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WP 2021 O.4.1 ENISA CSIRT Maturity Metholodogy Improvement

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ENISA CSIRT
MATURITY
FRAMEWORK
Updated & Improved

FEBRUARY 2022
ENISA CSIRT MATURITY FRAMEWORK UPDATE
Final | TLP WHITE| February 2022

ABOUT ENISA

The European Union Agency for Cybersecurity, ENISA, is the Union’s agency dedicated to
achieving a high common level of cybersecurity across Europe. Established in 2004 and
strengthened by the EU Cybersecurity Act, the European Union Agency for Cybersecurity
contributes to EU cyber policy, enhances the trustworthiness of ICT products, services and
processes with cybersecurity certification schemes, co-operates with Member States and
EU bodies, and helps Europe prepare for the cyber challenges of tomorrow. Through
knowledge sharing, capacity building and awareness raising, the Agency works together with its
key stakeholders to strengthen trust in the connected economy, to boost resilience of the
Union’s infrastructure and, ultimately, to keep Europe’s society and citizens digitally secure.
More information about ENISA and its work can be found here: www.enisa.europa.eu.

CONTACT
To contact the authors please use [email protected]
For media enquiries about this paper, please use [email protected].

AUTHORS
Andrea Dufkova (ENISA), Don Stikvoort (Open CSIRT Foundation), Klaus Peter Kossakowski
(University of Hamburg), Miroslaw Maj (ComCERT), Vilius Benetis (NRD Cyber Security) and
Kamil Gapinski (ComCERT)

ACKNOWLEDGEMENTS
Stichting Open CSIRT Foundation, CSIRTs Network Maturity Working Group members, Olivier
Caleff (SIM3 auditor), Edgars Taurins (ENISA)

LEGAL NOTICE
This publication represents the views and interpretations of ENISA, unless stated otherwise. It
does not endorse a regulatory obligation of ENISA or of ENISA bodies pursuant to the
Regulation (EU) No 2019/881.

ENISA has the right to alter, update or remove the publication or any of its contents. It is
intended for information purposes only and it must be accessible free of charge. All references
to it or its use as a whole or partially must contain ENISA as its source.

Third-party sources are quoted as appropriate. ENISA is not responsible or liable for the content
of the external sources including external websites referenced in this publication.

Neither ENISA nor any person acting on its behalf is responsible for the use that might be made
of the information contained in this publication. ENISA maintains its intellectual property rights in
relation to this publication.

COPYRIGHT NOTICE
© European Union Agency for Cybersecurity (ENISA), 2022
This publication is licenced under CC-BY 4.0 “Unless otherwise noted, the reuse of this
document is authorised under the Creative Commons Attribution 4.0 International (CC BY 4.0)
licence (https://creativecommons.org/licenses/by/4.0/). This means that reuse is allowed,
provided that appropriate credit is given and any changes are indicated”

ISBN 978-92-9204-563-0, DOI 10.2824/35453 Catalogue Number TP-07-22-077-EN-N

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TABLE OF CONTENTS

EXECUTIVE SUMMARY 3

1. INTRODUCTION 4

1.1 DEPRECATION STATEMENT 6

2. ENISA CSIRT MATURITY FRAMEWORK 7

2.1 3.1 SECURITY INCIDENT MANAGEMENT MATURITY MODEL (SIM3) 7

2.2 CSIRT MATURITY STEPS – THREE-TIER APPROACH 13

2.3 3.3 ASSESSMENT METHODOLOGY 16

3. CONCLUDING REMARKS 18

4. REFERENCES 19

5. APPENDICES 20

5.1 APPENDIX A: FAQ 20

5.2 APPENDIX B: COMMENTS ON ALIGNMENT TO CYBERSECURITY STRATEGY AND NIS2 DIRECTIVE 26

5.3 APPENDIX C: UPDATE OF THREE-TIER MATURITY APPROACH AND SIM3 STANDARD 27

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EXECUTIVE SUMMARY

The ENISA CSIRT Maturity Framework is intended to contribute to the enhancement of the
global capacity to manage cyber incidents, with a focus on CSIRTs. Cyber incidents and
developments are inherently transnational and effective responses depend on transnational
collaboration. The establishment of national CSIRTs 1 is an essential step to facilitate the
building of cyber capacity both within and across nations and make it more effective. The ENISA
CSIRT Maturity Framework is aimed at parties involved in planning, building and leading such
capacities with a concrete focus to increase maturity of all CSIRTs in the CSIRTs Network 2.

The ENISA CSIRT Maturity Framework is built on three pillars:

1. the well-established OCF SIM3 3 standard;


2. the ENISA three-tier maturity approach: a series of three pre-defined steps that can be
used as a guideline for the steps to be taken to increase maturity, complete with
practical guidance on how to work with the Maturity Framework at different phases –
from pre-establishment to advanced levels of maturity;
3. the ENISA assessment methodology: self-assessment and peer-reviews applied in the
CSIRTs Network.

It is important to recognise that the framework is not intended to be prescriptive but is meant to
support and stimulate national efforts on building and improving the capacity to respond to
cyber incidents. However, the steps to maturity that have been defined are based on extensive
experience and expertise in the CSIRT community and offer valuable guidance for national
CSIRTs with regards to the level of quality to which they aspire. The CSIRT Maturity Framework
combines previous models that have been widely recognised and adopted.

In this document the updated and improved version of the Framework is presented. This
includes changes to all three pillars mentioned above.

1. Some aspects of SIM3 have been improved upon, and brought up to date – leading to
a strong recommendation to OCF 4 to include these in any new drafts of the SIM3
standard.
2. The three-tier maturity approach has remained the same as regards terminology,
including the terms Basic, Intermediate and Advanced. However the demands on
those three steps have been upgraded, in line with the development of the maturity of
the CSIRTs Network in the past four years while also reflecting the changing
landscape of the NIS Directive5.
3. The self-assessment and peer-review system received a complete overhaul, with in-
depth guidance, which is expected to not only make this process easier to work with,
but also lead to higher quality and more consistent results.

1
The term ‘National CSIRT’ is more closely defined later in the report.
2
https://www.enisa.europa.eu/topics/csirts-in-europe/csirts-network
3
http://opencsirt.org/wp-content/uploads/2019/12/SIM3-mkXVIIIc.pdf
4
https://opencsirt.org/
5
https://digital-strategy.ec.europa.eu/en/library/revised-directive-security-network-and-information-systems-nis2

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INTRODUCTION

This document presents ENISA’s Computer Security Incident Response Teams (CSIRT)
Maturity Framework that is intended to contribute to the enhancement of the capacity to
manage cyber incidents, with a focus on national CSIRTs 6. It is aimed at parties involved in
planning, building and leading such capacities. This document has been developed as part of
ENISA’s continuous commitment to enhancing CSIRTs and related methodologies.

National CSIRTs play a crucial role in the collaboration and co-ordination between national and
international communities and organisations. Cyber incidents and developments are inherently
transnational and effective responses depend on transnational collaboration. The establishment
CSIRT
of national CSIRTs is an essential step to facilitate and co-ordinate the building of cyber MATURITY
capacity both within and across nations. Encouraging the
establishment,
Within the CSIRT community, incident management is generally defined as the combination of expansion and
incident prevention, detection, resolution and quality management – thus much more than just maturity of national
incident handling. As such, CSIRTs form an essential element of cyber incident management CSIRTs contributes
and cyber capacity in general. to the ambition of
building European
Internal CSIRTs (sometimes also referred to as ‘enterprise’ CSIRTs) operate at the level of and global cyber
individual organisations – this can be any type of organisation, such as a private company, capacity,
multinational, not-for-profit, university, hospital or government agency. Such internal teams have
supplementing the
a clear mandate and knowledge to perform hands-on incident management activities within an
existing network of
organisation’s network of IT systems.
private industry and
academic and
Another type of CSIRT has an external focus and provides services to a sector or nation, and
research CSIRTs.
usually has a limited mandate to access or implement security measures within the actual IT
systems of their constituency. Therefore, these focus more on the co-ordination of responses,
the analysis of threats and incidents, and other forms of support to members within the
constituency.

National CSIRTs are in the latter category. They generally provide the capability of rapid,
integrated and co-ordinated responses to cyber incidents for national sectors, cyber dependent
communities such as e-commerce enterprises or financial institutions, critical infrastructure and
the nation at large, as well as being important links in the global CSIRT community. Depending
on the specific legal and political context, national CSIRTs can have a variety of focus areas
and mandates. In some nations, national CSIRTs are institutionally embedded in (or closely
related to) a National Cyber Security Centre (NCSC) or similar authority or agency.

NCSCs have a broader mandate as national co-ordination centres: they provide technical and
policy expertise and are usually tasked with executing national crisis exercises and contributing
to technical standards and legislation. In some countries, national CSIRT functions are
distributed between two or more teams. In cases of multiple national teams, it is important that
the mandate and constituencies for each team are clearly defined and that they can co-operate
closely.

