyber threats amid compliance burdens by proposing a proportionate, awareness-first governance design. It develops a seven-dimension architecture derived from EU Squad 2025 experience and validates it through a two-stage policy analysis that maps each dimension to regulatory frameworks such as NIS2, ISO/IEC 27005, and ENISA guidance. Key contributions include a scalable, practical governance template that prioritizes awareness and simple, high-impact controls before heavier obligations, with explicit mapping to regulatory scope and required complementary actions. The work offers EU and national policymakers a workable path to enhance SME cyber resilience under NIS2 and related instruments, bridging voluntary guidance with formal requirements and enabling phased, cost-conscious implementation.

Abstract

Micro and small enterprises (SMEs) remain structurally vulnerable to cyber threats while facing capacity constraints that make formal compliance burdensome. This article develops a governance design model for proportionate SME cybersecurity, grounded in an awareness-first logic and informed by the EU Squad 2025 experience. Using a qualitative policy-analysis and conceptual policy-design approach, we reconstruct a seven-dimension preventive architecture: awareness and visibility, human behaviour, access control, system hygiene, data protection, detection and response, and continuous review, and justify each dimension's contribution to proportionality and risk reduction. We then map the model's regulatory scope and limits against the NIS2 Directive, Commission Implementing Regulation (EU) 2024/2690, the Digital Operational Resilience Act (DORA), the Cyber Resilience Act (CRA), and the EU Action Plan on Cybersecurity for Hospitals, clarifying which obligations are supported and which require complementary governance (e.g. role accountability, incident timelines, statements of applicability, sector-specific testing and procurement). The analysis argues that raising awareness is the fastest, scalable lever to increase cyber-risk sensitivity in micro-SMEs and complements, rather than replaces, formal compliance. We conclude with policy implications for EU and national programmes seeking practical, proportionate pathways to SME cyber resilience under NIS2.

Proportionate Cybersecurity for Micro-SMEs: A Governance Design Model under NIS2

TL;DR

The paper addresses the vulnerability of micro-SMEs to cyber threats amid compliance burdens by proposing a proportionate, awareness-first governance design. It develops a seven-dimension architecture derived from EU Squad 2025 experience and validates it through a two-stage policy analysis that maps each dimension to regulatory frameworks such as NIS2, ISO/IEC 27005, and ENISA guidance. Key contributions include a scalable, practical governance template that prioritizes awareness and simple, high-impact controls before heavier obligations, with explicit mapping to regulatory scope and required complementary actions. The work offers EU and national policymakers a workable path to enhance SME cyber resilience under NIS2 and related instruments, bridging voluntary guidance with formal requirements and enabling phased, cost-conscious implementation.

Abstract

Micro and small enterprises (SMEs) remain structurally vulnerable to cyber threats while facing capacity constraints that make formal compliance burdensome. This article develops a governance design model for proportionate SME cybersecurity, grounded in an awareness-first logic and informed by the EU Squad 2025 experience. Using a qualitative policy-analysis and conceptual policy-design approach, we reconstruct a seven-dimension preventive architecture: awareness and visibility, human behaviour, access control, system hygiene, data protection, detection and response, and continuous review, and justify each dimension's contribution to proportionality and risk reduction. We then map the model's regulatory scope and limits against the NIS2 Directive, Commission Implementing Regulation (EU) 2024/2690, the Digital Operational Resilience Act (DORA), the Cyber Resilience Act (CRA), and the EU Action Plan on Cybersecurity for Hospitals, clarifying which obligations are supported and which require complementary governance (e.g. role accountability, incident timelines, statements of applicability, sector-specific testing and procurement). The analysis argues that raising awareness is the fastest, scalable lever to increase cyber-risk sensitivity in micro-SMEs and complements, rather than replaces, formal compliance. We conclude with policy implications for EU and national programmes seeking practical, proportionate pathways to SME cyber resilience under NIS2.

Paper Structure

This paper contains 13 sections, 1 figure, 2 tables.

Table of Contents

  1. Introduction
  2. Regulatory Governance and Proportionality as Design Principles
  3. Policy Context
  4. Policy Analysis and Design Approach
  5. Derivation of the Model.
  6. Governance Design Model: Seven-Dimension Preventive Architecture
  7. Policy Discussion and Implications
  8. Policy Relevance
  9. Regulatory Scope and Limits
  10. Behavioural Foundations
  11. Implications for EU Policy
  12. Conclusion
  13. Contribution and Limitations.

Figures (1)

  • Figure 1: Two-stage methodological process in which Stage 1 derives the preventive governance model from practice, and Stage 2 evaluates it against relevant regulatory frameworks (NIS2, ISO/IEC 27005, and ENISA guidance). Source: Author’s elaboration, 2025.