Together with the All NEMO Committee, we welcome this opportunity to provide input on ACER’s draft Framework Guideline on electricity sector-specific rules for cybersecurity and see the value in ensuring a high standard of cybersecurity. However, in this response we would like to stress that the FG should complement existing cybersecurity requirements such as those in the proposed NIS 2 Directive and avoid unnecessary duplication. Furthermore, harmonisation across Member States will be critical to identify cross-border cybersecurity risks efficiently and ensure that communication obligations are well tailored as to avoid unduly increasing the workload of entities in scope.
Please find below selected responses to the consultation questionnaire.