Encouraging the establishment, expansion and maturity of national CSIRTs contributes to the
ambition of building European and global cyber capacity, supplementing the existing network of

6
This document uses the term ‘national CSIRT’ to refer to a range of national cyber (co-ordination and response) activities, including CIIP, sectorial and
governmental teams. Depending on the context, a national CSIRT can have a different focus or name. Currently the scope relates to CSIRTs Network
(https://csirtsnetwork.eu/) as governed by the NIS Directive.

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private industry and academic and research CSIRTs. To do so, it is important to approach the
development of this network from both a technical as well as a policy perspective. Existing
models and good practices for CSIRTs and CSIRT maturity can not only support nations that
are ready to establish a national CSIRT but also nations that want to enhance the maturity of
their national team.

The new version of the ENISA CSIRT Maturity Framework presented here includes the OCF
SIM3 standard, with its more-than-forty parameters; the ENISA three-tier approach, which
consists of three pre-defined maturity steps (Basic, Intermediate and Advanced) that can be
used as stepping stones towards increased maturity; and an enhanced ENISA assessment
methodology, based on a system of self-assessments and peer-reviews with elaborate
guidance on best practice. A main thread in all this is to give guidance on how to work with the
Maturity Framework with teams at different phases, from pre-establishment through the whole
maturity cycle to the advanced stage.

It is important to recognise that the framework is not intended to be prescriptive but is meant to
support and stimulate national efforts on building global capacity for responding to cyber
incidents. However, the maturity steps that have been defined are based on extensive
experience and expertise in the CSIRT community and offer valuable guidance for national
CSIRTs regarding the quality level to which they aspire. It needs to be stressed here that the
NIS Directive has been taken right from the start as the inspiration and guide for the steps
towards maturity, and this is reflected in the ENISA three-tier approach – and with the changes
in the NIS Directive, it became necessary to further upgrade the Basic, Intermediate and
Advanced steps.

The ENISA CSIRT Maturity Framework builds on its previous incarnation and continues to
adopt the Open CSIRT Foundation’s SIM3 standard, whilst applying improvements and updates
across the board.

Open CSIRT Foundation (OCF) – SIM3 7

SIM3 is designed as a generic maturity standard that applies to all types of CSIRTs, including
national CSIRTs. The Open CSIRT Foundation (OCF) shepherds the development of SIM3. 8
The current version of SIM3 (latest update: May 2019) is popularly referred to as ‘v1’. In the
work that led to this new framework, done in co-operation with OCF, it was recognised that
some changes and updates were needed; these will be reflected in an interim version of ‘SIM3
v2’ to be made available by the OCF. More information regarding this is found in Appendix E.

ENISA previous maturity framework: CSIRT three-tier maturity approach

The ENISA CSIRT three-tier maturity approach is based on SIM3 and was developed to support
the maturity development of national CSIRTs in the EU.

This tiered maturity approach is globally applicable, as was proven by the publication of the
GFCE’s GCMF or Global CSIRT Maturity Framework (April 2021) which, content-wise, is
identical to the ENISA approach.

In Section 3 the maturity standard and maturity steps are presented. In Section 4, there is
extensive guidance on the assessment methodology for the CSIRTs Network (self-assessments
and peer-reviews).

7
See http://opencsirt.org/csirt-maturity/sim3-and-references/
8
The OCF encourages ENISA members to use the current SIM3 version, under the condition that it is used unchanged and with the request that any
potential improvements of SIM3 are shared with the OCF in order to help improve and update SIM3.

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1.1 DEPRECATION STATEMENT


The following documents are deprecated following the publication of this Framework:

1. ENISA Maturity Evaluation Methodology for CSIRTs, April 09, 2019,


https://www.enisa.europa.eu/publications/study-on-csirt-maturity-evaluation-process
2. ENISA CSIRT maturity assessment model, April 30, 2019,
https://www.enisa.europa.eu/publications/study-on-csirt-maturity
3. Maturity Reference for CSIRTs – Executive Summary, January 15, 2018,
https://www.enisa.europa.eu/publications/maturity-reference-for-csirts-2013-executive-
summary
4. CSIRT Capabilities. How to assess maturity? Guidelines for national and governmental
CSIRTs, January 11, 2016, https://www.enisa.europa.eu/publications/csirt-capabilities
5. CSIRT Maturity - Self-assessment Tool, https://www.enisa.europa.eu/topics/csirts-in-
europe/csirt-capabilities/csirt-maturity/csirt-survey
6. CSIRTs Network internal documents (not publicly available)

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ENISA CSIRT MATURITY


FRAMEWORK

At the core of the ENISA CSIRT Maturity Framework lies the SIM3 standard, ENISA’s three-tier
maturity approach and its application in the form of self-assessments and peer-reviews. In this
chapter both SIM3 and ENISA’s three maturity steps are presented, in such a way that they can
be applied globally.

2.1 3.1 SECURITY INCIDENT MANAGEMENT MATURITY MODEL (SIM3)


SIM3 stands for Security Incident Management Maturity Model and has been in use since
2008 9. The maturity standard has been applied by teams all over the world, including various
national CSIRTs 10. In the European Union, national CSIRTs are encouraged to develop their
maturity using the ENISA CSIRT three-tier maturity approach which is based on SIM3. The
current version of SIM3 is mkXVIIIc 11. I was most recently updated in May 2019. It is in essence
still the original SIM3, also known as ‘v1’. Work on a new version, SIM3v2 is in process.

For the development of the new ENISA Framework, ENISA and OCF have co-operated to
ensure that there will be no loss of synchronicity between the ENISA Framework and OCF’s
SIM3. In fact under the current ENISA project for updating the ENISA Framework, the updated
SIM3 parameters will continue to align with SIM3v2.

Reference will be made to an interim draft version of SIM3v2 which is as much as possible, and
indeed to a great extent, identical to SIM3v1 yet includes various updates, improvements and a
few extensions that are necessary for both ENISA and OCF. The final version of SIM3v2,
expected to be published by OCF late in 2022, will be more elaborate yet will not in any way
invalidate the new ENISA Framework; both will remain fully compatible.

Below we refer to SIM3v2i – with ‘i’ referring to ‘interim’. This can be replaced by just SIM3v2
once that has been finalised by OCF.

SIM3v2i features forty-five parameters, one more than SIM3v1. Parameters are attributes
relevant for either the organisation, operation or functioning of a CSIRT.

The SIM3v2i parameters are divided into four categories:

O: Organisational
The organisational (‘O’) parameters focus on aspects that together describe the foundation and
extent of the CSIRT’s activities (i.e. the mandate, setup and services of the CSIRT, and the
framework connecting all organisational aspects).

H: Human
The human (‘H’) parameters in the framework focus on important aspects related to the CSIRT’s
staff (this refers not only to technical staff but to all staff members). Together, these parameters
reflect how the team views its staff in relation to the work of the team and how this is organised.

9
The Open CSIRT Foundation (OCF) governs and maintains SIM3, and trains and certifies SIM3 auditors.
10
Two online measurement tools exist. The OCF tool aims at all sorts of CSIRTs worldwide, including national ones. ENISA’s tool aims at national
CSIRTs.
11
See http://opencsirt.org/csirt-maturity/sim3-and-references/

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T: Tools
The tools (‘T’) parameters refer to the tools and technologies that are used by the CSIRT to
reach its objectives and offer its services to its constituency. A ‘tool’ in this context can be a list,
an excel sheet or, in most advanced cases, an actual implementation of advanced tooling.

P: Processes
The processes (‘P’) parameters focus on a set of processes that should be well organised in
order for a CSIRT to perform its tasks. The word ‘process’ is meant in a generic way – it
includes not only processes in the sense of a logical set of sequential or parallel steps, but also
policies, both of the more fundamental kind as well as very basic policies. Some of the Process
parameters are connected with parameters from the other categories (Organisation, Human and
Tools), where the description or list is found more in those other categories, and the P-
parameters focus on the steps that need to be taken.

The forty-five parameters are listed below in Table 1.

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Table 1- Overview of SIM3v2i parameters 12

Parameter Parameter Parameter Parameter


number description number Description

O-1 Mandate T-6 Resilient Messaging

O-2 Constituency T-7 Resilient Internet Access

O-3 Authority T-8 Incident Prevention Toolset

O-4 Responsibility T-9 Incident Detection Toolset

O-5 Service Description T-10 Incident Resolution Toolset

O-6 Public Media Policy P-1 Escalation to Governance Level

O-7 Service Level Description P-2 Escalation to Press Function

O-8 Incident Classification P-3 Escalation to Legal Function

O-9 Participation in CSIRT Systems P-4 Incident Prevention Process

O-10 Organisational Framework P-5 Incident Detection Process

O-11 Security Policy P-6 Incident Resolution Process

H-1 Code of Conduct/Practice/Ethics P-7 Specific Incident Processes

H-2 Staff Resilience P-8 Audit & Feedback Process

H-3 Skillset Description P-9 Emergency Reachability Process

H-4 Staff Development P-10 Best Practice Internet Presence

H-5 Technical Training P-11 Secure Information Handling Process

H-6 Soft Skills Training P-12 Information Sources Process

H-7 External Networking P-13 Outreach Process

T-1 IT Assets & Configuration P-14 Governance Reporting Process

T-2 Information Sources List P-15 Constituency Reporting Process

T-3 Consolidated Messaging System(s) P-16 Meeting Process

T-4 Incident Tracking System P-17 Peer Collaboration Process

T-5 Resilient Voice Calls

When working with the SIM3v2i framework, each parameter can be measured on a scale of 0 to 4 (see Table 2 below).

