With the second half of 2026 now on the horizon, EU national competent authorities are gearing up to actively examine NIS2 compliance documentation from essential and important entities. The directive's Article 20(1) is a particular point of concern: it explicitly holds senior management personally liable for infringements. That means executives cannot simply delegate compliance and walk away—they carry individual risk if documentation falls short.

Passwork, a password management vendor, has published an efficiency guide aimed at helping organizations streamline their NIS2 preparation. The guide focuses on saving teams hours of work before the audit window opens, presumably by tightening internal processes around access control, logging, and evidence collection. The source does not provide specific techniques, but the emphasis is on reducing the administrative burden while meeting the directive's requirements.

The timing is deliberate: with audits starting in late 2026, the guide targets organizations that still have time to adjust their practices. The source does not mention any other vendors or alternative approaches, so there is no comparison to make. The key takeaway is that personal liability under Article 20(1) raises the stakes, making proactive preparation not just a compliance exercise but a personal risk-management issue for senior leaders.