DORA and NIS2 Compliance in Microsoft 365: A Guide to Continuous Cyber Resilience

The regulatory landscape for cyber security is evolving at an unprecedented pace, placing significant pressure on mid-sized and large enterprise companies to not only meet but continuously maintain a high level of digital operational resilience. For organisations heavily reliant on Microsoft 365 environments, this presents a unique challenge. With the Digital Operational Resilience Act (DORA) for financial services, the NIS2 Directive for critical infrastructure in the EU, and the forthcoming UK Cyber Security & Resilience Bill, the days of periodic, checklist-based compliance are firmly behind us. The new era demands continuous monitoring, active risk reduction, and demonstrable resilience.

At Elasticito, we understand these challenges. We work with cyber risk and Information Security teams to help them better monitor and reduce their attack surface risk within Microsoft 365. We leverage cutting-edge tools, such as Overe, to assess, harden, monitor, and respond to threats, ensuring our clients can efficiently and effectively reduce their Microsoft 365 attack surface risk and achieve the continuous compliance required by these demanding regulations.

DORA and NIS2 Compliance in Microsoft 365: A Guide to Continuous Cyber Resilience

The Imperative for Continuous Compliance

The core tenet of DORA, NIS2, and the proposed UK Cyber Security & Resilience Bill is a shift from static, point-in-time security assessments to dynamic, ongoing digital operational resilience. These regulations recognise that the threat landscape is constantly changing, and therefore, an organisation’s defences and compliance posture must adapt continuously.

Let’s delve into how these regulations specifically mandate continuous compliance and where tools like Overe become indispensable.

DORA: Digital Operational Resilience Act (for Financial Services)

DORA, particularly in Article 6, “ICT risk management requirements”, explicitly calls for a “sound, comprehensive and well-documented ICT risk management framework” that is “continuously improved on the basis of lessons derived from implementation and monitoring.” This article further requires financial entities to:

  • Minimise the impact of ICT risk by deploying appropriate strategies, policies, procedures, ICT protocols and tools. This directly speaks to the need for proactive security measures and automated hardening.
  • Identify sources of risk on a continuous basis, and also take into account the risk in relation to other financial undertakings. This necessitates continuous attack surface monitoring.
  • Continuously monitor ICT systems to ensure resilience, continuity, and availability, with high standards for availability, authenticity, integrity, and confidentiality of data. This implies ongoing assessment of configurations and user activities within platforms like Microsoft 365.
  • Implement measures for vulnerability management, including “automated vulnerability scanning on a regular basis” and processes for addressing and monitoring identified vulnerabilities.
  • Establish adequate and appropriate redundant ICT capacities and regularly test business continuity plans (BCPs) with realistic scenarios, including those involving third-party ICT services.

Elasticito, with Overe, directly addresses these requirements by providing continuous, automated assessment of Microsoft 365 environments. It can identify misconfigurations, excessive permissions, and other vulnerabilities that contribute to ICT risk, allowing for swift remediation. Its continuous monitoring capabilities ensure that any deviations from established security policies or best practices are immediately flagged, supporting the “continuously improved” mandate of DORA.

Furthermore, Article 25 of DORA states: “Financial entities shall manage ICT third-party risk as an integral component of ICT risk.” This underscores the importance of monitoring the security posture of cloud service providers like Microsoft and ensuring their configurations meet compliance standards, a key area where Overe provides visibility.

NIS2: Network and Information Security Directive 2 (for Critical Infrastructure)

The NIS2 Directive similarly elevates the bar for cyber security across a broader range of critical entities. Article 21, “Security requirements”, mandates that essential and important entities “take appropriate and proportionate technical, operational and organisational measures to manage the risks posed to the security of network and information systems.” These measures, which must be based on an all-hazards approach, include at least:

  • (a) policies on risk analysis and information system security; This implies a need for regular and up-to-date risk assessments of IT systems, including Microsoft 365.
  • (b) incident handling; Requires robust incident detection, analysis, and response mechanisms.
  • (e) security in network and information systems acquisition, development and maintenance, including vulnerability handling and disclosure; This includes ongoing vulnerability management for deployed systems.
  • (f) policies and procedures to assess the effectiveness of cybersecurity risk-management measures; This is a direct call for continuous validation of security controls.
  • (g) basic cyber hygiene practices and cybersecurity training; Relates to ensuring baseline security configurations are maintained.
  • (i) human resources security, access control policies and asset management; Requires strict control over access and management of digital assets.

Overe’s ability to automate security hardening and policy enforcement directly supports NIS2’s requirements for strong cyber hygiene and consistent application of security policies. Its continuous monitoring helps detect incidents and vulnerabilities in real-time, facilitating prompt incident handling and ensuring the effectiveness of cybersecurity risk-management measures are continuously assessed. By continuously monitoring access controls and asset configurations within Microsoft 365, Overe contributes significantly to meeting these Article 21 mandates.