12
O-6 is a new parameter introduced in SIM3v2. In SIM3v1 O-6 was intentionally left blank. All 44 other parameters have only had relatively minor name
changes when changing from v1 to v2, in order to bring them up-to-date.

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Table 2 – SIM3v2i parameter measurement scale

Level Status Indicators

0 Not available / undefined / unaware -

1 Implicit Known or considered but not written down,


‘between the ears,’ ‘tribal knowledge’

2 Explicit, internal Written down but not formally adopted or reviewed

Explicit, formalised on authority of CSIRT head Approved or published


3

4 Explicit, actively assessed on authority of Subject to a control process and/or review


governance levels above the CSIRT
management on a regular basis

To use this measurement scale appropriately, some additional explanation about each of the
five levels (what they mean and what the procedure for evidence could be) may be helpful:

Level 0 (Not available / undefined / unaware)

This score is mostly only met with teams made up of novices, as it means that the team
members have not yet thought about the parameter in question. If, during an assessment or
audit, all attendants produce blank looks when a parameter is mentioned, this may be a
candidate for level 0. When a team starts actively discussing a parameter, there is a high
likelihood of it moving to level 1 fairly soon.

Level 1 (Implicit)

This score is typically encountered with teams of novices but, for some parameters, also with
experienced teams where a few experts know how to do things but never took the trouble of
writing them down. When conducting an assessment or audit and a parameter at level 1 is
encountered, it is worthwhile asking a few team members to explain how they think about that
parameter. Chances are that the explanations will be different enough to convince the team as
well as the team management that it would be a good idea to actually write down the content for
this parameter, so as to increase consistency within the team – and also to make it easier to get
new team members up to speed.

Level 2 (Explicit, internal)

This score is typically encountered when teams have internal information systems of a more
informal type ̶. like a team-wiki or a shared site or similar. It is strongly recommended that all
CSIRTs have facilities like this as they provide an easy way to bring the most important
processes, tools (and manuals) and policies under the direct attention of those doing the work
of incident management. A wiki-style approach has the added advantage of allowing hyperlinks,
thus enabling the internal information to be easily structured and interconnected; e.g. T-2 is the

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information sources list, and from that list you could easily point at the process(es) relevant for
those various sources – and those processes comprise the P-12 parameter.

There are also other cases that can lead to a level 2 score such as, for instance, when some
tool used by the team holds information relevant for one of the parameters but this information
has not been ratified by the team management. For example, the incident tracking system (T-4)
of the team will most likely have some kind of incident classification scheme (O-8) on board –
but that will be in the form of a dropdown choice; when that dropdown list has not been formally
approved by the team management, the O-8 parameter scores at level 2.

Going back to the wiki-style approach, the typical characteristic of that approach is that various
team members can write texts and fit them in – and even when consensus among team
members about such texts will come into existence after continued use (and adaptation, again
wiki-style), this is still level 2, as there is no formal approval by the team management. Level 2 is
certainly valid to begin documentation, but for most information it is advisable that, at some
stage, what has come to be the consensus is recognised as such and supported by the team
management – leading to level 3.

Level 3 (Explicit, formalised on authority of CSIRT head)

This score applies to any parameter where the subject matter of that parameter has been
formally and explicitly (in ‘writing’) approved by the team management. Here we mention a few
of the most common situations for level 3.

1. The subject matter is part of policy or process documents on the team level, authorised
by the team management. These comprise the most simple and direct case. However
the risk inherent in separate documents is, if there are too many of those, the overview
is lost and it can become a separate (paper) reality, rather than part of the day-to-day
procedures of the team. Therefore, it is important to integrate such documents into
team operations and information systems to ensure that team members actually know
of and use them, for instance, by integrating them into a team-wiki or similar. In
addition, it is strongly recommended to use an expiry and maintenance system for a
team’s internal documents.
2. Relevant policy (or process) documents authorised on a governance level higher than
the team management: these are automatically also valid for the team management
and the team; however it is essential that they are embedded into team operations and
information systems to ensure that the team members actually know of and use them.
3. Wiki-style level 2 information or pages or documents that are ‘upgraded’ to level 3: this
of course requires explicit (visible) authorisation by team management for such
‘pages’. It is currently not demanded by SIM3 but it is highly recommended to go one
step beyond this and not just grant authorisation, but also include some system of
expiry and maintenance for such pages. Some wiki-types have facilities or plug-ins to
make this easier.

Level 4 ‘Explicit, actively assessed on authority of governance levels above the CSIRT
management on a regular basis’

This score implies level 3 plus an important addition that ensures that the parameter in question
is no longer just an internal matter for the team but has the active attention of some higher
governance level above the team’s management. There needs to be evidence of this, and this
evidence must include the following.

1. There must be a process of checking, assessing or auditing this parameter on the


authority of a higher governance level.

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2. This process must be followed regularly. There is currently no set rule for this in SIM3,
but as best practice ‘regular’ means at least once every two years and usually once a
year.
3. The process must be ‘active,’ which means in that there is a feedback mechanism
towards the team management (and the team) in addition to the process of checking
and reporting on it. This feedback mechanism is intended to ensure that there is
communication about the parameter between the team (management) and higher
governance levels.

This level 4 mechanism is meant to ensure that (a) the higher level of governance is actively
aware of some of the crucial aspects of the nCSIRT and how it functions in real life, and (b) as a
consequence, to enable constructive communication between higher governance levels and the
team in order to enable improvements: clearer policies, better tools and processes, more
people, better training sessions and education, etc.

The evidence for level 4 is not always clear-cut. The clearest cases are the following.

1. When the topic of a parameter is formally and unambiguously part of the national cyber
(security) legislation, that parameter automatically scores level 4, because it is
assumed that the system of legislation and the checks and balances associated with
that are more than sufficient to warrant level 4. It is, however, important to note here
that the mere mentioning of something in the law – even if it is clear and unambiguous
– still requires the team to implement this internally so as to be able to effectively
‘make the law work’. So such aspects still require documentation inside the team, by
being embedded in a team information system (e.g. team wiki), integrated into internal
training, etc.
2. When there is a team organisational framework, charter or a ‘team handbook’ (O-10), it
is strongly advised to have a paragraph there for the team about the assessments or
audits, which is essentially the P-8 parameter process. This should include internal
team assessments (which alone are not sufficient for level 4). But it should also
address the process of auditing the team by a higher governance level or by an
auditing department. As such higher level audits usually set their own rules,
acknowledging their independent position is recommended while requesting a
minimum set of aspects (which could directly be translated into SIM3 parameters) on
which the team wants to be audited. Most of the O-parameters could be included there,
plus optionally some others, such as H-2, P-1 and P-2.

In other cases, it is often harder to find clear evidence for level 4 characteristics when, for
instance, an auditing department does an extensive audit of the nCSIRT every year and they
use SIM3 as one of the controlling documents but no-one has written down some minimal
requirements for that audit. In such a case, alternative evidence can be a posteriori rather than
a priori; meaning, a few of those audit reports may be reviewed to see what they contain in
order to gauge whether it is reasonable to assume that a certain SIM3 parameter was indeed
audited in a level 4 way (including feedback to the team) and therefore there is reasonable
substantiation for level 4.

Figure 1 shows a (hypothetical) result of a CSIRT maturity assessment. The forty-five


parameters 13 are given a score and the figure provides visual insight of the maturity of a team.

13
The new parameter O-6 is still missing in this example figure.

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Figure 1: CSIRT maturity assessment example outcome

2.2 CSIRT MATURITY STEPS – THREE-TIER APPROACH


This paragraph provides information on the maturity steps that can be used to assess the
maturity of a national CSIRT and support decision-making on where to focus efforts to increase
maturity. The maturity steps previously developed by ENISA are the three-tier maturity
approach. Three steps have been defined: Basic, Intermediate and Advanced. An Under-basic
step is designated to those who do not yet reach the requirements of the Basic step.

For each step, a minimum value is assigned for each of the forty-five parameters. The values for
each parameter at each of the three steps are based specifically on the profile requirements for
most national CSIRTs. This means that, in practice, some parameters will be more relevant for
some national teams than for others – the weighting of that is the responsibility of the teams in
question.

National CSIRTs, by virtue of their national responsibility, should always be mandated by the
government or through legislation to legitimately fulfil their national role. This also reflects on
many of the other aspects related to the scope of their activities. For this reason, even at the
Basic step national CSIRTs should obtain relatively high levels of maturity on many of the

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O-parameters. In turn, the aspects addressed by the H-parameters are usually part of the
internal management processes of the team and do not necessarily require regular control from
governance levels above the CSIRT management. This means that for the three maturity steps,
none of these parameters requires a level higher than level 3.

