Security awareness training: building and measuring a programme
Train the board, raise every employee's awareness, measure what actually changes: how to build a security awareness programme that meets NIS 2 and DORA.
Security awareness training covers the actions that teach everyone in the organisation to recognise digital risks and adopt the right reflexes: spotting phishing, protecting their accounts, reporting an incident. Long treated as a yearly formality, it has become an obligation: NIS 2 requires training for management, and DORA makes awareness compulsory for all staff of financial entities. The challenge is to build a programme that genuinely changes behaviour, and to prove it.
Security awareness: definition and stakes
There are usually three levels: awareness, aimed at everyone and focused on reflexes; training, more in-depth, for people with a particular role (administrators, developers, procurement, security champions); and practice, through exercises and simulations. A complete programme combines all three.
The goal is not to turn every employee into an expert, but to reduce the mistakes that let attackers in and, above all, to get fast reports. A phishing message reported within minutes lets you block the sender and warn other recipients before they click. That is the best return a programme can deliver, and the idea behind the human firewall.
What NIS 2, DORA and other rules require
| Text | Requirement | Who |
|---|---|---|
| NIS 2, Article 20(2) | Members of management bodies follow training to identify risks and assess risk management practices; Member States encourage similar regular training for staff. | Essential and important entities |
| NIS 2, Article 21(2)(g) | Basic cyber hygiene practices and cybersecurity training, among the minimum risk management measures. | Essential and important entities |
| DORA, Article 13(6) | ICT security awareness programmes and digital operational resilience training, compulsory for all staff and senior management, at a level matching their functions; ICT providers may be included. | Financial entities |
| DORA, Article 5 | The management body keeps its knowledge up to date through regular training and allocates the budget for awareness and training programmes. | Financial entities |
| GDPR, Article 39 | The data protection officer raises awareness and trains staff involved in processing. | Organisations with a DPO |
| ISO 27001 | Clause 7.3 on awareness and Annex A control 6.3 on awareness, education and training. | Certified organisations |
Recital 89 of NIS 2 sets out the spirit: entities should adopt a wide range of cyber hygiene practices, including user awareness, and organise training for their staff. In France, the transposition law had not yet been passed in early October 2026, but these requirements are in the directive itself.
For artificial intelligence, the AI Act adds an AI literacy obligation for staff using these systems, covered in our article on deployer obligations.
Building an awareness programme in six steps
- Start from the risks. Your risk analysis shows which scenarios involve a human action: phishing leading to stolen credentials, CEO fraud or fake bank detail changes, reused passwords, a lost laptop, data handed to an unapproved tool (shadow IT and shadow AI). The programme targets these scenarios first.
- Distinguish audiences. Management (training required by NIS 2 and DORA, focused on decisions and crisis management); all staff (basic reflexes); exposed roles: finance and payments, HR, executive assistants, administrators, developers; newcomers; contractors who access your systems.
- Choose short, regular formats. A few minutes a month stick better than an hour a year. Alternate online modules, small-group workshops, targeted messages after a real incident, crisis exercises for management (see our article on the business continuity plan) and phishing simulations.
- Make reporting easy. A button in the mail client or a single address, a quick reply and a thank-you every time, including for false alarms.
- Link it to the rules. Awareness explains the rules of the acceptable use policy and the security policy; it does not replace them. The CISO leads, HR builds the programme into onboarding and the training plan.
- Plan, budget, document. A yearly calendar, a budget (which DORA explicitly asks management to provide) and evidence kept on file: programmes, attendance lists, results, corrective actions. That is what an auditor or regulator will ask for.
Free public resources (France)
- The Cybermalveillance.gouv.fr awareness kit. The kit from France's national victim support service covers everyday topics: passwords, social network, mobile device and work-personal use security, backups, updates, phishing, ransomware, fake tech support. It comes in several formats (fact sheets, memos, videos, quizzes, comic strip, poster, infographics) and is published under an open licence: you can reuse and adapt it, crediting the source. It is in French.
- ANSSI's SecNumacadémie online course. The agency's free course is being redesigned in 2026, with paths by level and a certificate for each completed path. Meanwhile, existing content remains available on request in a format that can be imported into your organisation's learning platform.
- Cybermois. Every October, as France's version of European Cybersecurity Month, Cybermalveillance.gouv.fr provides resources to organise an internal event. It is a good anchor for a yearly highlight.
