customer asks for pentest results but we have never done a pentest
No pentest done is not an automatic no
A pentest — a penetration test, where someone actively tries to break into your systems to find weak spots — is one possible test of effectiveness, but not the only one. Article 21(2) of NIS2 asks for "policies and procedures to assess the effectiveness of measures", without prescribing a pentest. Annex A of ISO/IEC 27001 also mentions technical vulnerability management and testing, but does not mandate a specific test method. You can often honestly fill in "no, not yet" without this being a blocking answer — it is one of the ten measures, not the only one.
What does count as alternative evidence: automated vulnerability scans, a patch process, or a risk analysis showing that a pentest was not yet deemed necessary given the scope of your systems. Check with the process for identifying and remediating vulnerabilities whether you already have something running there — often you do, even if it is not called a "pentest". If your file does not have that supporting document, the system will not suggest a "yes": you will then get a question with an empty answer, and you decide yourself whether to fill in "no" or first run a scan. Some customers accept a commitment ("scheduled for Q-whatever") as an interim answer; you only know that after submitting to their portal.
What this is based on: Article 21(2) and Annex A
The obligation to conduct periodic testing derives from Article 21(2) of Directive (EU) 2022/2555, which names "policies and procedures for assessing the effectiveness of cybersecurity risk management measures" as one of the ten measures, alongside — not in place of — vulnerability management. ISO/IEC 27001 Annex A elaborates on this in control measures around technical vulnerabilities and assessment, without naming a pentest as a mandatory instrument. Whether your organisation falls directly under the NIS2 obligations depends on sector and size — you determine that separately from this question, for example via whether the undertaking itself falls under NIS2.
What this is based on
- Directive (EU) 2022/2555 (NIS2), Article 21(2) — the ten measures
- ISO/IEC 27001 — Annex A, the control measures
- Cybersecurity Act — the Dutch transposition of NIS2, entering into force 15 August 2026
The regulation itself is on EUR-Lex. We refer for each claim; you do not have to take our word for it.
What you concretely need to do
The implementation of each obligation, with the deadlines involved and the templates for recording it, is included in the subscription.
View the subscription First the free quick-scanThis is not legal advice. This page provides general information on the regulations this platform covers. We do not know your situation. If in doubt about your own case, consult a lawyer or the competent supervisory authority.
Written with AI based on the sources above, checked by a human on 2026-09-05. Is something incorrect? Let us know — corrections receive priority.