Of course, it is possible that in some countries, there will be a conceived need to have auditing
and feedback from a higher level of governance on, for instance, the availability of sufficient
staff (parameter H-2), or to help ensure they are properly educated (parameters H-4 to H-6) –
and that could be a reason for these parameters achieving level 4 – but in general such a level
is not required for the three maturity steps for national CSIRTs. As a final example, most
national CSIRTs will play less of a role in the prevention of an actual incident and therefore the
value for T-8 (Incident Prevention Toolset) and P-4 (Incident Prevention Process) are low
across all three maturity steps.

The Basic and Advanced steps allow national CSIRTs to define a growth path. New teams can
first aim to achieve the Basic step in the short term, as this is really the starting point for any
national team and also provides the bare minimum demands to enable joint incident handling.
Next, teams can set a time schedule for developing to the Advanced stage – note here that the
peer-review cycle in the ENISA Framework uses change-cycles of up to 3 years.

The Intermediate step offers some guidance for setting a path for growing from Basic towards
Advanced, although – depending on specific needs – some teams may opt to develop right from
Basic to Advanced. The higher steps are in place to show that a national team has reached a
higher level of maturity and that the conditions that enable interaction with CSIRTs worldwide
reactively as well as pro-actively have been met. It will also facilitate the building of trust
between teams. Below, a short explanation of the three steps is provided.

2.2.1 Under-basic step


The Under-basic step applies to CSIRTs who have not yet reached the Basic step for one or
more parameters. This step is especially relevant for teams who want to secure resources to
improve their maturity and move to higher steps.

2.2.2 Basic step


For national CSIRTs to function adequately within their country and to work together with other
teams (not just nationally but also globally or within their multinational economic region) they
need to have a basic degree of maturity. Therefore, teams must already have a good foundation
with regards to mandate, constituency, authority (etc.) – they need to be reachable and have a
functional incident handling process. The values for the SIM3 parameters have been set in this
manner for the Basic step; most organisational parameters will already need to score a fairly
high level of maturity of at least 3, while most of the other parameters need to score only 1 or 2.

2.2.3 Intermediate step


This step builds on the Basic step and especially aims at enabling higher management or
legislative controls (level 4) for most of the organisational parameters, which were documented
and approved (level 3) at the Basic step, without such controls. In the other categories (human,
tools and processes) there is also gradual progress on most parameters.

2.2.4 Advanced step


For national CSIRTs to progress from merely ‘working together’ on handling incidents to
establishing a comprehensive co-ordinated capacity to manage incidents, including effectively

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and reliably sharing threats, vulnerabilities and early-warning data with ‘peer’ national CSIRTs 14,
it is essential that these teams reach a high level of maturity. The parameter values for the
Advanced step have been set in this way. It means that most organisational parameters must
score at level 4, whereas the human, tools and processes parameters must score at least 3
and, in important cases, even level 4.

The minimum scores required for the three maturity steps are specified in Table 3 below.
Appendix E presents a version of the table below that highlights the changes between the
current ENISA Framework and the new one (and thus also the changes between SIM3v1 and
SIM3v2i), and also indicates what the increase has been in the overall maturity demands for the
three steps.

Table 3 - Overview of ENISA maturity steps with minimal SIM3v2i score for each parameter

Parameter Parameter Minimum values for the tiers:


number description Basic Intermediate Advanced

O-1 Mandate 3 4 4

O-2 Constituency 3 4 4

O-3 Authority 3 4 4

O-4 Responsibility 3 4 4

O-5 Service Description 3 4 4

O-6 Public Media Policy 2 3 4

O-7 Service Level Description 3 4 4

O-8 Incident Classification 2 3 3

O-9 Integration in CSIRT Systems 3 4 4

O-10 Organisational Framework 3 3 3

O-11 Security Policy 2 3 4

H-1 Code of Conduct/Practice/Ethics 2 3 3

H-2 Staff Resilience 2 3 4

H-3 Skillset Description 2 2 3

H-4 Staff Development 2 3 4

H-5 Technical Training 1 2 3

H-6 Soft Skills Training 1 2 3

H-7 External Networking 2 3 3

T-1 IT Assets & Configurations 1 2 3

T-2 Information Sources List 2 3 4

T-3 Consolidated Messaging System 2 3 3

T-4 Incident Tracking System 2 3 3

T-5 Resilient Voice Calls 2 3 3

14
Every CSIRT has ‘peers’ (fellow teams) with whom they work closely and have built trust to exchange potentially-sensitive information.

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T-6 Resilient Messaging 2 3 3

T-7 Resilient Internet Access 2 3 3

T-8 Incident Prevention Toolset 2 2 3

T-9 Incident Detection Toolset 2 3 3

T-10 Incident Resolution Toolset 2 3 3

P-1 Escalation to Governance Level 3 4 4

P-2 Escalation to Press Function 2 3 3

P-3 Escalation to Legal Function 2 3 3

P-4 Incident Prevention Process 2 3 4

P-5 Incident Detection Process 2 3 4

P-6 Incident Resolution Process 2 3 4

P-7 Specific Incident Processes 2 3 4

P-8 Audit & Feedback Process 3 4 4

P-9 Emergency Reachability Process 2 3 3

P-10 Best Practice Internet Presence 2 3 3

P-11 Secure Information Handling Process 2 3 3

P-12 Information Sources Process 2 3 4

P-13 Outreach Process 2 3 4

P-14 Governance Reporting Process 3 4 4

P-15 Constituency Reporting Process 2 3 3

P-16 Meeting Process 2 2 3

P-17 Peers Collaboration Process 2 3 4

2.3 3.3 ASSESSMENT METHODOLOGY


The Maturity Framework provides support and guidance to all national CSIRTs across the
globe, including nations that are yet to establish a national CSIRT. In this chapter, different uses
of the Maturity Framework are described. Throughout the chapter other relevant resources are
mentioned that can contribute to the establishment and maturity of these CSIRTs. The
information provided is meant as a supporting guideline for teams. It does not offer (prescriptive)
predefined grow paths or cost estimates because this will vary strongly across contexts and is
dependent on the specific ambition that each CSIRT sets for itself.

For instance, in a country that already has several CSIRT activities running (e.g. for the
government, and for the research and education community) it can be considerably easier and
less costly to create a national CSIRT than in a country that has no such institutions yet. But,
also, it makes a big difference in terms of time and resources if the constituency of the national
team is limited to the critical infrastructure sectors compared to when it also includes, for
example, all companies and citizens.

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2.3.1 Self-Assessment
The CSIRT Maturity Framework makes it possible to assess the maturity of a CSIRT through a
self-assessment as the first step. Self-assessment can be useful for setting a baseline (more
subjective) score for internal review purposes. It can also be used as the starting point to
enhance maturity. Based on the self-assessment score, an action plan (including timeline) may
be defined to improve to a higher level of maturity. Assessments can also be used to compare
with peer CSIRTs using the Maturity Framework as guideline. The maturity steps defined in the
CSIRT Maturity Framework are set as good practice to provide guidance for national CSIRTs.
Some parameters may be less relevant to a specific team whilst others are at the core of their
strategy.

2.3.2 Peer-Review
The second step in the assessment described in the CSIRT maturity framework is peer-review.
National CSIRTs can ask another team to perform a peer-review of their self-assessment. A
way to implement this is to ask a peer team to make available one of their more experienced
staff members, who ideally has knowledge and experience with the assessment of CSIRT
maturity.

After the team has done their self-assessment, the peer-reviewer can meet them – experience
teaches that such a meeting is most effective when done on site – and discuss their results.
This is a win-win situation where both sides can learn from each other. It will help the team to
make their self-assessment more accurate (with an element of objectivity) and show how to
effectively increase maturity. It also contributes to a level of trust between the teams for future
collaboration.

Peer-reviews are smoother if staff representatives from both sides are educated on the model.
Thus, taking part in formal and informal education on how to use these reviews is strongly
encouraged.

2.3.3 General Remarks


The CSIRT Maturity Framework may also be used to audit the maturity level of a (national)
CSIRT to provide certification or as proof of meeting specific requirements (for instance to be
eligible for certain forms of support or collaboration). There are many ways of using the Maturity
Framework for requirement purposes. For example national CSIRT communities might
prescribe the Basic or Intermediate maturity step as the lowest common denominator and
boundary for membership of their community.

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CONCLUDING REMARKS

The ENISA CSIRT Maturity Framework is a very live concept, which is intensively used by the
CSIRTs Network. The national, governmental and sectoral CSIRTs constantly use it to
understand, maintain and improve their maturity. The very fact of this active and broad usage
means that the Framework needs to be improved regularly.

This report has undertaken that effort for the year of 2021, which also includes new
requirements derived from regulatory works, most notably the draft proposal for the EU NIS2
Directive.

The improvement to the framework includes concrete, highly-valuable results ̶ first of all, in the
foundation of the framework, the SIM3 standard, where various improvements and updates
have been identified in close collaboration with the Open CSIRT Foundation, which maintains
SIM3. OCF has agreed to adopt these changes in their forthcoming development of the next
version of SIM3.