Measuring awareness effectiveness
The revision of NIST SP 800-50, published in September 2024, gives measuring the impact of learning programmes an important place and proposes a continuous improvement life cycle. In practice, track three families of indicators:
| Family | Indicators | What they show |
|---|---|---|
| Coverage | Participation by audience, share of managers trained this year, time to train newcomers | That the programme reaches everyone; direct evidence for NIS 2 and DORA |
| Behaviour | Reporting rate for suspicious messages, real or simulated; time between receipt and first report; share of relevant reports | That reflexes are taking hold; the most useful day-to-day indicator |
| Outcome | Incidents caused by human error, compromised accounts, fraud attempts stopped | That risk is actually going down |
| Culture | Short surveys, questions from staff to the security team | That security is seen as help rather than punishment |
Present these indicators to management as trends, in the security dashboard, rather than as a single percentage. In an ISMS, they feed monitoring and the management review.
Phishing simulations: useful if done right
Fake phishing campaigns are the most widespread tool, and the most debated. In a blog post, “The trouble with phishing” (2018), the UK National Cyber Security Centre (NCSC) warns that you can get any result you want by adjusting how hard the messages are, which makes the click rate a poor objective measure, and that a culture of fear pushes staff to hide mistakes rather than report them. A few rules follow:
- announce that simulations happen, without announcing the dates;
- never punish a click, but explain straight away what should have raised suspicion;
- measure reporting and its speed first, the click rate second, taking difficulty into account;
- avoid lures that exploit sensitive topics for staff (bonuses, health, redundancies) and damage trust;
- treat campaign data as personal data: inform staff, record the processing, involve the DPO;
- combine with technical measures (filtering, multi-factor authentication): awareness reduces human error, it does not eliminate it.
To track these measures alongside the other NIS 2 or DORA requirements and keep the evidence, Phinasoft's compliance campaigns module assesses each entity or site against the same list of requirements.
Summary
An obligation, not just good practice
NIS 2 requires training for members of management bodies and lists training among the Article 21 measures; DORA makes awareness compulsory for all staff and senior management.
A programme for each audience
Start from the risks, distinguish management, staff and exposed roles, favour short and regular formats, and use free public resources.
Measure behaviour
Beyond participation, track reports and how quickly they come in. A click rate on its own can be gamed; a culture where people report without fear has to be built.
Frequently asked questions
What is security awareness training?
It covers all actions that make employees aware of digital risks and the right reflexes: spotting a phishing message, protecting passwords, reporting an incident, following the acceptable use policy. It differs from in-depth training for people with a specific security role.
Is security awareness training mandatory?
For entities covered by NIS 2, members of management bodies must follow training (Article 20) and cybersecurity training is one of the minimum measures in Article 21. For financial entities, DORA makes awareness programmes and training compulsory for all staff and senior management (Article 13(6)). ISO 27001 also requires it from certified organisations.
What does NIS 2 say about management training?
Article 20(2) requires members of the management bodies of essential and important entities to follow training so that they gain sufficient knowledge and skills to identify risks and assess risk management practices. Member States must also encourage entities to offer similar training to their employees on a regular basis.
What does DORA say about awareness?
Article 13(6) requires financial entities to run ICT security awareness programmes and digital operational resilience training, compulsory for all employees and senior management, at a level matching their functions. Article 5 requires the management body to keep its knowledge up to date through regular training and to budget for these programmes.
How do you measure awareness effectiveness?
With coverage indicators (participation by audience, share of managers trained), behaviour indicators (rate and speed of reporting suspicious messages, real or simulated) and outcome indicators (incidents caused by human error). The click rate on a simulation must be read with care, as it depends mostly on how hard the test message is.
Are there free resources for staff awareness?
Yes, especially in France. Cybermalveillance.gouv.fr offers a free awareness kit, reusable under an open licence, with fact sheets, videos, quizzes and posters. ANSSI offers the SecNumacadémie online course, being redesigned in 2026, whose content remains available on request for organisations' learning platforms.
Sources (8)
- Directive (UE) 2022/2555 (NIS 2) — considérant 89, articles 20 et 21
- Règlement (UE) 2022/2554 (DORA) — articles 5 et 13
- Règlement (UE) 2016/679 (RGPD) — article 39
- Cybermalveillance.gouv.fr — Kit de sensibilisation
- Cybermalveillance.gouv.fr — Cybermois : ressources pour créer votre événement pour les professionnels
- ANSSI — Le MOOC SecNumacadémie en cours d'évolution
- NIST — SP 800-50 Rev. 1, Building a Cybersecurity and Privacy Learning Program, septembre 2024
- NCSC (Royaume-Uni) — The trouble with phishing, 2018
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