In terms of prevention, the most important solution is to provide secure standards for setting up Smart Grids. Such standards are lacking now. Almost every party takes a different approach to cyber security, and this results in series of vulnerabilities. We advocate cooperation among the major market players – encouraged by the government – to develop such a secure standard and be mandatorily adopted by the entire industry.
Importantly, this involves an “ecosystem” of stakeholders in the energy chain. The standards should not only apply to the grid operators; the complexity in this playing field is too great and the security issue will not be solved by simply demanding more from the grid operators. In addition, it has become clear in recent years that the energy transition has required and will continue to require substantial financial investments from grid operators. It is time for the security burden to be borne by more shoulders.
In line with this, a second important solution to the cyber risks of Smart Grids is a greater guiding role of the government. The current European directive (the NIS Directive) for the security of critical infrastructure is implemented in the Netherlands with the Wbni (Wet beveiliging netwerk- en informatiesystemen, Security of Network and Information Systems Act). However, compliance is lacking and not adequately monitored. Many organizations view such laws and regulations from a compliance perspective: doing it because they have to and not from an intrinsic motivation. As long as the “stick” is insufficiently used, the need to do something is moderate. To date, supervision is still limited, partly because it is organized by sector and because supervisors are dealing with scarce capacity to conduct audits and supervision.
Given the importance of Smart Grids for our green future, this is an undesirable situation: tighter government direction is needed. An additional advantage is the recently issued successor to the NIS Directive: the NIS2.
The NIS Directive (NIS stands for: Network & Information Systems) is European legislation aimed at increasing the cyber security and resilience of critical systems in Europe. It is up to the European member states to translate the Directive into national legislation. In the Netherlands, the Wbni was established, with supervision assigned to the Dutch Authority for Digital Infrastructure (Rijksinspectie Digitale Infrastructuur, RDI), formerly known as the Agentschap Telecom. The NIS2 Directive is the successor to the NIS Directive and came into force in early 2023. The elaboration of NIS2 for the Netherlands will take effect later in 2023; the deadline for member states is October 2024. Organizations covered by these regulations must comply with the requirements by January 2025 at the latest. The energy sector in a broad sense has already been designated as a “critical infrastructure” under the NIS Directive. This will be further extended with NIS2 towards the underlying ecosystem.
Although the content and approach are largely similar to that of the current NIS Directive, it is to be expected that NIS2 will be less non-binding and more “prescriptive” on a technical level. Fines associated with increased enforcement, at least on paper, are not negligible. They can be as much as 10 million euros or 2 percent of global turnover. The fact that the energy sector is considered “critical” from a regulatory perspective should come as no surprise. After all, without energy supply, a lot of essential services in a country will come to an immediate halt.
It is expected that the supporting and supplying companies of the energy sector also have to deal with the NIS2 requirements to a greater extent. It will take some time to establish enforcement in the Netherlands and gather the necessary experience and capacity.
A third preventive measure to prevent attacks on (future) Smart Grids is to certify the network devices consumers use. Having a sound and uniform certification system in place will assure consumers that there is no malware in the equipment and that it cannot be exploited from the outside.