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CYBERSECURITY

OT Cybersecurity Audit

Compliance with NIS2 and the Polish National Cybersecurity System Act (uKSC)
The amended Polish National Cybersecurity System Act (uKSC), implementing the NIS2 Directive, has been in force since 3 April 2026 and imposes new obligations on essential and important entities.

At TT-CS, we conduct OT infrastructure cybersecurity audits aligned with the requirements of NIS2, uKSC, and IEC 62443. We help translate these requirements into a single, structured action plan for your OT infrastructure, from the audit and closing identified gaps to readiness for an inspection.

Key Deadlines Under the KSC Act and the NIS2 Directive

  • By 3 October 2026: >1 month remain to submit an application for entry in the register of essential or important entities.
  • By 3 April 2027: 7 months remain to implement all required obligations.
  • By 3 April 2028: 19 months remain until the first mandatory cybersecurity audit for essential entities.
  • It is not worth waiting until the last minute. Implementing effective OT safeguards, preparing documentation, and organising security processes require time and cooperation across multiple departments.

    The security of OT systems is no longer optional. It is a responsibility for production continuity, water and energy supply, and, in extreme cases, the health and safety of people who depend on this infrastructure. Neglect in this area has tangible financial consequences, including downtime, penalties, and loss of trust among customers and partners. In sectors such as energy and water utilities, physical safety may also be at stake. The following are three of the most common mistakes we encounter.

    An IT Approach Does Not Work in an OT Environment

    Many providers treat OT security as an extension of the IT department, applying the same procedures, priorities, and mindset. Different rules apply on a production floor or at a water treatment plant: uninterrupted equipment operation, rather than data protection alone, is paramount. An approach transferred directly from IT is not only ineffective but may also create a false sense of security where the risk profile is fundamentally different. OT cybersecurity therefore requires different risk-assessment methods, different safeguards, and an approach tailored to industrial systems.

    Documentation Should Reflect the Organisation

    Many organisations implement an Information Security Management System (ISMS) or a Cybersecurity Management System using an off-the-shelf template that does not reflect their actual infrastructure or working practices. Such documentation may look good on paper, but the team does not know how to respond in practice, and the documentation will not withstand scrutiny during an inspection because it does not describe the organisation’s real operating environment. At TT-CS, we therefore develop ISMS and cybersecurity-management documentation based on an audit of the organisation’s actual OT/IT infrastructure and real operational processes. Each policy and procedure reflects how the organisation truly operates, so that the team knows what to do.

    Responsibility Also Extends to Suppliers

    The amended uKSC considers not only your organisation, but also the companies that support and service your infrastructure. Without structuring these relationships, demonstrating compliance is difficult even when internal arrangements are robust. The entire supplier and subcontractor chain must be mapped, and clear security requirements must be introduced into contracts with each party.

    OUR APPROACH

    From Assessment to Compliance

    What Does the TT-CS OT Cybersecurity Audit Include?
    Our work follows a proven “from assessment to compliance” methodology. The organisation receives not only an audit report, but also a practical plan for improving the cybersecurity posture of its OT environments.

    Support in Interpreting NIS2 and uKSC Requirements

    Determining whether your organisation qualifies as an essential or important entity is a legal decision and is not part of our audit. If you need support in this area, we can recommend legal firms and advisers with whom we cooperate and who specialise in classification under uKSC. This avoids a situation in which a technical company, rather than a legal expert, determines your organisation’s legal status. You can then proceed to the next stages with a clear understanding of the obligations that apply to you.

    Assessment of the State of your Organisation’s Security

    Our auditors work together with industrial automation engineers who understand the topology of your systems from previous implementations. The audit is not a theoretical exercise. It is based on how your infrastructure actually operates, rather than on a universal template.
    We examine the technical layer, including networks, devices, and access controls, as well as the policies and procedures genuinely used in day-to-day operations, not merely those documented on paper. We also verify system-maintenance practices, access-rights assignment, change management, incident response, and business-continuity arrangements. The result is a comprehensive view of the security posture on which further decisions can be based.

    Cybersecurity Risk Assessment

    We conduct a cybersecurity risk analysis that considers the impact of potential incidents on technological processes and the organisation’s operations.
    The assessment covers threats that may lead to:

    • Production stoppages.
    • Disruption of critical infrastructure.
    • Loss of service availability.
    • Risks to human health and safety.
    • Financial losses.
    • Regulatory non-compliance.

