---
title: NIS2 Cybersecurity Training Plan Guide
description: How to build an approvable NIS2 cybersecurity training plan (PR.AT-01). Practical guide covering awareness programs, role-based training, and competency tracking.
canonical: https://www.aegister.com/en/cms/insights/nis2-cybersecurity-training-plan-pr-at-01/
url: /en/cms/insights/nis2-cybersecurity-training-plan-pr-at-01/
lang: en
---

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# NIS2 cybersecurity training plan: practical guide for an approvable PR.AT-01 document

---

![NIS2 cybersecurity training plan: practical guide for an approvable PR.AT-01 document](/static/images/cms/nis2-requisiti-di-base.webp)

## NIS2 cybersecurity training plan: practical guide for an approvable PR.AT-01 document

February 03, 2026

[NIS2](/en/cms/keyword/nis2/)
[Appendix C](/en/cms/keyword/appendix-c/)
[board approval](/en/cms/keyword/board-approval/)
[ACN](/en/cms/keyword/acn/)
+5

Under the ACN baseline framework, the training plan is explicitly included among documents requiring approval by management and directive bodies (Appendix C, PR.AT-01 point 1).

Timeline-wise, incident notification obligations are already active from January 2026, while the baseline implementation horizon for many organizational measures remains October 2026. A structured training plan is therefore both an immediate risk control and a compliance requirement.

## Key takeaways

- The training plan is a governance-approved document, not only an HR calendar.
- PR.AT-01 and PR.AT-02 expectations require role-based cybersecurity capability building.
- Evidence (attendance, tests, exercises, remediation) is central to audit readiness.
- Training should be integrated with incident, risk, and policy governance cycles.

## Regulatory framing for training under NIS2

ACN guidance maps cybersecurity hygiene and training practices to baseline measures including PR.AT-01 and PR.AT-02. In operational terms, organizations should define mandatory training streams, role segmentation, recurrence, and measurable effectiveness.

A recurring gap is documenting course titles without proving behavioral and operational impact. Expected maturity includes traceable participation, role alignment, periodic refresh, and corrective actions when outcomes are weak.

## What an approvable training plan should contain

| Section | Why it matters for PR.AT-01 execution |
| --- | --- |
| Scope and training governance | Clarifies mandatory population and accountabilities |
| Role-based learning paths | Aligns content with technical and business risk exposure |
| Annual calendar and recurrence rules | Ensures continuity and minimum training cadence |
| Onboarding/offboarding training controls | Reduces early-stage human risk exposure |
| Test/simulation model | Measures effectiveness beyond attendance |
| Evidence and reporting structure | Supports auditability and management oversight |

## Practical structure from the Aegister template approach

### 1. Objective, scope, and references

Define training purpose, organizational perimeter, and baseline references.

### 2. Audience segmentation and role matrix

Group audiences by risk profile: executives, technical teams, operational staff, privileged users, suppliers.

### 3. Training catalogue and annual cycle

Set mandatory modules, refresh cadence, and trigger-based extraordinary sessions.

### 4. Delivery model and ownership

Define internal/external delivery, accountability between CISO and HR, and completion governance.

### 5. Effectiveness validation model

Use quizzes, simulations, incident trend correlation, and targeted remediation.

### 6. Evidence register and audit reporting

Track attendance, outcomes, remediation actions, and management reporting.

## Common training-plan quality gaps to avoid

- Generic training for all roles with no risk-based segmentation.
- Attendance tracked but no effectiveness validation.
- No linkage with incident trends and recurring weaknesses.
- Training plan disconnected from onboarding/offboarding flows.
- Evidence incomplete for audit and management review.

## 20-day hardening checklist

| Week | Priority actions |
| --- | --- |
| Week 1 | Validate role matrix and mandatory training population |
| Week 2 | Finalize annual catalogue, ownership, and evidence model |
| Week 3 | Run first validation cycle and close top capability gaps |

## FAQ

### Does the training plan require formal approval by management bodies?

Yes. Appendix C includes the training plan among documents requiring approval by management and directive bodies (PR.AT-01 point 1).

### Is attendance tracking enough for NIS2 training compliance?

No. Participation records are necessary, but organizations should also prove effectiveness through tests, simulations, and corrective actions.

### What is the minimum practical output expected from this plan?

A role-based annual training system with traceable evidence, effectiveness checks, and governance reporting.

## Conclusion and next steps

A NIS2 training plan should create measurable capability, not only complete mandatory sessions. Organizations that align role-based content, effectiveness metrics, and governance reporting early are better positioned for October 2026 readiness and for supporting live obligations already active.

## Related reading

- [NIS2 mandatory documents master guide: what must be approved by the board and what to prepare now](/en/cms/insights/nis2-mandatory-documents-master-guide-board-approval/)
- [NIS2 training and cyber-competency register: practical guide to auditable workforce evidence](/en/cms/insights/nis2-training-competency-register-workforce-evidence/)
- [NIS2 Protection Controls (PR): Technical and Organizational Measures in Execution](/en/cms/insights/nis2-protection-pr-technical-organizational-measures/)
- [Aegister NIS2 Compliance Service](/en/solutions/compliance/nis2/)
- [Aegister Virtual CISO Service](/en/solutions/virtual-ciso/)

## Official sources

- [ACN – Guida alla lettura delle specifiche di base](https://www.acn.gov.it/portale/documents/d/guest/guida-alla-lettura-specifiche-di-base)
- [ACN – Determinazione obblighi di base 379907/2025](https://www.acn.gov.it/portale/documents/d/guest/detacn_obblighi_2511-v3_signed)
- [ACN – Modalità e specifiche di base](https://www.acn.gov.it/portale/nis/modalita-specifiche-base)
- [Gazzetta Ufficiale – Decreto Legislativo 138/2024](https://www.gazzettaufficiale.it/eli/id/2024/10/01/24G00155/SG)

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