ITF Cyber

NCA ECC readiness, with the evidence behind it

A control-by-control position against ECC-2:2024, the governance documents it requires, and a remediation plan with an owner on every line.

Control set
ECC-2:2024, 4 domains and 28 subdomains
Controls
108 main controls and 92 subcontrols
ECC certificate
Does not exist, and nobody can issue one
How NCA checks
Self-assessment, the compliance tool, field audits
Coverage
Riyadh and the Eastern Province; documents read remotely

ECC-2:2024 is NCA's mandatory minimum control set: 4 domains, 28 subdomains, 108 main controls and 92 subcontrols. It binds government bodies, their affiliates and private entities that own, operate or host critical national infrastructure. There is no ECC certificate. Readiness means every applicable control is either evidenced or on a dated plan with an owner.

The 28 subdomains of NCA ECC-2:2024 drawn as one cell each, grouped into the four domains: Governance with 10, Defense with 15, Resilience with 1, and Third-Party and Cloud with 2. Subdomain 1-2, which holds the independence and Saudi staffing controls, is highlighted; subdomain 2-11, penetration testing, is dashed as evidenced by a commissioned test; subdomain 4-2 covers cloud and hosting. Below, each control in the register ends either evidenced, recorded in the evidence map, or partial or absent, ranked in the gap register and carried into a remediation plan with an owner and a date.NCA ECC-2:2024 · ONE CELL PER SUBDOMAIN3 RESILIENCE · 4 THIRD-PARTY AND CLOUD1 · GOVERNANCE · 10123456789102 · DEFENSE · 15123456789101112131415314121-2 · CYBERSECURITY MANAGEMENTCONTROLS 1-2-1 AND 1-2-2: A REPORTING LINE AND HIRING4-2 · CLOUD AND HOSTINGIF YOU USE OR PLAN CLOUD2-11 · PENETRATION TESTINGEVIDENCED BY A COMMISSIONED TESTWHERE EACH CONTROL IN THE REGISTER ENDS UPCONTROL REGISTEREVERY APPLICABLE CONTROLEVIDENCEDTHE RECORD CAN BE OPENEDPARTIAL OR ABSENTRANKED IN THE GAP REGISTEREVIDENCE MAPEACH RECORD AND WHERE IT IS KEPTREMEDIATION PLANAN OWNER AND A DATE ON EVERY LINEPARTIAL: THE THING WAS DONE, NOBODY COULD SHOW ITREADY: EVERY APPLICABLE CONTROL ENDS IN ONE OF THE TWO RIGHT-HAND BOXES
Twenty-eight subdomains, one rule for readyEach applicable control ends evidenced, or on the plan with an owner and a dateSwipe to pan
  1. 01 Call
  2. 02 Scope
  3. 03 Read
  4. 04 Register
  5. 05 Documents
  6. 06 Plan

NCA ECC readiness, with the evidence behind it sits at step 4 of how an engagement runs. You receive the register.

01

Two controls you cannot write your way out of

Control 1-2-1 requires a cybersecurity function independent of the IT department, preferably reporting to the head of the entity. Control 1-2-2 requires cybersecurity positions to be filled by full-time, qualified Saudi professionals.

Neither is closed by a procedure. Both mean a reporting line, a budget and hiring. In a mid-size entity where security has always been part of the IT manager's job, 1-2-1 is the one that causes the argument. We put both first in the plan, because they have the longest lead time and they decide who owns everything else.

Most of the other controls fail on evidence, not on practice. "Access reviews happen by email and are not recorded" is a partial, and the fix is a record rather than a product. The thing was being done. Nobody could show it.

02

Seven areas of work, each ending in a document

The third column is what your team keeps and maintains after the engagement.

AreaWhat we doWhat you hold
Control mappingEvery applicable control assessed as evidenced, partial or absent, with the evidence seen recorded against it.The control register
Governance documentsThe policies, standards and procedures the control set requires, drafted for your own approval route.The document set
Asset and data inventoryWhat you hold, where it sits, who owns it, and which controls apply to it.The inventory
Evidence structureHow each control produces a record a reviewer can open, and where that record is kept.The evidence map
Third-party and cloudYour contractual and documentary position with suppliers and hosting, read against domain 4.Supplier and cloud rows in the register
Penetration testing and vulnerability managementThe procedure these controls require, a scope for the test, and a comparison of providers you could contract.A test scope ready to send
RemediationGaps sequenced by risk and effort, an owner on each, written so your IT team or its suppliers can carry out the technical items.The remediation plan
03

The documents you hold at the end

01

The control register

Every applicable control with its state, the evidence seen and its owner, kept in NCA's own numbering. The working document, not the report.