    Each identified vulnerability is analysed in terms of its likelihood and its potential business and operational impact.

    Vulnerability Prioritisation and Recommended Actions

    A list of non-conformities alone does not solve a security problem.
    We therefore organise audit findings according to risk level, impact on the organisation’s operations, and the deadlines arising from uKSC and NIS2 requirements. The organisation receives a clear priority map that enables resources to be focused on the activities delivering the greatest security benefit.
    Each recommendation includes business and technical justification, supporting management decisions and budget planning.

    Development of an Implementation Plan

    The final deliverable is a detailed roadmap of activities designed to improve the state of the organisation’s cybersecurity.
    The plan may include:

    • Segmentation of industrial networks.
    • Implementation of OT monitoring and SOC/iSOC services.
    • Vulnerability management.
    • Secure remote access for employees and suppliers.
    • Privileged access management.
    • Backup management.
    • Incident-response procedures.
    • Protection of communications between IT and OT environments.

    Drawing on TT-CS experience, we can not only identify the necessary actions, but also support their practical implementation.

    Verification of Compliance with NIS2, uKSC, IEC 62443, and ISO 27001

    We prepare documentation and evidence of compliance with the mandatory audit for essential entities, due by 3 April 2028, in mind. The goal is to ensure that the inspection is not a surprise, but a formality. We make sure that the documentation reflects the actual condition of your infrastructure rather than formal requirements alone. As a result, if an inspection takes place, you have the required answers and evidence ready instead of preparing them in haste under deadline pressure.
    Experience and efficiency

    Competitive Advantage

    We are part of the renowned Transition Technologies Group, which has been creating the future of industrial technology since 1991. The group includes 21 companies, employs more than 2,280 specialists and operates from 27 offices around the world, operating with 100% Polish capital. Our mission is to provide innovative technology solutions that drive global industry growth.

    • Innovation: We constantly invest in the latest technologies to keep our solutions at the forefront of innovation.
    • Experience: More than three decades in the industrial technology market provide us with the knowledge and skills needed for the most demanding projects.
    • Quality: We are ISO 9001:2015, ISO 27001:2013 and ISO 45001:2018 certified, confirming our commitment to the highest standards of quality and safety.

    When you choose our solutions, you are investing in the future of your business – a future that is innovative, efficient and sustainable.

    Trust and Satisfaction

    Opinions of Our Customers

    ”

    From the very beginning of our cooperation, Transition Technologies-Control Solutions has made itself known as a reliable partner. What set them apart was their creative approach at the bidding stage. We were presented with several proposals for solutions based on which we could choose a target direction.

    During implementation, on the other hand, they acted with determination, solving successive problems that arose. Faced with the fact that the project was implemented in a difficult market environment, we often had to work together and develop remedies, often through compromise. Also, during the operation of the site, they reacted constructively and quickly to faults as they appeared.

    TT-CS has proven itself as a trusted partner in challenging projects. We positively look forward to working together on future mechanical engineering projects.

    Adam BombaProcess Manager
    Knowledge and experience

    Our experts guarantee the quality of services

    Development Director

    Pawel Przygodzki

    Aabs graduate of the Wroclaw University of Technology, where he majored in Automation of Energy Processes at the Faculty of Mechanical and Power Engineering. He has been with Transition Technologies Group for over seventeen years, where he began his career as an Assistant Engineer. Currently, for more than four years, he has been serving as the Director of Marketing. He is a Development Director at Transition Technologies-Control Solutions. In his role, he manages a portfolio of industrial automation and cyber security projects with a focus on critical infrastructure.

    Member of ISSA Poland and the Polish Wind Energy Association. He is certified as an ISO 27001 lead auditor, confirming his competence in information security management. He is currently expanding his knowledge and skills by studying an MBA at the Wroclaw University of Economics.

    Project Manager

    Pawel Sukiennik

    Project Manager at Transition Technologies-Control Solutions responsible for the implementation of projects related to the security of OT systems. Graduated from the Faculty of Electronics, majoring in Automation and Robotics at Wrocław University of Technology.