Another important achievement is that the maturity steps of the ENISA three-tier maturity
approach have been brought up to date, also taking into account the proposals for the draft
NIS2 Directive.

Finally, the ENISA assessment methodology that consists of self-assessment and peer-review
has been extensively improved upon, with a much more detailed approach to the process,
including better tooling.

It must be stressed here that the function of this report is to identify the aforementioned changes
and improvements to the framework, and then to recommend them to the CSIRTs Network for
implementation.

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REFERENCES

1. SIM3 standard: https://opencsirt.org/maturity/sim3/


2. FIRST CSIRT Services Framework:
https://www.first.org/standards/frameworks/csirts/csirt_services_framework_v2.1
3. The ENISA SIM3 self-assessment tool includes the three-tier maturity approach, and is therefore mostly
suited for use by national CSIRTs – bearing in mind that where ENISA uses the term ‘Certifiable’ for the
highest maturity step, this is called ‘Advanced’ in this document: https://www.enisa.europa.eu/csirts-maturity-
sas
4. The OCF SIM3 self-assessment tool is designed for worldwide use, and for all sorts of CSIRTs including
national ones: https://sim3-check.opencsirt.org/
5. TF-CSIRT / Trusted Introducer use SIM3 as a basis for the highest tier of their membership, the ‘Certified’
status:
https://www.trusted-introducer.org/processes/certification.html
6. CSIRTs Network, see https://csirtsnetwork.eu/

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APPENDICES

5.1 APPENDIX A: FAQ


This FAQ section provides informal knowledge about framework-related questions, in order to
clarify the framework’s context, intent and usage.

Questions on the ENISA CSIRT Maturity Framework


Question: The maturity roadmap has been introduced in this report as a tool to help
teams with increasing their maturity in a structured, project-like manner. Will this
roadmap also be integrated in SIM3?

Answer: The roadmap is not a SIM3 artefact – SIM3 does not intend to prescribe how to do
things, it is a neutral measurement tool. OCF has communicated that this policy will stay the
same for SIM3v2. Thus, the roadmap will not be mentioned in any SIM3 parameters. OCF might
mention it in accompanying texts like an FAQ of course, as an example of tools to be used to
help improve maturity. In this report however, written for CNW/ENISA, the roadmap approach
makes perfect sense. The implementation of it is up to CNW/ENISA.

Q: Article 16.2 of the draft proposal for the NIS2 Directive requires a peer review of the
CSIRTs’ operational capabilities and effectiveness. Is there a risk that there will be two
peer reviews, the CNW one, and the NIS2 Directive one?

A: Article 16.2 is indeed a new element compared with the original NISD. It is urgently
recommended to the CSIRTs Network and ENISA that they ensure that the next iteration of the
CNW peer-review process, for which recommendations are given in this paragraph, are fully
aligned with the NIS2 Directive expectations, so as to exclude any double efforts in this area.

Q: The EU Cybersecurity Strategy suggests applying AI in cybersecurity. How is this


reflected in the Maturity Framework?

A: For the Maturity Framework, AI usage is implicitly reflected in the SIM3v2i T-8, T-9 and T-10
parameters – the toolsets for incident prevention, detection and resolution. AI is expected to
improve the effectiveness and precision of corresponding technologies. In the longer term, one
could also expect applications of AI in the Processes category. However, it is expected that for
the foreseeable future the human role in CSIRT work will remain crucial, due to the human
ability to deal with the unexpected and new, a standard requirement in the CSIRT business.

Q: How does the emergence of the NIS2 Directive affect the Maturity Framework?

A: The latest revised version of the NIS2 Directive proposes more stringent measures for
supervision and enforcement, including administrative sanctions, such as fines for breach of the
obligations for the management of cybersecurity risk and reporting. Other proposed changes
include obligations for the co-ordinated disclosure of newly discovered vulnerabilities across the
EU and the streamlined co-ordination of incident reporting with more precise provisions for the
reporting process, content and timeline.

For the Maturity Framework, the capability to co-ordinate the disclosure of vulnerabilities and to
co-ordinate capabilities in crisis management fall under parameters O-5, P-1 and P-4/5/6/7.

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However Article 10 of the Presidency Compromise draft of the NIS2 Directive describes the
requirements and tasks of CSIRTs. Some specific relevant parts include the following.

• Article 10.1 (a) focuses on availability of CSIRTs communications services, corresponding


with the T-3 and T-5/6/7 parameters.
• Article 10.1 (b) focuses on CSIRTs secure sites (premises and the supporting information
systems). This dimension is not explicitly covered in SIM3, but in SIM3v2i it will be added to
the description of O-11.
• Article 10.1 (d) focuses on staff resilience, corresponding to the H-2 parameter.
• Article 10.1 (e) focuses on the resilience of systems (redundant systems) and on working
space resilience (backup working space). Resilience of systems can be covered partially
with the T-3 and T-5/6/7 parameters, but working space resilience is not explicitly covered in
SIM3. However in SIM3v2i it will be added to the description of O-11 to include Business
Continuity Management

Questions on SIM3 in general


Q: Why is SIM3 not an ISO or IETF standard?

A: OCF has made the conscious decision to not submit SIM3 to any formal standardisation
process. The reason for that is that such formal processes, almost without exception, increase
the complexity of approaches, certainly over time – and reduce the flexibility. The worldwide
success of SIM3 since its introduction in 2008 is based on its simplicity and ease of application.
Even with the introduction of SIM3v2 during 2022, which will add some new features and be
useful for more types of security teams, the boundary condition of SIM3 will remain very strong:
simplicity and ease-of-use. This also keeps the cost of application low.

Questions on the four SIM3 Categories O, H, T and P


Q: It seems that the 17 Process Parameters have rather different natures, from high level
to low level. Is the word ‘process’ really warranted for all of them?

A: This was a deliberate determination in the design of SIM3, to avoid excessive complexity. In
fact, there are potentially three Ps in the ‘P’ category: policies, processes and procedures. They
have, for the sake of convenience, all been listed under the Processes category but they indeed
have different natures.

Q: Why are O-6 (Public Media Policy) and O-11 (Security Policy) not in the Processes
category, as you could argue these are really more akin to the kind of parameters found
in that Category?

A: The reason they are in the Organisation Category is that O-6 and O-11 are both quite
fundamental policies that are an essential part of the organisational make-up of CSIRTs. This is
why it was decided to have them in the ‘O’ Category.

Questions on the SIM3 levels 0 to 4 and related evidence gathering


Q: How can I figure out if the parameter is level 3 or 4?

A: Essentially, the parameter is level 4 when there is regular checking, assessing or auditing of
this parameter on the authority above team manager and a feedback mechanism is preserved
throughout.

This is intended to ensure that the higher level of governance is actively aware of some of the
crucial aspects of the CSIRT and how it functions in real life.

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Q: Our team manager conducts an internal compliance review every year for our own
purposes. SIM3 methodology is used as a framework in the review. Does that count for
level 4?

A: No, because the process lacks involvement of the higher governance.

Q: Our team manager sends a report to higher governance every year, and the report
explicitly refers to seven of the SIM3 parameters. Does that mean those parameters can
go to level 4?

A: No, because sending a report to higher governance does not satisfy the level 4
requirements; a regular audit or review needs to be done on the authority of higher governance,
and there needs to be a feedback loop with the team, aiming for improvements. Just sending a
report really means nothing as yet, therefore this does not warrant level 4 in any way.

Q: Our management board commissions an audit of our unit to the internal audit unit.
This is a part of an annual [PUT ANY STANDARD HERE] compliance review. The audit
report is presented to the management board along with findings and recommended
actions. The annual review also pertains to the actions taken by the team since the
previous audit. Does that count for level 4?

A: Yes, but only when it is explicit enough in mentioning the aspects corresponding with SIM3
parameters. It will probably also only work towards a subset of the SIM3 Parameters, since
SIM3 does not fully map to any of the known formal standards. Thus, it is strongly
recommended to use SIM3 as one of the controlling documents in such audits.

Q: The topic of a parameter is covered in our cybersecurity legislation. Is this sufficient


for level 4?

A: Yes, but only when the law mentions it explicitly – and when the function is indeed
implemented within the team. Thus, this still requires documentation inside the team for such
aspects and embedding it in a team information system, processes, service description etc.

Q: How can I know if evidence is suitable for a particular parameter?

A: Due to the specific characteristics of each team, the SIM3 methodology tries not to indicate
a specific set of evidence for achieving a specific level of maturity. Therefore, a predetermined
closed checklist for the parameter (and the maturity level assigned) cannot be introduced.
Additionally, in terms of finding evidence and assessing its relevance, SIM3 does not require a
special approach.

There are some good practices (apart from common sense!) that can be conducted to ease
this process. The person who performs the self-assessment may do the following.