The UK Cyber Security & Resilience Bill (Proposed)

While still in its drafting stages, the proposed UK Cyber Security & Resilience Bill is expected to align closely with the principles of NIS2 and DORA, strengthening the UK’s cyber defences and expanding the scope of existing regulations. Key themes emerging from the Bill include:

  • Wider Reach: Extending cyber security obligations to a broader range of organisations, including Managed Service Providers (MSPs), data centres, and vendors, recognising their role in the digital supply chain.
  • Faster Incident Reporting: Requiring businesses to report significant cyber incidents without delay, ensuring a more coordinated national response.
  • Closer Alignment with NIS2: Indicating a consistent approach to international cyber security standards, particularly regarding risk management and supply chain security.

The continuous compliance capabilities offered by Overe will be crucial for UK organisations navigating this new legislation. Its automated monitoring and hardening features provide the real-time visibility and control necessary to demonstrate robust security posture and rapid incident response, aligning with the expected stricter requirements of the UK Bill.

The Business Case for Automated Tools like Overe

Manually managing and configuring Microsoft 365 environments to achieve continuous compliance with DORA, NIS2, and the UK CSRA, while simultaneously reducing attack surface risk, is an incredibly arduous and often impossible task. Here’s why automated tools like Overe are not just beneficial, but essential:

1. Complexity and Scale of Microsoft 365:

  • Manual Burden: Microsoft 365 offers a vast array of services, settings, and configurations (e.g., Exchange Online, SharePoint Online, Teams, Azure AD, Intune). Manually reviewing and enforcing security best practices across thousands, or even hundreds of thousands, of settings and user accounts is prone to human error, time-consuming, and unsustainable.
  • Attack Surface: Each setting, each user, each application within Microsoft 365 can be a potential attack vector if misconfigured. The attack surface is dynamic and constantly expanding with new features, users, and integrations.
  • Overe’s Value: Overe automates the discovery, assessment, and hardening of these complex environments. It provides a centralised, real-time view of your Microsoft 365 security posture, identifying and remediating misconfigurations that manual audits often miss. This comprehensive security assessment capability saves countless hours and drastically reduces the likelihood of human error.

2. The “Continuous” Requirement:

  • Regulatory Demands: DORA, NIS2, and the UK CSRA all emphasise “continuous” monitoring, improvement, and risk management. A manual, annual, or even quarterly audit simply won’t cut it. The threat landscape evolves daily, if not hourly.
  • Reactive vs. Proactive: Manual processes are inherently reactive, focusing on remediation after a vulnerability is discovered or an incident occurs. Continuous compliance requires a proactive approach.
  • Overe’s Value: Overe provides 24/7 threat monitoring and automated response capabilities. It continuously scans for deviations from your security policies, new vulnerabilities, and suspicious activities. This allows for immediate detection and automated remediation, ensuring that your Microsoft 365 environment remains hardened and compliant at all times, not just during an audit.

3. Resource Optimisation and Cost Efficiency:

  • Skilled Shortage: Cybersecurity talent is scarce and expensive. Relying solely on manual processes places an unsustainable burden on already stretched InfoSec teams.
  • Opportunity Cost: Time spent on manual configuration and compliance checks is time not spent on strategic security initiatives, threat hunting, or innovation.
  • Overe’s Value: By automating discovery, hardening, monitoring, and response, Overe frees up valuable security resources. It allows your team to focus on higher-value tasks, significantly reducing operational costs associated with manual compliance efforts and incident response. The business case is clear: investing in automation like Overe is an investment in efficiency, accuracy, and reduced risk, ultimately leading to lower total cost of ownership for your cyber security programme. This efficiency also translates into better audit readiness, saving time and resources during regulatory inspections.

4. Demonstrable Evidence and Audit Readiness:

  • Burden of Proof: These regulations don’t just require compliance; they require demonstrable Organisations must be able to prove that they have implemented and are continuously maintaining appropriate security measures.
  • Manual Documentation: Generating comprehensive and up-to-date documentation of security controls and compliance status manually is a monumental task.
  • Overe’s Value: Overe provides detailed reports and logs that serve as concrete evidence of your continuous compliance efforts and attack surface reduction. This automated reporting simplifies audit preparation and provides regulators with the assurance that your organisation is meeting its obligations effectively.

In essence, while Microsoft provides a powerful platform, achieving the stringent continuous compliance requirements of DORA, NIS2, and the forthcoming UK Cyber Security & Resilience Bill within Microsoft 365 manually is an insurmountable challenge. Tools like Overe offer the automation, precision, and continuous visibility needed to effectively reduce your attack surface risk and confidently demonstrate ongoing compliance.

Elasticito will be hosting a webinar on this very topic, “Is Your Microsoft 365 DORA & NIS2 Ready? A Practical Guide to Compliance and Cyber Resilience”, on Wednesday 5th November 2025 at 11:00 CET. We invite you to join us to learn more about navigating these critical regulations and leveraging modern solutions to enhance your Microsoft 365 security posture.