    A member of the association in ISSA Poland. A practitioner with more than 8 years of experience as an integrator of industrial automation and cyber security solutions on many critical infrastructure installations in Poland and abroad.

    OT Cybersecurity Key Account Manager

    Maciej Ramotowski

    Key Account Manager for OT Cybersecurity at Transition Technologies-Control Solutions, where he is responsible for driving business development and sales of industrial cybersecurity solutions. His career spans sales, investment banking, business development in the US, and strategic procurement management within the pharmaceutical and port sectors in Poland. This diverse experience has shaped his ability to build trusted C-level relationships and translate complex technical challenges into clear, business-oriented decisions.

    His career naturally evolved towards industrial cybersecurity, combining his commercial expertise with a strong understanding of the operational and strategic challenges faced by organizations operating critical infrastructure. He is a co-founder of a startup focused on OT cybersecurity, supporting operators of critical services in strengthening their security posture and addressing the requirements of the NIS2 Directive.

    He is a member of ISSA Poland and currently pursuing an ISC2 certification. As an experienced trainer and active industry speaker, he regularly shares his expertise, promotes cybersecurity best practices, and contributes to raising awareness of cyber threats among business leaders and the wider community.

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      FAQ

      Questions
      and answers

      In the FAQ section, you will find answers to key questions about our services and processes, based on knowledge and experience. Our goal is to dispel doubts and provide clear information.

      What Is an OT Security Audit, and Why Is It Essential for Industrial Companies?

      An OT (Operational Technology) security audit is a comprehensive assessment of operational technology systems designed to identify security gaps, evaluate risk, and support the implementation of safeguards against cyber threats. For organisations operating in the industrial, energy, or manufacturing sectors, an audit is essential for maintaining operational continuity, protecting critical infrastructure, and meeting applicable industry requirements. Inadequate safeguards may result in serious consequences, including downtime, financial losses, and reputational damage.

      What Are the Benefits of Conducting an OT Security Audit?

      An OT security audit provides organisations with a range of important benefits, including:

      • Identifying potential security gaps that could be exploited by cybercriminals.
      • Minimising the risk of operational downtime and financial losses caused by cyberattacks.
      • Supporting compliance with current industry requirements, including NIS2, IEC 62443, and ISO 27001.
      • Improving the resilience of operational infrastructure to cyber threats and strengthening incident-management processes.
      • Enhancing the long-term security of OT systems through the implementation of recognised good practices and monitoring tools.

      How Long Does an OT Security Audit Take?

      The duration of an audit depends on the size and complexity of the OT infrastructure. For smaller systems, an audit may take from several days to one week. For larger and more complex installations, a full audit may take several weeks. The schedule and scope are tailored to the client’s requirements to minimise disruption to ongoing business operations.

      Can an Audit Disrupt the Operation of My OT Infrastructure?

      An OT security audit is designed to minimise its impact on the organisation’s ongoing operations. Our approach includes detailed planning of all audit activities, allowing most analyses to be carried out without interfering with critical processes. If certain tasks require real-time intervention, they are performed safely and in a controlled manner, without putting operational continuity at risk.

      What Are the Most Common Threats Addressed by an OT Security Audit?

      An OT security audit helps identify and address a wide range of threats, including:

      • Ransomware: attacks that encrypt or block access to systems and demand payment to restore them.
      • Malware: malicious software designed to disrupt the operation of systems and devices.
      • Advanced Persistent Threats (APTs): sophisticated, long-term attacks that are difficult to detect and may be intended to gain control of OT systems.
      • Unauthorised access: security breaches resulting from misconfigured systems or insufficient access controls.
      • Insider threats: risks associated with authorised employees having inappropriate access to critical systems without adequate control procedures.

      How Does an OT Security Audit Support Compliance with Regulations and Industry Standards?

      One of the key elements of an OT security audit is assessing whether the infrastructure is aligned with applicable regulations and industry standards. The audit helps organisations adapt their systems to internationally recognised requirements such as IEC 62443, ISO 27001, and the NIS2 Directive. Meeting these requirements not only reduces the risk of financial penalties and sanctions, but also strengthens the confidence of customers and business partners, which is particularly important in tendering processes and international cooperation.

      What Are the Key Stages in Implementing Post-Audit Recommendations?