02

The gap register

Only the gaps, ranked, with what closing each one requires. Short enough for a management meeting.

03

The governance document set

The policies, standards and procedures ECC requires, drafted for your approval route rather than lifted from a template pack.

04

The evidence map

For each control, the record that proves it and where that record is kept. This is what a reviewer opens.

05

The remediation plan

Gaps in order, an owner and a date on each, written so a different supplier could carry out the technical items.

06

A test scope

For the penetration testing controls: targets, exclusions and the testing window, ready to send to providers.

04

From the clause to the walk-through

The time from scope to walk-through is set at scoping. A group with shared services and no asset list takes longer, and the asset list is the part that takes the time.

  1. 01

    Scope

    Which legal entity, sites and systems, read against the obligation or the contract clause. The output is the scope statement.

  2. 02

    Collect

    Your existing policies, registers, contracts and screenshots, read before we ask a single question. The output is a document index.

  3. 03

    Interview

    Short sessions with the people who operate each control, because documents and practice rarely match.

  4. 04

    State each control

    Evidenced, partial or absent, with the evidence recorded. Partial is the most common state and the most useful, because it names what is missing.

  5. 05

    Write up the gaps

    Each one with the effort to close it, so the plan can be argued on cost rather than on principle.

  6. 06

    Draft the documents

    Governance documents for whatever is missing or unusable, written for your approval route.

  7. 07

    Walk it through

    A session with management, who decide the order of remediation. The output is the remediation plan.

05

When a customer's renewal depends on it

A services company in Riyadh is told by a government-affiliated customer that renewal depends on showing its position against ECC-2:2024.

Whether ECC binds the company directly is a question for its legal advisers, and we say so. The contract clause settles the practical scope: one legal entity, two offices, the ERP and email.

We read the existing policies, the cloud contracts and the asset spreadsheet before the first interview. The spreadsheet stops at laptops and misses the cloud accounts, so the inventory is rebuilt first. Interviews follow with the IT manager, HR and finance.

Most controls land as partial. Controls 1-2-1 and 1-2-2 land as absent, because security sits inside the IT manager's role, and the plan puts a decision on that to management first. The penetration testing controls cannot be evidenced without a test, so the plan includes a test scope and a provider comparison.

The company holds a control register, a gap register, a governance document set drafted for its own approval, an evidence map and a remediation plan its customer can read.

06

Who it binds, and who it reaches

The legal scope is narrow. The practical scope is much wider, and NCA encourages every other entity in the Kingdom to adopt the controls.

Government bodies and their affiliates

Ministries, authorities and other government bodies, and the companies and entities affiliated to them, inside and outside the Kingdom. For them ECC applies in full: every control relevant to the entity, not a selected subset.

07

Questions before an ECC assessment

Q01

Is there an ECC certificate?

No. ECC is not certifiable and no certification body issues one. NCA checks compliance through self-assessment, its compliance tool and field audits. An offer of ECC certification is a reason to ask what exactly you would receive.

Q02

Does ECC apply to us?

It binds government bodies, their affiliates and private owners, operators or hosts of critical national infrastructure. For everyone else it usually arrives through a contract. Whether it binds you legally is a question for your legal advisers; we work from whichever obligation you actually have.

Q03

Does ISO 27001 make us ECC compliant?

It gets you a long way, not all the way. ISO 27001 lets you justify excluding a control; ECC applies every control relevant to you. And 1-2-1 and 1-2-2 have no ISO equivalent.

Q04

Can you complete NCA's compliance tool for us?

The self-assessment belongs to your entity and is submitted by it. We prepare the evidence and the answers so the person submitting can stand behind every line.

Q05

Who runs the penetration testing ECC asks for?

A testing provider you contract. We write the scope, help you compare providers and work through the report with you, so each finding lands in the remediation plan with an owner.

Q06

What drives the cost?

The entities and sites in scope, how much documentation already exists, how many control owners must be interviewed, and whether suppliers and cloud services are included.

Start from the clause you were handed

Bring the contract clause or the regulator's letter to the first call. It settles which entity, sites and systems are in scope, and every document after it is built from that scope statement.

Book an ECC readiness call