Independent thinking. Informed defence.

CISO Times

Intelligence for the people behind the defence.

The CISO Decision Brief

Management Body Cybersecurity Training Plan

Plans and evidences the cybersecurity training members of the management body are required to follow.

Available soon

Format
Excel
Size
87 KB
Length
12 sheets
Version
1.1
Updated

What's inside

What changed

  1. 1.1

    The training interval is this pack's default, not the Directive's.

  2. 1.0

    Published.

Changes across this pack

Preview

The workbook's sheets as you will receive them, with its example rows and the values its formulas calculate. Highlighted [[text]] is for you to replace; rows marked EXAMPLE are for you to delete. Wide sheets scroll sideways. The cover, document control and changelog sheets are in the file.

Instructions

How to use this workbook

StepWhat to do
1On the Plan Overview sheet, set the As-at date. The EXAMPLE uses 2026-09-30, the example quarter end; type today's date, or =TODAY() to keep it current. Check the cadence: at least every 12 months, and within [[3]] months for a new member (NR-05), unless national law sets a shorter time.
2On the Programme sheet, review the six topics (MT-01, MT-02, MT-03, MT-04, MT-05, MT-06) and their minutes: 120 minutes in all. Change the content to fit your entity, but keep a topic for each duty the body has. Say where the materials are kept.
3On the Members sheet, list every member of the management body: an ID, the role, the date appointed, and the date left when someone leaves. Do not delete a member who leaves: the record stays.
4On the Sessions sheet, enter each session, held or planned: an ID, the type (Induction, Annual, Refresher), the date, the trainer, and Yes or No for each topic it covered. The minutes and the topics covered calculate.
5On the Attendance sheet, add one row per member per session: Booked when booked, then Yes or No once the session is held. The role, the date, the topics, the trainer and the next due date fill in.
6Read the Members sheet: each member's last training, booking, next due date and status. Book anyone showing Book now, move a booking that is booked after due date, and train anyone overdue at once. Clear every Record check that does not say OK.
7Read "Where we stand" on the Plan Overview sheet and report the board figure with the quarterly cyber report (P03 BM-08). Give the board secretary the figures for Part F of the Management Body Cybersecurity Accountability Record.
8Keep the agenda, the slides and the attendance sign-in for each session where the Sessions sheet says. That, with this workbook, is the record a supervisor may ask for.
9Delete the EXAMPLE rows before the plan is approved. Do not type over the white calculated columns.

Legend

Yellow cells are inputs. Everything else is calculated or fixed — do not overwrite formulas.

EXAMPLERows marked EXAMPLE in the first column show how a completed row looks. Delete them before approval.

This document helps you apply NIS2's own tests to your facts. It is not legal advice. National law may add to the Directive or define terms more closely, so confirm the result with counsel before you rely on it.

EXAMPLE: a wholesale distributor with about 900 staff, three warehouses and an online ordering service that takes 60% of its orders, as at 2026-09-30. Its management body is a board of seven: the chair, the chief executive, the chief financial officer and four non-executive directors. Six members were trained at the annual session on 26 Feb 2026; the member appointed on 15 Jul 2026 is booked on an induction on 8 Oct 2026, inside the 3 months (due 15 Oct 2026). The board figure is Board 6 of 7, as P03's BM-08 reports.

Tailoring — small organisation: where the management body is one or two people, one session a year that covers all six topics is enough, and it can be a briefing by the NIS2 lead or an outside trainer. Keep the attendance record all the same.

Tailoring — regulated entity (NIS2, DORA): national law may set how often members are trained, or what the training must cover; check it with counsel and change the cadence on the Plan Overview. A financial entity under DORA keeps its management body's ICT risk training to DORA Article 5(4) as well. Offer similar training to staff (NR-05), and keep that record in your awareness programme.

Tailoring — IT run by a service provider: a provider or an outside trainer may deliver the sessions. Content and attendance stay yours: record them here, and ask the trainer for the slides.

Plan Overview

Plan overview

Where the training stands, what the plan is for, how often each member is trained, and who approved it. Yellow cells are yours; the EXAMPLE entries show a completed plan.