      After the audit is completed, we provide a detailed report containing the findings and recommended corrective actions. Implementation includes the following stages:

      1. Identifying priorities: determining the most critical security gaps that require immediate action.
      2. Implementing recommendations: deploying safeguards such as real-time monitoring, intrusion-prevention systems, and identity and access management.
      3. Testing the solutions: conducting attack simulations to verify that the implemented safeguards operate as intended.
      4. Training personnel: preparing the client’s team to manage the implemented systems effectively and respond to incidents.

      Do You Provide Support After the Audit Recommendations Have Been Implemented?

      Yes. We provide comprehensive support after the audit recommendations have been implemented. This may include regular security testing, system updates, network monitoring, and ongoing incident-management support. Depending on the client’s needs, we can also provide dedicated employee training to improve OT cybersecurity awareness and capabilities.

      Does My Organisation Fall Within the Scope of NIS2?

      This depends on the organisation’s sector, size, and the importance of the services it provides. The NIS2 Directive and the Polish National Cybersecurity System Act (uKSC) cover, among others, companies operating in manufacturing, energy, water supply, transport, healthcare, and digital infrastructure.
      If your organisation uses OT, SCADA, or PLC systems and operates in a regulated sector, it is worth verifying its status as early as possible. An OT cybersecurity audit helps assess preparedness for NIS2 and uKSC requirements and identifies the actions needed to achieve compliance.

      How Does OT Cybersecurity Differ from IT Cybersecurity?

      IT cybersecurity focuses primarily on protecting data, applications, and business systems. OT cybersecurity protects technological processes, machinery, industrial equipment, and critical infrastructure. In OT environments, the key priorities are:

      • System availability.
      • Production continuity.
      • Operational safety.
      • The safety of people and the environment.

      An OT audit therefore requires a different approach from a traditional IT security audit.

      Which Organisations Should Conduct an OT Cybersecurity Audit?

      An OT cybersecurity audit is particularly recommended for organisations operating industrial systems and critical infrastructure, including:

      • Manufacturing companies.
      • The energy sector.
      • Water and wastewater utilities.
      • Critical-infrastructure operators.
      • Chemical and petrochemical companies.
      • The transport sector.
      • The food sector.
      • District-heating operators.
      • The gas sector.

      It is especially important for entities subject to NIS2 and uKSC requirements.

      What Does a NIS2-Aligned OT Cybersecurity Audit Cover?

      A NIS2-aligned OT cybersecurity audit assesses the technical and organisational security measures used to protect industrial environments. Its scope most commonly includes:

      • OT asset inventory.
      • Industrial network architecture analysis.
      • Assessment of SCADA and PLC systems.
      • OT cybersecurity risk analysis.
      • Assessment of security procedures.
      • Access management.
      • Vulnerability management.
      • Incident response.
      • Business continuity.
      • Security of suppliers and subcontractors.

      How Long Does an OT Cybersecurity Audit Take?

      The duration depends on the size of the organisation, the number of sites, and the complexity of the industrial infrastructure.
      For a single production facility, the audit may involve several days to several weeks of analytical and on-site work. The detailed scope is agreed during project planning.

      How Should an Organisation Prepare for a uKSC Audit?

      Preparation should begin with a review of the OT infrastructure, identification of key assets, and an initial risk assessment. It is also helpful to:

      • Organise documentation.
      • Conduct an asset inventory.
      • Analyse suppliers.
      • Assess security procedures.
      • Implement fundamental OT protection measures.

      A professional OT audit enables gaps to be identified before the mandatory inspection.

      Does NIS2 Also Cover Suppliers and Subcontractors?

      Yes.
      The NIS2 Directive and the KSC Act place particular emphasis on supply-chain security. Organisations must identify suppliers that affect the security of systems and services and manage the associated risk appropriately. This also applies to companies servicing OT systems and providing remote access to infrastructure.

      Why Conduct an OT Audit Before the NIS2 Deadlines?

      Implementing NIS2 and KSC requirements takes time, involves multiple departments, and often requires modernisation of existing infrastructure. An early OT cybersecurity audit enables an organisation to:

      • Spread activities over time.
      • Control implementation costs.
      • Minimise incident risk.
      • Prepare for mandatory inspections.
      • Achieve NIS2 compliance in industrial environments without acting under deadline pressure.