1. Identify all relevant parties to the CSIRT functions (e.g. CISO, CIO, BCM Unit, IT
Department, Legal Office, Communication Department, HR, Internal Audit) simply in
order to ask for a particular piece of information or document.
2. Collect all physical and electronic documentation. This may include procedures,
instructions, playbooks, policies, regulatory documents, control lists, incident response
plans, contact lists, diagrams, etc. These may already be collected for the purposes of
another assessment.
3. If applicable, look for documents scoped by the integrated management systems
(usually the Information Security Management System is relevant here).
4. If applicable, look for any previous reports from security audits.

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5. Identify all knowledge bases that are used within the CSIRT – these may be sources
such as an internal wiki and intranet.
6. Create a list of the most important technologies and tools that are used by CSIRTs.
Identify what they are used for and who uses and manages them.

Q: What is the optimal level to which we should strive while building the maturity of the
team? Our management usually requires us to achieve the highest scores in this type of
assessment.

A: It should have been emphasised that it is not necessary or required to ‘push’ everything to
level 4 unless it comes naturally from continuous improvement. The OCF SIM3 standard scoring
should not be treated as a linear solution. SIM3 does not require a CSIRT to implement an
elementary approach in which the only strategy should be to reach the highest possible score
for every parameter. The scoring system from 0 to 4 is only the probe of technical interpretation
of the controlled area. The real need for achieving a particular level of the maturity bases
depends on many factors such as a strategy, a mission, priorities, operational needs etc. Thus,
the strategy for the development of a national level CSIRT differs much from a CSIRT strategy
of a small or medium-sized organisation. The roadmap to the maturity of any CSIRT should be
determined individually or based on some recommendation (e.g. TF-CSIRT Trusted Introduction
certification schema or ENISA/GCMG profiles). A consciously-developed strategy can positively
influence the conduct of an optimal long-term development of CSIRT maturity.

Q: The potentially-long process of developing an assessment report prevents us from


taking action. Is there any template or tools that we can use to speed up the process?

The following two (optional) documents have been made available to help the assessment and
peer-review process:

1. CSIRT maturity evaluation report template (see Appendix C)


2. CSIRT maturity evaluation spreadsheet (see Appendix D)

Both documents can be used together for the purpose of self-assessment and peer-review, in
conjunction with ENISA’s online maturity self-assessment tool.

Questions on the SIM3 parameters


Q: What is the difference between O-3 and O-4?

A: O-3 is the authority of the team – what it is allowed to do towards its constituency, based on
its mandate (O-1) – the power of the team. Is that power just advisory? Or can the team also
escalate? Or can it also enforce (e.g. port filtering, blocking, etc.)? Clearly, the authority of the
team needs to come from higher governance or else there will be no high-level support for the
team in cases where the power needs to be used.

O-4 is the responsibility of the team – what it is expected to do towards their constituency, again
based on its mandate. Basically, the responsibility is a high-level version of what is detailed in
the team’s services (O-5). In almost all cases, a team has more responsibility than authority. For
example: a team may well be responsible for checking out if new threats could hurt their
constituency, e.g. by doing non-interruptive port scans. But that is not to say that the team has
the authority to go beyond ‘non-interruptive’ scans or that, if the team finds such vulnerabilities,
it can give orders to the constituents in question; this will often be in the form of advice, not
enforcement.

A situation to avoid is where a team’s authority is very small but their responsibility very big. If
the gap between O-3 and O-4 becomes too great then a team is more or less expected to do

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many things without having the power to actually make them work. That is a recipe for
malfunctioning. There is a natural gap between O-3 and O-4 but it should not become too wide.

Q: Why does P-8 combine audit and feedback? Why not treat them separately?

A: The essential idea behind P-8 is that it should help teams to foster a fruitful collaboration
between a team’s higher governance level(s) and the team itself. This is also the essence of
maturity level 4. Collaboration only exists by virtue of two-way communication. The mechanism
chosen in P-8 to support and inspire this is the method of ‘audit’ on the authority of higher
governance. But such an audit is only useful when followed by feedback to the team. The goal
is that the audit (or review or assessment) leads to a fruitful communication (feedback) between
the higher governance and the team – which then should lead to whatever changes or
improvements are needed, such as hiring more people, or more specialised people; sending
team members for specific training; increasing the tooling of the team; optimising various
processes; improving the outreach of the team; etc.

Q: Can P-8 help to bring parameters to level 4?

A: Yes, that is one of the design functions of P-8. When the P-8 process or policy is specific
enough, it can lead to parameters being rated at level 4. What is needed is simple enough.
When P-8 specifically refers to certain aspects, corresponding to specific parameters, and the
policy ensures that:

1. the audit (or review or assessment) is done on the authority of the higher governance
level(s);
2. the audit is done regularly (typically once or twice a year – once every two years is
seen as the minimum); and
3. there is feedback after the audit to the team in order to establish two-way
communication between the team and higher governance, with the aim of improving
the team’s set-up and operations;

then such parameters can be rated at level 4.

Of course, when all this is the case and such audits have already been performed then the
obvious request of any external auditor (or peer-reviewer) will be to examine one of the audit
reports, and the consequences arising therefrom – and the team needs to be prepared to
oblige.

Q: What kind of ’audit’ is meant in P-8? Formal or informal, internal or external, etc.?

A: The audits meant in P-8 are really any type of audit, review or assessment. If a team does
internal evaluations twice a year, this can be listed under P-8 and the question is then simply
whether it is level 2, 3 or 4 (level 1 seems unlikely, as such audits are rarely documented).
Indeed, internal evaluations can be at level 4 provided level 4 requirements are met, which
would mean that such an evaluation scheme would need to be approved by higher governance
and checked regularly. However, an internal evaluation only by the team will never make it
possible to lift parameters other than P-8 itself to level 4 because, for example, even if that
evaluation explicitly includes O-1 and O-5 every year, it does not satisfy the level 4 demands for
O-1 and O-5, and so O-1 and O-5 cannot be raised to level 4.

Thus, to use P-8 as enabler for level 4 (see the previous Q&A) it is necessary that there is also
a regular audit or evaluation on the authority of higher governance, including a feedback loop to
the team – and that it is made explicit what such an audit will (at least) cover.

Q: The updated Maturity Evaluation Spreadsheet contains an ‘Evidence collected’


column. What information should we add to this column?

A: The information about the evidence should refer to the type of evidence (document,
screenshot, part of an internal wiki etc.) and the name or, if the evidence has no name, a brief

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description of what it is about. Excerpts from evidence placed in cells are not required. Evidence
names should be consistent for all parameters.

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5.2 APPENDIX B: COMMENTS ON ALIGNMENT TO CYBERSECURITY STRATEGY AND


NIS2 DIRECTIVE

New EU Cybersecurity Strategy

On 16 December 2020, the European Commission and the High Representative of the Union for
Foreign Affairs and Security Policy presented a new EU Cybersecurity Strategy for the Digital
Decade. The EU’s new Cybersecurity Strategy aims to ensure a global and open Internet with
strong guardrails to address the risks to the security and fundamental rights and freedoms of
people in Europe. Following the progress achieved under the previous strategies, the strategy
contains concrete proposals for deploying three principal instruments – regulatory, investment
and policy – to address three areas of EU action:

(1) resilience, technological sovereignty and leadership,


(2) building operational capacity to prevent, deter and respond, and
(3) advancing a global and open cyberspace.

Some of initiatives will have an impact on how national, sectorial or private CSIRTs and SOCs
should operate – for example, the initiative to build a European Cyber Shield; the Commission
proposes to build a network of Security Operations Centres across the EU. Effective
collaboration of SOCs from different types of organisations and nations will be possible just by
building mutual understanding and trust between the teams.

Recommendations for future framework development:

1. A specific maturity profile might be useful to indicate whether the maturity level of a
SOC is sufficient for it to be accepted into the ‘EU’s Cyber Shield’ network. To be
analysed in future work.

Additionally, the question of the use of AI is addressed in FAQ section.

Proposal for NIS Directive

The Directive on Security of Network and Information Systems (the NIS Directive) provides legal
measures to boost the overall level of cybersecurity in the EU. It came into force in 2016 and
helped achieve a higher and more even level of security of network and information systems
across the EU. In view of the unprecedented digitalisation of the last years, the time has come
to refresh it. The revised Directive was proposed on 16 December 2020.

The revised version proposes more stringent measures for supervision and enforcement,
including administrative sanctions, such as fines for breaches of the obligations to manage and
report cybersecurity risk. Other changes propose increased information sharing and co-
operation between authorities in Member States with the enhanced role of the Co-operation
Group; co-ordinated disclosure of newly discovered vulnerabilities across the EU; streamlined
obligations to report incidents with more precise provisions on the reporting process, content
and timeline; as well as an expanded scope to include more sectors and services as either
essential or important entities.

It is additionally addressed in the FAQ section.

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5.3 APPENDIX C: UPDATE OF THREE-TIER MATURITY APPROACH AND SIM3


STANDARD
The table below presents the minimum scores required for the three steps of maturity, similar to Table 3 in Chapter 3,
but the version here also highlights the changes between the old ENISA Framework and the current one ̶ and thus
also the most significant changes between SIM3v1 and SIM3v2i. In addition, it indicates what increases in the overall
requirements for maturity in the three steps.

