Essential and important entities designate the persons responsible for network and information system security within 30 days of being notified of the DNSC director’s decision. At larger essential entities, the person must have managerial authority, report directly to management and operate independently of IT. Responsibility for the measures stays with management, whoever holds the role.

What the law says

Article 14 of OUG 155/2024 places cybersecurity with management. The management bodies approve the risk management measures, supervise their implementation and are liable for breaches. They also attend accredited training courses and ensure staff are trained.

The same article requires them to set up permanent contact channels, allocate the necessary resources and designate the persons responsible for network and information system security. The deadline is 30 days from notification of the DNSC director’s decision registering the entity as essential or important.

For essential entities other than public administration, micro and small enterprises, art. 14 para. (4) adds cumulative conditions for the designated person:

For important entities and for small essential entities, the designation obligation remains, without these conditions.

Who can be the NIS2 security officer

An employee with authority
The natural option where a security director or risk manager with authority and budget already exists. The independence-from-IT condition means that, at large essential entities, the head of IT cannot combine the role: they would supervise their own measures.
An external consultant, by mandate
The law uses the verb “designate” and does not tie the role to an employment contract. An external officer meets the conditions through the appointment decision and a written mandate: direct reporting to management, access to systems and documents, the authority to require measures from suppliers. Responsibility stays with management.
What does not work
A name on a form, without time, access or authority. During audits and inspections, DNSC looks for evidence that the role is exercised: assessments, plans, reports, decisions.

In-house or outsourced

The real question is who has the time and the competence, not where they are employed.

Outsourcing makes sense at important entities and at essential entities below the threshold of the art. 14 para. (4) conditions, where no in-house specialist exists, and at large ones as a transition until they recruit.

What the NIS2 security officer does, month by month

How TRU helps

Through CIO-as-a-Service we take on the role of outsourced NIS2 security officer: the appointment decision and written mandate, the risk level assessment, the self-assessment, the remediation plan, the policies and the coordination of suppliers. We report directly to management.

The audit stays separate: it is performed by DNSC-certified auditors, TRU partners, under a direct contract. For the technical measures you have, when needed, PenTest, SOC 24/7/365 and Proton Business.

The cost depends on the risk level and on how much of the role we take over. We set it after a 30-minute conversation.

Sources

OUG 155/2024, consolidated text (in Romanian), art. 14 and 60, approved with amendments by Law no. 124/2025 (Official Gazette no. 638 of 7 July 2025) · DNSC: legislation · DNSC Order no. 1/2026.