      Does NIS2 Apply to Manufacturing Plants?

      Yes, many manufacturing plants may fall within the scope of the NIS2 Directive and the Polish National Cybersecurity System Act (uKSC). Applicability depends on the sector, company size, and the importance of the services provided to the economy and society. Particular relevance applies to organisations operating in sectors classified as essential or important, including the manufacture of critical products, energy, water and wastewater management, transport, and the chemical industry.
      For industrial facilities, this means implementing appropriate cybersecurity risk-management measures, protecting OT systems, and preparing to meet NIS2 and uKSC requirements. In practice, the first step is usually a NIS2-aligned OT cybersecurity audit that assesses the organisation’s level of preparedness for the new obligations.

      Who Is Responsible for OT Cybersecurity in an Organisation?

      Under NIS2 requirements, responsibility for cybersecurity is not limited to IT or automation departments.

      The organisation’s leadership and persons performing management functions are responsible for ensuring an appropriate level of cybersecurity. In practice, OT security activities most commonly involve:

      • The management board and organisational leadership.
      • Production directors.
      • Maintenance managers.
      • OT and automation teams.
      • IT teams.
      • Cybersecurity specialists.
      • Persons responsible for regulatory compliance.

      The NIS2 Directive emphasises management involvement in cybersecurity risk management rather than limiting these activities to technical teams.

      Are SOC and iSOC Required by NIS2?

      The NIS2 Directive does not explicitly require the implementation of a Security Operations Center (SOC) or an Industrial Security Operations Center (iSOC).

      However, NIS2 requires appropriate measures for detecting, monitoring, and responding to cybersecurity incidents.

      In industrial environments, SOC or iSOC solutions are among the most effective ways to support these requirements by enabling:

      • Continuous OT cybersecurity monitoring.
      • Real-time threat detection.
      • Incident analysis.
      • Event correlation.
      • Support for incident-reporting processes.

      For this reason, an OT cybersecurity audit often assesses the need to implement industrial security monitoring as part of NIS2 and uKSC compliance.

      Is OT Network Segmentation Required by NIS2?

      NIS2 does not prescribe specific technologies. However, network segmentation is recognised as a fundamental OT cybersecurity good practice.

      Industrial security audits frequently identify cases in which IT and OT environments are not properly separated or communications between them are not adequately controlled. Industrial network segmentation helps to:

      • Limit the spread of threats.
      • Reduce the attack surface.
      • Increase the security of SCADA and PLC systems.
      • Improve the resilience of critical infrastructure.
      • Meet requirements arising from IEC 62443.

      Network segmentation is therefore one of the actions most commonly recommended following an OT cybersecurity audit.

      How Often Should an OT Cybersecurity Risk Assessment Be Conducted?

      An OT cybersecurity risk assessment should be a continuous process rather than a one-off activity performed solely for an audit. Good practice is to conduct a full risk assessment:

      • After significant infrastructure changes.
      • After the deployment of new technological systems.
      • After a security incident.
      • Following organisational changes.
      • Periodically as part of the security management system.

      Regular risk assessment enables faster identification of emerging threats and helps maintain alignment with NIS2, uKSC, and IEC 62443.

      During an OT infrastructure audit, risk analysis is one of the most important elements used to assess the status of an organisation’s cybersecurity.

      Are Suppliers Maintaining OT Systems Subject to NIS2 Requirements?

      Yes, either indirectly or directly.

      Supply-chain security is one of the key areas addressed by NIS2. The Directive requires organisations to assess the risks associated with technology suppliers, service providers, and subcontractors that have access to IT and OT systems.

      Particular attention should be paid to companies responsible for:

      • SCADA system maintenance.
      • PLC servicing.
      • Remote technical support.
      • Automation-system integration.
      • Network-infrastructure maintenance.
      • Security monitoring.
      • Cloud services used in industrial environments.

      Suppliers with remote access to OT infrastructure often represent a significant cybersecurity risk vector. For this reason, an OT cybersecurity audit assesses not only the organisation’s safeguards, but also how relationships with suppliers and subcontractors are managed.

      Good practice includes introducing security requirements into contracts, controlling supplier access to industrial systems, and regularly assessing supply-chain risk.

      This area is particularly emphasised by both NIS2 and the amended KSC Act.

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