As-at date30 Sep 2026EXAMPLE date (the example quarter end). Replace it with today's date, or type =TODAY().
Train every member at least every (months)12At least once a year (this pack's default; NIS2 Art 20(2) and DORA Art 5(4) require the training and set no interval), as the Board Cybersecurity Reporting pack sets it. Shorten it if national law does.
Train a new member within (months)3NR-05. The pack's default; set your own.
Book-ahead window (days)60A member due within this many days and not booked shows Book now. The pack's default; set your own.

Where we stand

MeasureValueWhat it means
Members of the management body7Everyone listed who has not left.
Trained in the last 12 months6Attended a session within the cadence, as at the as-at date.
Board figure for the cyber report (P03 BM-08)Board 6 of 7The board half of BM-08, board and staff security training.
Booked1Not yet trained within the cadence, but booked in time.
To book0Book now, or booked after due date.
Overdue0Past the due date and not trained: NR-05 is not met for them.
Training status (NR-05)On schedule: members bookedEvery member trained; on schedule while the others are booked in time; action needed when someone must be booked; not met when anyone is overdue.
Sessions held in the last 12 months1Sessions on the Sessions sheet dated within the cadence.
Sessions that left out a topic0A member who missed a topic should cover it at the next session.
Programme length (minutes)120The six topics on the Programme sheet.

Objectives and measures of success

ObjectiveMeasure of success
Every member able to judge the entity's cyber risks and challenge how they are managed (NIS2 Article 20(2))Every member trained within the cadence: "Every member trained" or "On schedule" above, never "Not met"
Every new member trained within [[3]] months of appointment (NR-05)No member overdue; a new member booked in their first month
The record ready for a supervisorEvery session with its date, trainer, topics and materials; every attendance recorded

Scope

ItemEntry
Who is trainedEvery member of the management body. The body that directs the entity: the board of directors, or the management board in a two-tier structure. [[Where there is no board, the people national law makes responsible for running the entity.]] NIS2 does not define the term, so confirm with counsel what the national law counts.
Not in this planStaff awareness training, which NR-05 says must be offered to staff too. Keep it in your awareness programme; its figure is the staff half of BM-08 (EXAMPLE: staff 92%).
Period covered[[e.g. 1 Jan to 31 Dec 2027]]

Cadence and content

SessionWhenContentLengthEvidence kept
InductionWithin [[3]] months of appointment (NR-05)All six topics on the Programme sheetAbout 120 minutesAttendance, agenda, slides, trainer
Annual sessionAt least every 12 months (NIS2 Article 20(2), NR-05)All six topics, refreshed with the year's readiness result, incidents and gapsAbout 120 minutesAttendance, agenda, slides, trainer
Refresher[[When a law, the classification or the risks change materially]][[The topics the change touches]][[30 to 60 minutes]]Attendance, agenda, slides

Resources and dependencies

ItemEntry
Trainer[[e.g. external counsel with the Head of Information Security, or an outside trainer]]
Budget[[€ amount for trainer and materials, and who holds it]]
Depends onThe latest readiness result (NIS2 Readiness Self-Assessment), the open gaps (NIS2 Gap & Remediation Tracker) and the quarterly cyber report, so each session speaks of the entity's own position

Review points

WhenWhoWhat is checked
Each quarterBoard secretaryEvery member's status; bookings; the board figure for the cyber report
When a member joinsBoard secretaryThe induction booked within the first month, inside the 3 months
Once a year, at the annual approvalChair of the management body, with the NIS2 leadThe content of the programme, and Part F of the Management Body Cybersecurity Accountability Record

Approval of the plan

RoleNameDate
Chair of the management body[[Name]][[YYYY-MM-DD]]
Board secretary[[Name]][[YYYY-MM-DD]]

Members

One row per member of the management body, current or past. Yellow columns are inputs; white columns calculate from the Attendance sheet. Every colour sits beside a word.

