A Romanian NIS2 responsible person is not simply an IT administrator with a new title. The role connects management decisions, cyber-risk controls, incident handling, evidence, and communication with the National Cyber Security Directorate (DNSC). Its purpose is to make sure the organisation can demonstrate that security measures exist, work in practice, and improve when risks change.
Romania implemented the NIS2 framework through Emergency Ordinance no. 155/2024, subsequently approved with amendments by Law no. 124/2025. The law matters, but it does not turn every Romanian company into an essential or important entity. Scope depends on factors such as sector, service, size, and the statutory criteria. Classification should therefore be documented before a job description or training certificate is treated as proof of compliance.
The Role in One Sentence
The responsible person implements and supervises the organisation’s cyber-risk measures while giving its governing body enough reliable information to approve resources, oversee compliance, and make incident decisions.
Management remains accountable. It cannot delegate legal responsibility by appointing one employee and then withholding budget, access, or authority. The responsible person coordinates the work; system owners, IT and OT teams, legal staff, procurement, HR, data-protection personnel, and incident responders still perform their respective duties.
Where the Position Should Sit
For essential entities subject to the stricter statutory conditions, with the exceptions provided by law, the designated person must have meaningful managerial authority, report directly to the governing body, remain independent from the IT/OT function, and have access to the resources needed for the role. The legislation also provides for a DNSC-recognised accredited specialist course within 12 months of designation in the cases covered by that requirement.
That structure prevents a common conflict: the same operational team should not be the only party judging whether its own controls are adequate. Independence does not mean isolation. The responsible person needs daily cooperation with IT and OT, but must be able to escalate an unacceptable risk without having that conclusion filtered by the department that owns it.
An internal appointment should define at least:
- direct reporting line and a named management sponsor;
- systems, services, locations, and subsidiaries in scope;
- access to risk, asset, log, contract, and incident information;
- authority to convene an incident team and request remediation;
- an alternate contact for absence and an on-call mechanism;
- budget, training, and specialist support;
- rules for conflicts of interest and independent assurance.
What the Responsible Person Does
Build a defensible view of risk
The work starts with knowing what the organisation actually operates. A usable asset and service register links business owners, technology, suppliers, data, dependencies, recovery targets, and criticality. From it, the responsible person maintains a risk register with likelihood, impact, treatment, owner, deadline, and residual risk.
This is not an annual spreadsheet ritual. New suppliers, cloud migrations, exposed services, mergers, vulnerabilities, and changes to essential processes must feed back into the risk assessment.
Coordinate security measures
The Romanian framework requires appropriate and proportionate technical, operational, and organisational measures. In practice, the responsible person coordinates policies and evidence for areas such as:
- incident handling and crisis communication;
- business continuity, backup, disaster recovery, and restore testing;
- supply-chain and service-provider security;
- vulnerability disclosure, patching, and secure change management;
- access control, privileged access, authentication, and asset management;
- cryptography and secure communications;
- monitoring, logging, testing, and evaluation of control effectiveness;
- staff awareness and management training.
The role should set outcomes and verification methods, not prescribe technology without context. A backup policy is not effective because a document exists; it is effective when protected copies can be restored within the agreed recovery objective.
Prepare incident reporting before an incident
Significant incidents can create a rapid reporting clock. The framework includes an early warning within 24 hours, an incident notification within 72 hours, and a final report generally within one month. An intermediate progress report may also be requested, and specific cross-border information obligations can apply.
These deadlines cannot be met by inventing a process during an outage. The responsible person should maintain a reporting decision tree, severity criteria, permanent contact details, approved templates, evidence-preservation rules, and an escalation list. The incident team must know who can authorise a notification when senior managers are unavailable.
The first notification is not expected to contain a completed forensic investigation. It should communicate what is known, what remains uncertain, likely impact, indicators where available, and immediate containment. Later reports can refine the analysis without hiding uncertainty in the first one.
Maintain the DNSC relationship
Where the entity is in scope, the responsible person coordinates registration and updates through the applicable DNSC mechanisms, including the permanent means of contact. Romanian requirements adopted in 2025 describe the notification information and use of the NIS2@RO instrument; they should be read together with the primary legislation and current DNSC instructions.
The internal evidence file should preserve submissions, acknowledgements, material changes, contact tests, management approvals, and the reasoning behind classification decisions.
Report to management in business terms
A useful management report does not list thousands of scanner findings. It shows the services at risk, likely business impact, overdue treatments, incident trends, supplier exposure, restore-test results, and decisions required. It also records risks that management formally accepts.
Recommended measures include percentage of critical assets with an owner, remediation compliance by severity, privileged accounts reviewed, successful restore tests, mean incident-detection and containment time, overdue supplier assessments, and completion of role-based training. A metric should drive a decision, not merely decorate a dashboard.
A Practical Job Description
A job description can group the position’s recurring deliverables as follows:
| Area | Minimum operational deliverable |
|---|---|
| Scope and assets | Current service and asset register with owners and criticality |
| Risk | Risk register, treatment plan, accepted-risk record, and review calendar |
| Governance | Approved policies, responsibility matrix, budget requests, and management minutes |
| Incidents | Response plan, reporting decision tree, contact roster, templates, and exercise reports |
| Continuity | Business impact analysis, recovery targets, protected backups, and restore evidence |
| Suppliers | Critical-supplier register, security clauses, assessments, and remediation tracking |
| Vulnerabilities | Intake, prioritisation, patch exceptions, deadlines, and verification evidence |
| Access | Joiner-mover-leaver controls, privileged-access reviews, MFA coverage, and exceptions |
| Awareness | Annual plan, role-based training, attendance, exercises, and lessons learned |
| Assurance | Control tests, audit evidence, findings register, and closure validation |
The document should also define quarterly and annual review cycles, incident availability, confidentiality, performance indicators, and the substitute who acts during leave. It should not promise powers that employment rules or management have not actually granted.
What a Course and Exam Can—and Cannot—Prove
A serious course should cover the legal framework, entity classification, governance, risk management, minimum controls, supply-chain risk, incident response and reporting, continuity, audits, and practical documentation. Assessment may combine multiple-choice legal questions with scenarios, risk exercises, or a small implementation project. The exact syllabus and exam format belong to the training provider and must be checked in its current course documentation.
Before enrolling, verify who accredits or recognises the programme, which occupation or competency appears on the certificate, whether DNSC recognition applies to the legal requirement relevant to your appointment, how assessment works, and whether the provider teaches the latest consolidated Romanian rules.
A certificate does not decide that an employer falls under NIS2, replace the management appointment, guarantee DNSC acceptance in every context, or prove that security controls work. Training is one competency input; compliance remains an organisational programme.
A Safe First 90 Days
During the first month, confirm scope, appointment, reporting line, permanent contacts, critical services, and existing evidence. In the second, create the risk and remediation baseline, validate incident reporting, and test one critical restore path. In the third, present a prioritised management plan, start supplier reviews, run a tabletop incident exercise, and establish the assurance calendar.
The best outcome is not a large policy library. It is a short chain of accountability: each important service has an owner, each material risk has a decision, each control has evidence, and an incident can reach the right people before the reporting clock expires.
Because entity classification and legal duties depend on current facts, organisations should confirm their position against the consolidated legislation, DNSC instructions, and qualified Romanian legal advice. The responsible person can lead that work, but should not turn an uncertain classification into a confident declaration without evidence.
