Cyber Governance module

Answer the controls once, and see where you stand against every cyber regime that reaches you.

Self-guided, or with advisors at the ready.

NIS2, DORA, the SEC cybersecurity rules, ISO 27001 and NIST CSF 2.0 share one set of 25 controls and differ in how much of it they reach. You pick the frameworks that apply to you, answer once, and only those controls are scored.

See what you need to reportOrder the module, $2,900/yr

DORA does not switch NIS2 off

Where a sector-specific Union act imposes at least equivalent requirements, art. 4(1) disapplies the relevant provisions of NIS2 to the entities it covers, including the supervision and enforcement provisions in Chapter VII. Art. 4(2) sets the equivalence test by reference to art. 21(1) and (2) for cybersecurity risk-management measures and art. 23(1) to (6) for incident notification. NIS2 does not cease to apply: what is displaced is the provisions the sector-specific act replaces, not the Directive.

An entity identified as essential or important submits to its Member State, under art. 3(4), its name, address and up-to-date contact details, the relevant sector and subsector, and the Member States where it provides services. Changes are notified without delay, and in any event within two weeks. Member States were to establish the list of these entities by 17 April 2025.

How people arrive here

NIS2 reaches your sector
Your national law is what actually applies, and the first question is which controls are yours.
You are a financial entity, so DORA applies
It covers more of the controls than any other cyber regime here, including the third-party provider register.
You report to the SEC
The SEC rules reach fewer controls than the others, and the one they add is deciding whether an incident is disclosable.

What the module covers

The control set
25 controls across eight domains: governance, risk management, access control, incident response, supply chain security, technical controls, business continuity, and training and awareness.
NIS2
Scores you against the 19 controls it reaches, including the two it alone requires: a maintained asset inventory, and a documented notification procedure for the 24-hour early warning and 72-hour full report.
DORA
Scores you against the 21 controls it reaches, the widest of the three regimes, including its four unique ones: incident classification, resilience testing, an access review process, and the critical third-party provider register.
SEC cybersecurity rules
Scores you against the 5 controls they reach, the narrowest of the three, four of which are shared with NIS2 and DORA. The one they alone require is the 8-K materiality assessment.
ISO 27001 and NIST CSF 2.0
Scored as well, against 20 and 19 of the controls. Both are voluntary, and both are commonly asked for by customers rather than by a regulator.
Maturity, not yes or no
Each control is recorded as not implemented, partially implemented, fully implemented, or optimised and tested, so partial progress counts as partial rather than as nothing.
What to fix first
Gaps are ranked by the priority weight on the control, and the top five are listed on their own so a remediation plan has somewhere to start.

How it works

You bring
Answers about the controls you already have, one screen at a time.
ThemisIQ applies
The controls each framework reaches, so answering once scores you against all of them at the same time.
You get
A score by domain, your gaps ranked by priority, and a spreadsheet showing how every score was reached.

How you stand behind it

Every control keeps the maturity you recorded, the frameworks that reach it and the priority weight behind its ranking, so a score can be traced to the answers that produced it rather than to a judgement nobody wrote down.

Nothing is a black box. Every score carries the inputs and the method that produced it, so a reviewer can follow the reasoning rather than taking the number on trust.

What the module produces

You can work through the whole assessment and see your results before buying anything.

The gap assessment itself
Work through the controls your frameworks reach and see your score by domain, your gaps and the five to fix first. Downloading the spreadsheet needs the module.
Open the preview

What it satisfies

Each of these is described, sourced and mapped to a module on the regulations page.

NIS2DORAISO/IEC 27001NIST CSF

Pricing

One flat annual price.

Add modules and the multi-module discount applies automatically: two modules −10%, three or more −20%.

Cyber Governance
$2,900 / reporting year
✓25 controls across eight domains
✓Scored against the frameworks that reach you
✓A score by domain, and your gaps ranked by priority
✓The five gaps to fix first
✓A spreadsheet of every control, maturity and priority
Order the module

Questions people ask first

Does DORA mean NIS2 no longer applies to us?
No. Where a sector-specific EU law imposes at least equivalent requirements, article 4(1) sets aside the NIS2 provisions that law replaces, including supervision and enforcement. The Directive itself does not stop applying. A financial entity still has to be identified as essential or important, and still has to keep its own registration details up to date with its Member State. That duty is not a cybersecurity provision, so the carve-out does not reach it.
Which frameworks does this actually score us against?
Five: NIS2, DORA, the SEC cybersecurity rules, ISO 27001 and NIST CSF 2.0. They share one set of 25 controls and differ in how much of it they reach. DORA reaches 21, ISO 27001 reaches 20, NIS2 and NIST CSF reach 19 each, and the SEC rules reach 5. You pick the ones that apply to you and only those are scored, so the number you get is about your obligations rather than about a generic maturity model.
We already have a security team and an ISO audit. What does this add?
A different job from the one your security team does. This does not test your controls or replace an audit. It records what you have against what each regime asks for, ranks what is missing by how much weight the control carries, and gives you the working as a spreadsheet you can hand to a board or a customer. If your ISO audit already covers a control, you mark it and move on.
How long does it take?
Twenty-five controls, and fewer if only some frameworks apply to you. It is five steps: set up, answer the controls, see the results, look at what to fix first, and export. Your answers are saved in this browser as you go, so you can stop and come back. Signed out they are kept for two hours; sign in and they stay.

Not sure which cyber rules apply to you?

Free, takes about five minutes. Your Compliance Obligation Map lists the sustainability-related regulations your company is likely to face, country by country.

See what you need to reportTalk to us