| Abstract: |
Many Italian Public Administrations are simultaneously bound by the Network and Information Security Directive (NIS2) and by a national Regulation on cloud services issued by the Italian National Cybersecurity Agency (Agenzia per la Cybersicurezza Nazionale, ACN), which risks duplicating compliance effort across separate auditing workflows. The ACN Regulation, like other important EU legislations (e.g., GDPR), presents significant challenges for organisations: its length, complexity, and high-level legal language make it difficult to understand and manage how to comply with its obligations. Furthermore, it prescribes neither a verification methodology nor supporting tools, and its connection with NIS2, which it invokes, is left implicit. We propose a methodology that transforms these obligations into verifiable requirements and, in doing so, makes explicit their correspondence with the NIS2 risk management measures, covering 9 of the 10 measures. Our main finding is that 42 of the 47 test cases we derive are automatable, meaning that tools can support their verification, though for 34 of them the final evaluation against the adopted policies still requires human judgement; only 5 test cases depend entirely on documentary or organisational evidence. |