ExampleMemberRole on the management bodyAppointedLeftLast trainedBooked forNext dueDays to due dateTrained in the last 12 monthsStatusRecord checkNotes
EXAMPLEM-01Chair (non-executive)1 Jun 201926 Feb 202626 Feb 2027149YesUp to dateOK
EXAMPLEM-02Chief Executive11 Jan 202126 Feb 202626 Feb 2027149YesUp to dateOK
EXAMPLEM-03Chief Financial Officer5 Sep 202226 Feb 202626 Feb 2027149YesUp to dateOK
EXAMPLEM-04Non-executive director2 Mar 202026 Feb 202626 Feb 2027149YesUp to dateOK
EXAMPLEM-05Non-executive director15 May 202326 Feb 202626 Feb 2027149YesUp to dateOK
EXAMPLEM-06Non-executive director4 Nov 202426 Feb 202626 Feb 2027149YesUp to dateOK
EXAMPLEM-07Non-executive director15 Jul 20268 Oct 202615 Oct 202615NoBookedOK

Attendance

One row per member per session: the record NR-05 asks for. Booked when booked; Yes or No once the session is held.

ExampleMemberRole on the management bodyAppointedSessionDateTopics coveredTrainerAttendedNext dueRecord check
EXAMPLEM-01Chair (non-executive)1 Jun 2019S-2026-0126 Feb 2026MT-01 MT-02 MT-03 MT-04 MT-05 MT-06[[e.g. external counsel with the Head of Information Security]]Yes26 Feb 2027OK
EXAMPLEM-02Chief Executive11 Jan 2021S-2026-0126 Feb 2026MT-01 MT-02 MT-03 MT-04 MT-05 MT-06[[e.g. external counsel with the Head of Information Security]]Yes26 Feb 2027OK
EXAMPLEM-03Chief Financial Officer5 Sep 2022S-2026-0126 Feb 2026MT-01 MT-02 MT-03 MT-04 MT-05 MT-06[[e.g. external counsel with the Head of Information Security]]Yes26 Feb 2027OK
EXAMPLEM-04Non-executive director2 Mar 2020S-2026-0126 Feb 2026MT-01 MT-02 MT-03 MT-04 MT-05 MT-06[[e.g. external counsel with the Head of Information Security]]Yes26 Feb 2027OK
EXAMPLEM-05Non-executive director15 May 2023S-2026-0126 Feb 2026MT-01 MT-02 MT-03 MT-04 MT-05 MT-06[[e.g. external counsel with the Head of Information Security]]Yes26 Feb 2027OK
EXAMPLEM-06Non-executive director4 Nov 2024S-2026-0126 Feb 2026MT-01 MT-02 MT-03 MT-04 MT-05 MT-06[[e.g. external counsel with the Head of Information Security]]Yes26 Feb 2027OK
EXAMPLEM-07Non-executive director15 Jul 2026S-2026-028 Oct 2026MT-01 MT-02 MT-03 MT-04 MT-05 MT-06[[e.g. external counsel with the Head of Information Security]]BookedOK

Sessions

One row per session, held or planned. Mark each topic it covered; the minutes use the Programme sheet.

ExampleSession IDTypeDateTrainerMT-01MT-02MT-03MT-04MT-05MT-06MinutesTopics coveredAll topics coveredHeld or plannedAttendedMaterials kept at
EXAMPLES-2026-01Annual26 Feb 2026[[e.g. external counsel with the Head of Information Security]]YesYesYesYesYesYes120MT-01 MT-02 MT-03 MT-04 MT-05 MT-06YesHeld6[[e.g. board portal, NIS2 training folder]]
EXAMPLES-2026-02Induction8 Oct 2026[[e.g. external counsel with the Head of Information Security]]YesYesYesYesYesYes120MT-01 MT-02 MT-03 MT-04 MT-05 MT-06YesPlanned0[[e.g. board portal, NIS2 training folder]]

Programme

The content of the training: one topic per duty the body has. Rows marked Default are the pack's programme, 120 minutes in all; adapt them.

RowTopic IDTopicWhat it coversMinutesIn the inductionIn the annual sessionMaterials kept atContent owner
DefaultMT-01Our NIS2 status and what it asks of the management bodyWhether we are essential or important and why; approving and overseeing the measures; that members can be held liable (Article 20(1)).20YesYes[[Location of slides and notes]][[e.g. Head of Information Security]]
DefaultMT-02The ten measures and where we standEach Article 21(2) measure in plain words, our readiness level on it and the open gaps.25YesYes[[Location of slides and notes]][[e.g. Head of Information Security]]
DefaultMT-03Our top cyber risks and our appetiteThe risks outside appetite, what they would cost and what is being done (P05, P03).20YesYes[[Location of slides and notes]][[e.g. Head of Information Security]]
DefaultMT-04When an incident happensWho decides what, which decisions only the board or its equivalent takes, and the reporting deadlines the policy sets (P09 IM-08, RD-01 to RD-04).20YesYes[[Location of slides and notes]][[e.g. Head of Information Security]]
DefaultMT-05Supervision, enforcement and personal accountabilityWhat the competent authority may ask for, the measures it may order and the fines it may impose (Articles 32 to 34).15YesYes[[Location of slides and notes]][[e.g. Head of Information Security]]
DefaultMT-06Reading the cyber report and challenging itWhat good answers look like to the board's questions (P03 question bank).20YesYes[[Location of slides and notes]][[e.g. Head of Information Security]]