Parameter Parameter Minimum values for the tiers:


number Description Basic Intermediate Advanced

O-1 Mandate 3 4 4

O-2 Constituency 3 4 4

O-3 Authority 3 4 4
In the description in SIM3v2i it will be explicitly stated that the whole purpose of the O-3 parameter
is to help ensure that a CSIRT has a clear and distinct description of its authority. If the cyber
security law can provide that clarity for an nCSIRT, so much the better – if the law is not very
specific then the CSIRT should make sure that the authority is defined more precisely, starting
from the law. Also the difference between O-3 and O-4 will be explained better (also see FAQ).
O-4 Responsibility 3 4 4
In the description in SIM3v2i the difference between O-3 and O-4 will be explained better (see also
FAQ).
O-5 Service Description 3 4 4
In the description in SIM3v2i it will be stated explicitly that the concept of O-5 and O-7 is only to
ask ‘have you defined your services towards the constituency (O-5) and the service levels thereof
(O-7)?’ Detailing what those services should or should not be is up to the team as SIM3 makes no
specific requirements on these matters – although, of course, in other parameters it is assumed
that every CSIRT at least deals with Incident Management as a service. It will also be stated that
SIM3 serves as the overall maturity standard for the CSIRT, and can be visualised by a horizontal
line with the forty-five parameters as ticks on that line. On O-5 (and O-7) a vertical line intersects
the SIM3 horizontal line; that vertical line is the visualisation of the FIRST CSIRT Services
Framework, which every team is strongly recommended to use to map their services portfolio in
detail.
N/a >
O-6 ->2 ->3 ->4
Public Media Policy
O-6 has been added as a new parameter in SIM3v2i in the space that in SIM3v1 was ‘intentionally
left blank’. O-6 is about how to work together with the press and how to conduct public
communications in general. The NIS2 Directive makes it necessary to aim high here, starting with
a minimum of level 2 and growing towards level 4. This is aligned with the demands for O-11
(identical) and P-2 (the same for Basic and Intermediate but, for Advanced, level 4 is requested
for O-6 policy whereas for the P-2 process, level 3 is regarded as sufficient).
O-7 Service Level Description 3 3>4 3>4
The levels here are aligned with O-5. In general, the move from NISD to the NIS2 Directive comes
with higher service demands, which makes this alignment logical. The 1.5 year re-assessment
time-interval should allow sufficient time for this change.
O-8 Incident Classification 1>2 2>3 3

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The ENISA supported ‘common taxonomy’ will be referred to explicitly in SIM3v2i. Based on the
NIS2 Directive it is reasonable to demand at least level 2 for Basic, growing to level 3 for
Intermediate, while Advanced can stay on level 3.
Integration with existing CSIRT Systems >
O-9 3 4 4
Participation in CSIRT Systems
The name change for the parameter is a straightforward improvement, leaving out the superfluous
word ‘existing’ (one can only participate in a system if it exists), and changing ‘integration’ into
‘participation’ as that better reflects the reality. It will be explicitly emphasised how important the
participation in national CSIRT networks is also, apart from regional ones (such as CNW and TF-
CSIRT), and global ones. Where the focus of participation will be depends on the type of team.
O-10 Organisational Framework 3 3 3
In the description in SIM3v2i it will be stressed that O-10 does not have to be one single document.
It will also be stated that RFC 2350 can be part of O-10 but not all of it, and that RFC 2350 is
essentially a public document, whereas O-10 is an internal controlling document, often referred to
as the ‘team charter’. For CSIRTs, most of O-10 can be in the law – yet even then it can be very
useful to re-iterate the O-10-related aspects in, for example, a team wiki, with the correct
references.
It will also be stressed that the great use of having a consolidated write-up of O-10 (even if it is
more than one document) is that this is indeed the high-level ‘charter’ of any team – the controlling
document describing who and what they are, and what is expected of them. This is the kind of
controlling document for which the approval of higher governance is needed, and can then serve
as a reference for the functioning of the team, for audits etc.
O-11 Security Policy 1>2 2>3 3>4
In the description in SIM3v2i or FAQ, that business continuity (and BCM) is an essential element
of information security will be added – references will also be made to the resilience’ of T
parameters and to H-2. Given the NIS2 Directive and the importance of business continuity, the
level of demands here have been upgraded by +1 for all three tiers, leading to level 4 at the
Advanced tier.
Additionally the NIS2 Directive (Article 10.1.(b) and €) has expectations in this area, that they align
with the levels here – more specifically, the NIS2 Directive asks for secure sites (premises and the
supporting information systems) and for working space resilience (backup working space). SIM3
is a global standard and therefore does not reflect any specific national or regional situation.
However the concept of site and workspace resilience will be added explicitly to the BCM aspect
of O-11 in SIM3v2i.
O-* maturity increase (O-6 not counted) +2 +3 +2

H-1 Code of Conduct/Practice/Ethics 2 3 3


SIM3v2i or FAQ emphasise that a generic ethics code is good, but has nothing to do with CSIRT
work – therefore make sure to have your own ethics code. Highlight both CCoP and EthicsFIRST
and suggest that specific CSIRT co-operatives can create their own ethics code.
Personnel Resilience >
H-2 2 3 3>4
Staff Resilience
The parameter name change is done to (a) avoid the previous confusion between ‘personal’ and
‘personnel’ and (b) to align with the use of ‘staff’ in H-4. As O-11 is improved to explicitly include
business continuity, H-2 is related, as ‘having enough people on the job’ is a boundary condition
for BCM. The level demands for both have been aligned – a level 4 for Advanced is clearly
necessary for H-2.
Additionally, the NIS2 Directive (Article 10.1.(d)) has expectations in this area ̶ that there is
alignment with the levels here.

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H-3 Skillset Description 1>2 2 3


Even at the Basic step, a written skillset description is needed when hiring professionals, hence
level 2. The forthcoming FIRST role/skillset document can be used as a reference.
Internal Training >
H-4 1>2 2>3 3>4
Staff Development
SIM3v2i clarifies that this parameter is about staff development as a whole, thus the name change,
including personal development plans, and team building or education – much of it will be ‘internal’
but not necessarily so. H-5 and H-6 zoom in on two important aspects thereof, important enough
to warrant separate parameters, but H-4 is the high-level aspect. nCSIRTs are high-profile teams
paid for by public money – therefore the Advanced step needs to be at level 4, with proper auditing
and feedback. The Basic step already needs to be level 2, just as H-3 is at level 2 for Basic – the
H-4 programme leans on H-3 skillsets for roles.
External Technical Training >
H-5 1 2 3
Technical Training
SIM3v2i clarifies that H-5 is a specific, crucial part of the H-4 programme, requiring hard budgets
and prioritisation. It does not have to be ‘external,’ hence that is left out. Also added in SIM3v2i or
the FAQ is that it is about hard skills in general, as opposed to the soft skills that are the topic of
H-6.
(External) Communication Training >
H-6 1 2 3
Soft Skills Training
SIM3v2i clarifies that H-6 is a specific, crucial part of the H-4 programme, requiring hard budgets
and prioritisation. It does not have to be ‘external’, hence that is omitted. It is also generalised to
say ‘soft skills’ complement the ‘hard skills’ from H-5. SIM3v2i or FAQ also add that the soft skills
include the essential topics of human communication (and not just talking with the press – it is a
skill that’s needed by CSIRT members in general), team building, working under stress, etc.
H-7 External Networking 2 3 3

H-* maturity increase +2 +1 +2


IT Resources List >
T-1 1 1>2 1>3
IT Assets & Configurations
SIM3v2i clarifies that ‘assets’ is a more meaningful name than ‘resources’ and that T-1 is about
more than just those assets – it is about knowing, to some reasonable extent, what the constituents
have in terms of hardware, firmware and software, and how it is configured. ‘Assets &
Configurations’ seems, as a whole, to describe that well.
With increasing emphasis on CIIP, it is not acceptable to have level 1 across the board here – a
growth to level 3 for Advanced is entirely warranted. An nCSIRT may not have to know all details
of assets and configurations but, to some degree, there must be sufficient knowledge of the main
systems and software in use inside the CIIP, or else it is impossible to do targeted threat intel and
provide targeted advice.
T-2 Information Sources List 1>2 2>3 3>4
The NIS2 Directive specifically mentions Vulnerability Management, thus upping the ante for T-2
and P-12. Level 2 is thus the minimum to start with for Basic, growing to level 4 for Advanced.
Level 2 means that an informal list (e.g. on a team wiki) can be maintained, which is very easy and
really the minimum needed. For Intermediate, this list can still be on, for example, the team wiki,
but its existence and maintenance needs to have approval from the team management. Level 3
does not mean the list has to become static, it can still be dynamic, as long as the process (see
also P-12) for approval (and removal) of information sources has management support. Level 4
for Advanced means that this list and its maintenance are subject to audit and feedback by higher
governance.

