Article 13 of OUG 155/2024 lists ten areas of measures that essential and important entities must cover, and for four of them it explicitly requires policies and procedures. The management bodies approve them (art. 14). At the audit, the DNSC-certified auditor checks each document and the evidence that it is applied. The self-assessment methodology in DNSC Order 1/2026 scores documentation and implementation separately.

The ten areas of art. 13 and their documents

The exact number of controls depends on your assurance level: 34, 133 or 218, by risk level. The list above covers the areas; the controls say how deep you go into each.

What the auditor checks on each document

Frequent mistakes

Copied policies
A set of downloaded documents, with another company’s name left in a header. The auditor recognises them from the first page.
Policies without evidence
The backup policy exists, the restore test was never done. In the self-assessment, implementation scores zero.
An outdated asset inventory
The server decommissioned last year is still in the inventory, the new one is not. DNSC can request the list at any time.
An incident procedure without deadlines
It does not say who notifies DNSC and within what time. The first DNSC fine was precisely for a notification deadline.
Everything left to IT
Policies written and approved only by IT. The law places them with management.

The order to do them in

  1. The risk level assessment, to know how many controls you have to cover.
  2. The asset inventory and the risk list: without them, no policy has an object.
  3. The policies tied to liability and deadlines: security and risks (a), access and assets (f), incidents (g), continuity (h).
  4. The remaining areas: suppliers (d), vulnerabilities (e), cryptography (c), authentication (j), training (i), assessing effectiveness (b).
  5. The evidence, collected as you apply them: reports, logs, minutes.
  6. The self-assessment, then the remediation plan, then the audit.

How TRU helps

Through CIO-as-a-Service, from €100 per hour, we write the policies and procedures with you, on the structure above, take them to management for approval and prepare the audit file. The technical evidence comes from PenTest, SOC 24/7/365 and Proton Business. The audit is performed by DNSC-certified auditors, TRU partners, under a direct contract.

Sources

OUG 155/2024, consolidated text (in Romanian), art. 11, 13 and 14 · DNSC Order no. 1/2026, the measures and the self-assessment methodology.