Lists

YesNoAttendedSessionTypeMemberStatus
YesYesInductionLeft
NoNoAnnualOverdue
BookedRefresherBooked

Booked after due date

Book now

Up to date

Definitions

Definitions

TermMeaning in this workbook
Management bodyThe body that directs the entity: the board of directors, or the management board in a two-tier structure. [[Where there is no board, the people national law makes responsible for running the entity.]] NIS2 does not define the term, so confirm with counsel what the national law counts.
MemberA person who sits on the management body. Use an ID (M-01, M-02 …) or the name, the same on every sheet.
InductionThe first session for a new member: the whole programme, within 3 months of appointment (NR-05).
Annual sessionThe session every member attends at least every 12 months (NIS2 Article 20(2)).
Last trainedThe latest session the member attended (Attended = Yes), from the Attendance sheet.
Booked forThe latest session the member is booked on (Attended = Booked), from the Attendance sheet.
Next dueThe last training plus 12 months; for a member not yet trained, the appointment plus 3 months.
Status: LeftNo longer a member: the date left is on or before the as-at date. Kept as the record.
Status: OverdueThe next due date has passed and the member has not been trained since.
Status: BookedBooked on a session on or before the next due date.
Status: Booked after due dateBooked, but on a session after the next due date: bring the booking forward.
Status: Book nowDue within the book-ahead window (60 days by default) and not booked.
Status: Up to dateTrained within the cadence, and not yet due within the book-ahead window.
As-at dateThe date the statuses are measured against. Set on the Plan Overview sheet.
MT-nnThe number of a topic in the programme.
NR-05Every member of the management body must follow cybersecurity training (Article 20(2)), and similar training must be offered to staff on a regular basis. The Directive sets no interval. This pack's default is at least once a year for each member, and within [[3]] months of appointment for a new member; attendance and content are recorded.
EXAMPLE rowA worked example: a wholesale distributor with about 900 staff, three warehouses and an online ordering service that takes 60% of its orders, as at 2026-09-30. Delete before approval.

Framework References

Framework references

These references indicate relevance only and do not reproduce the text of any standard.

FrameworkReferenceSupported by
ISO/IEC 27001:2022Clause 7.2 — CompetenceProgramme and Attendance: the competence the members need, and the record that they have it
ISO/IEC 27001:2022Annex A 6.3 — Information security awareness, education and trainingProgramme and Sessions: the education and training delivered to the members
NIST CSF 2.0PR.AT-02 — “Individuals in specialized roles are provided with awareness and training so that they possess the knowledge and skills to perform relevant tasks with cybersecurity risks in mind”The whole plan: people in a specialised role, the management body, trained for it
NIS2 — Directive (EU) 2022/2555Article 20(2) — members of management bodies are required to follow training to identify risks and assess cybersecurity risk-management practicesMembers, Sessions and Attendance: every member trained, and the record
NIS2 — Directive (EU) 2022/2555Article 20(1) — management bodies approve the cybersecurity risk-management measures, oversee their implementation and can be held liable for infringementsProgramme, topics MT-01 and MT-05: the duties to approve and oversee, and liability

Editions referenced: Directive (EU) 2022/2555 (NIS2); Commission Recommendation 2003/361/EC; Implementing Regulation (EU) 2024/2690; ISO/IEC 27001:2022 incl. Amd 1:2024; NIST CSF 2.0

ISO/IEC 27001 references name the clause or control this document relates to. They do not say that meeting it meets any NIS2 requirement.

Prepared by Zero One Cybersecurity · Published by CISO Times

CISO Times Resource Licence — Internal Use