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Consolidated E-Mail System >


T-3 1>2 2>3 3
Consolidated Messaging System(s)
SIM3v2i clarifies the name change based on the fact that ‘messaging’ nowadays is a more generic
name for e-mail and other messaging systems (signal, threema et al.) that are in use concurrently
for similar purposes. These need to be consolidated one way or another. As to levels, by definition,
a functioning messaging system is already at level 2 (Basic) and a growth to level 3 (Intermediate)
already is logical, as this important parameter requires management oversight and approval.
Additionally the NIS2 Directive (Article 10.1.(a) and (e)) has expectations in this area that align
with the levels here.
T-4 Incident Tracking System 1>2 2>3 3

No name change needed, but otherwise similar reasoning for level changes as with T-3.
Resilient Phone >
T-5 1>2 2>3 3
Resilient Voice Calls
SIM3v2i replaces ‘phone’ by ‘voice calls’. It clarifies that the old mechanism of real-time voice or
phone calls is as important as it always was, which also applies to CSIRT work. In some cases we
can conveniently add video calls to that, creating another dimension.
The demands for levels have been synchronised with those for H-2 – as this is all about business
continuity. Therefore starting at Basic with level 2 is necessary – but whilst growing to level 4 is
necessary for H-2, it is sufficient to stop at level 3 for T-5 to T-7, as it is enough that these are
managed on the level of the CSIRT; they do not require a higher governance audit.
Additionally, the NIS2 Directive (Article 10.1.(a) and (e)) has expectations in this area that align
with the levels here.
Resilient E-Mail >
T-6 1>2 2>3 3
Resilient Messaging
Like for T-3, updating the name from ‘e-mail’ to ‘messaging’. The changes in levels here follow the
exact same logic as described for T-5.
Additionally, the NIS2 Directive (Article 10.1 (a) and (e)) has expectations in this area that align
with the levels here.
T-7 Resilient Internet Access 1>2 2>3 3
The changes in levels here follow the exact same logic as described for T-5.
Additionally, the NIS2 Directive (Article 10.1.(a) and (e)) has expectations in this area that align
with the levels here.
T-8 Incident Prevention Toolset 1>2 1>2 1>3
A description on, for example, a wiki (level 2) is regarded as the absolute minimum for T-8 to T-
10, in order that all team members can know and access the relevant tools – this is generally
enough for T-8. However the NIS2 Directive is explicit about prevention activities (such as
vulnerability management) and therefore a level 3 for Advanced is necessary.
T-9 Incident Detection Toolset 1>2 1>3 1>3
As for T-8, a description on, for example, a wiki (level 2) is regarded as the absolute minimum
here. However given the crucial significance for CSIRTs of incident detection and resolution, also
explicated in the NIS2 Directive, level 3 is warranted for both Intermediate and Advanced. For the
associated process, the demand for Advanced will even be level 4.
T-10 Incident Resolution Toolset 1>2 1>3 2>3
As for T-8, a description on, for example, a wiki (level 2) is regarded as the absolute minimum
here. However given the crucial significance for CSIRTs of incident detection and resolution, also
explicated in NIS2 Directive, level 3 is warranted for both Intermediate and Advanced. For the
associated process, the demand for Advanced will even be level 4.

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T-* maturity increase +9 +12 +8

P-1 Escalation to Governance Level 3 3>4 3>4

Levels are aligned with those for the parameters O-1 to O-5, as this escalation is equally crucial.

P-2 Escalation to Press Function 1>2 2>3 3


This important escalation needs to be approved by the CSIRT manager when it is at least already
at the Intermediate level. Levels are synchronised with the new P-6 parameter. Advanced level 3
is seen as sufficient here, while the press policy O-6 itself needs level 4 for Advanced.
P-3 Escalation to Legal Function 1>2 2>3 3

Same levels and reasoning as for P-2.

P-4 Incident Prevention Process 1>2 2>3 2>4


Levels follow the same reasoning as for the associated T-8. However for Advanced, level 4 is
required, as the importance of this process under the NIS2 Directive warrants auditing & feedback.
P-5 Incident Detection Process 1>2 2>3 2>4
Levels follow the same reasoning as for the associated T-9. However for Advanced, level 4 is
required, as the importance of this process under the NIS2 Directive warrants auditing & feedback.
P-6 Incident Resolution Process 1>2 2>3 2>4
Levels follow the same reasoning as for the associated T-10. However for Advanced, level 4 is
required, as the importance of this process under the NIS2 Directive warrants auditing & feedback.
P-7 Specific Incident Processes 1>2 2>3 2>4

Levels follow the same reasoning as for P-5 and 6.


Audit/Feedback Process >
P-8 2>3 3>4 4
Audit & Feedback Process
SIM3v2i and the FAQ add the aspect(s) of innovation, agility and flexibility to P-8 – how fast the
CSIRT invents and builds new tools and services according to new technology and legal changes,
i.e. the capability to adapt, generally speaking. You should also stress that this is about audit and
feedback from higher governance to the team – hence the slight name change ̶ explaining the
idea of audit and feedback thoroughly to avoid confusion. Explain that in general it is a good idea
to explicitly refer in P-8 to those parameters that need to be at level 4.
Levels must be aligned with O-1 to O-5.
P-9 Emergency Reachability Process 2 3 3
Best Practice E-mail and Web Presence >
P-10 2 2>3 2>3
Best Practice Internet Presence
In SIM3v2i the name change is explained – it is especially due to the fact that social media have
become important parts of the team’s online presence. Also, the new description will be more
explanatory, less prescriptive, similar to P-13. It is about having a clear process to deal with the
team’s presence on the Internet, rather than with the detailed implementation thereof.
The changes in level are due to the fact that it is essential in an early stage that team management
approves the team’s Internet presence; hence level 3 for Intermediate and Advanced.
P-11 Secure Information Handling Process 2 3 3
SIM3v2i will additionally state that P-11 should incorporate compliance with applicable privacy
laws, such as the GDPR and others, depending on where the team is based.
The NIS2 Directive (Recital 69 and 70) has expectations in the area of GDPR that align with the
levels here.
P-12 Information Sources Process 1>2 2>3 3>4

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Levels change based on same reasoning as for T-2, NISDS2 increased priority.

P-13 Outreach Process 1>2 2>3 3>4


SIM3v2i or the FAQ clarify that this process should be two-way – it should include modes of
feedback from constituency to team. This is different from the feedback in P-8, which is from higher
governance. Level-wise, the NIS2 Directive warrants level 4 for Advanced, and any outreach to
the constituency really cannot be level 1, thus making level 2 the minim for Basic.
Reporting Process >
P-14 2>3 3>4 4
Governance Reporting Process
SIM3v2i explains the name change as follows: as P-14 and P-15 are now both about reporting
processes, the difference between them needs to be made clear. Level-wise, it is aligned with O-
1 to O-5, and the NIS2 Directive requires that along with an emphasis on (mandatory) reporting.
Statistics Process >
P-15 1>2 2>3 3
Constituency Reporting Process
SIM3v2i makes clear that this parameter was and is really about what and how you report to your
constituency, as opposed to your governance (P-14) – whether that includes statistics or not is
less relevant, hence the name change. Level wise this is sensitive enough to require a minimum
of level 2 for Basic – whereas management approval is needed the sooner the better, hence twice
level 3.
In the tooling, level 1 could be present for P-15, but choosing level 1 does not allow P-15 to be
disregarded, as level 1 is not a valid option for Basic, Intermediate and Advanced steps, and that
should show in the tool. It is a valid option for the Under-basic step however.
P-16 Meeting Process 1>2 1>2 2>3
SIM3v2i or the FAQ has added online and hybrid meetings as options. Level-wise, this parameter
is so important (and some degree of notes taking must be in place) that level 2 is seen as the
absolute minimum. Level 3 is sufficient and required for Advanced.
Peer-to-Peer Process >
P-17 1>2 1>3 2>4
Peer Collaboration Process
In SIM3v2i the name change is clarified, and also that this parameter is about working together
with other security teams (CSIRTs, SOCs, PSIRTs etc.) outside but also inside the constituency.
Again, the feedback from (in this case) peers should be part of the process, like in P-8 (feedback
from higher governance) and P-13 (feedback from the constituency). Information sharing is an
explicit topic in the NIS2 Directive, thus a level upgrade is warranted to start with level 2 for Basic
and go towards level 4 for Advanced.
P-* maturity increase +13 +16 +15

32
TP-07-22-077-EN-N X
ABOUT ENIS A
The European Union Agency for Cybersecurity, ENISA, is the Union’s agency dedicated to
achieving a high, common level of cybersecurity across Europe. Established in 2004 and
strengthened by the EU Cybersecurity Act, the European Union Agency for Cybersecurity
contributes to EU cyber policy, enhances the trustworthiness of ICT products, services and
processes with cybersecurity certification schemes, co-operates with Member States and
EU bodies and helps Europe prepare for the cyber challenges of tomorrow. Through
knowledge sharing, capacity building and awareness raising, the Agency works together
with its key stakeholders to strengthen trust in the connected economy, to boost resilience
of the Union’s infrastructure and, ultimately, to keep Europe’s society and citizens digitally
secure. More information about ENISA and its work can be found here:
www.enisa.europa.eu.

ISBN 978-92-9204-563-0
doi: 10.2824/35453

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