Honest disclosure

Reglyze is below the NIS2 SME threshold of Article 2(1).

We are voluntarily implementing Article 21 measures using Reglyze (the product) as both subject and tool. This is dogfooding, not regulatory obligation. We surface this page so you can verify what an AI-built NIS2 evidence base actually looks like before you buy.

Built on Reglyze

Our own NIS2 evidence base — in the open

Every policy, training record, supplier entry, and effectiveness KPI below was generated, scored, and reviewed inside Reglyze the product, by the founder of Reglyze the company, on the same plan our paying customers use.

We documented our entire NIS2 evidence base in under 1 hour.

Manual consultant estimate for comparison: 80–120 hours.

Wall-clock minutes from the dogfooding timing log (docs/research/self-compliance-timing.md). Includes AI generation, Cyril's editing, and the review packet. Excludes the 36-hour overnight gap between phases.

Manual baseline is the lower bound of typical EU NIS2 consultancy engagements for SMEs (5–25 staff): 10–15 days of senior consultant time at €80–100/hour. Source: market quotes from CLUSIF, Clusit, and APDC member networks (2025–2026).

Last audited

19 May 2026

Next audit due

19 Aug 2026

Cadence

Quarterly self-audit per Article 21(2)(f). Q2-2026 cycle ran 2026-05-19 — 5 KPIs reviewed, 4 on-target + 1 above-target, no below-target gaps. The cycle replaces prior PDFs in place on this page; metric and dates update with each cycle.

What this page means

Reglyze (legal entity) is a 5-person, sub-€10M-turnover company — explicitly below the small-enterprise floor that Article 2(1) of the NIS2 Directive uses to bring entities into scope. We could not file an Article 23 incident notification with ANSSI even if we wanted to; we are out of the directive's scope. The honest reasons we still ship the evidence base on this page:

  • Dogfooding. If our customers walk through the Reglyze product to build a NIS2 evidence base, the founder should walk through it first. Issues we find during this walk become product tasks (see the open-source plan brief).
  • Marketing. Anyone evaluating an AI-built NIS2 platform deserves to see what the AI actually produces. A redacted-but-real evidence base is more honest than a synthetic demo.
  • Future hiring. The day Reglyze crosses 50 staff or €10M turnover, the directive applies. The policies on this page form the baseline we will be audited against. Building them now is cheaper than building them under deadline.
  • Quarterly cadence. Article 21(2)(f) asks for periodic effectiveness review. Our voluntary cadence is quarterly — same as we recommend to paying customers.

Article 21 policies and evidence

The 14 artifacts below cover the ten Article 21(2) cybersecurity risk-management measures plus Article 20(2) management-body training and Article 21(2)(f) effectiveness testing. Each row links to the redacted PDF when published; cards marked Summary only carry the abstract until Cyril completes the per-PDF redaction pass.

Information Security Policy

Master policy: risk analysis, governance, roles and responsibilities. Approved by Cyril (sole management body member) for the Reglyze entity.

Approved: References Article 21(2)(a)
Summary only

Incident Response Plan

Detection → triage → containment → eradication → recovery → lessons learned. Authority-comms path is voluntary for Reglyze (out of scope under Article 2(1)) but documented for completeness.

Approved: References Article 21(2)(b) + Article 23
Summary only

Business Continuity Plan

RTO/RPO targets per service tier, failover paths (Hetzner primary + Google Drive cold backup), and tabletop exercise cadence for the Reglyze SaaS itself.

Approved: References Article 21(2)(c)
Summary only

Backup and Disaster Recovery Plan

Daily PostgreSQL dumps via rclone to Google Drive; 7-day on-box rotation; restore drill in deploy-rollback.md. Sized for a single founder's reach.

Approved: References Article 21(2)(c)
Summary only

Supply Chain Security Policy

Vendor due-diligence checklist, DPA expectations, breach-notification cascade. Applies to the 7-vendor SaaS stack (Cloudflare, Hetzner, Anthropic, Stripe, GitHub, Resend, Google Drive).

Approved: References Article 21(2)(d)
Summary only

Access Control Policy

Least-privilege model, MFA on every SaaS surface, joiner/mover/leaver flow (formally trivial at headcount 5 but documented). Sets the policy ceiling for future hires.

Approved: References Article 21(2)(i)
Summary only

Cryptography Policy

TLS 1.3 in-transit, AES-256 at-rest (PostgreSQL, MinIO, GDrive backup), key rotation cadence, no roll-your-own crypto. Inherited via SaaS vendors where applicable.

Approved: References Article 21(2)(h)
Summary only

Asset Management Policy

Asset inventory boundary (laptop + cloud accounts), labelling, lifecycle and decommissioning. Self-attested at solo scale; reviewed quarterly.

Approved: References Article 21(2)(i)
Summary only

HR Security Policy

Onboarding security checklist, NDA template, training requirement and offboarding access-revocation steps. Sized for the first hire; current state self-attested.

Approved: References Article 21(2)(i)
Summary only

Vulnerability Management Policy

Dependabot + GitHub security alerts as the inbound channel; severity-tiered SLA (critical < 7 days, high < 30 days); patch evidence in the commit history.

Approved: References Article 21(2)(e)
Summary only

MFA and Secured Communications Policy

MFA enforced on every SaaS surface; preferred authenticator app (no SMS fallback); secured-channel matrix for sensitive comms (Signal for incidents, GitHub for code).

Approved: References Article 21(2)(j)
Summary only

Effectiveness Testing Policy

Quarterly self-audit cadence, KPI definitions (today: Mean Time To Detect < 2 days), review evidence stored alongside this page's last-audit timestamp.

Approved: References Article 21(2)(f)
Summary only

Cybersecurity Training Plan

Annual training curriculum for the management body (Article 20(2)) and staff (Article 21(2)(g)). At headcount 5 this is Cyril; flagged for third-party validation on next hire.

Approved: References Article 21(2)(g) + Article 20(2)
Summary only

Article 20(2) Management-Body Training Certificate

Cyril completed the Reglyze management-body training on 2026-05-17 (self-paced, self-attested). Valid until 2027-05-17. Honest about its solo-scale limitation.

Approved: References Article 20(2)
Summary only

Training register (Article 20(2) + Article 21(2)(g))

The Reglyze management body completed Article 20(2) training inside the product on 2026-05-17. At headcount 5 with a single founder, the management body is one person; we flag this honestly as a solo-scale limitation that will trigger third-party-validated training on the next hire.

NIS2 Article 20(2) — Management-Body Training

Participant:
Cyril Poder
Completed:
Valid until:

Solo scale, self-paced, self-attested. Third-party validation flagged for next hire.

Supplier register (Article 21(2)(d))

Reglyze runs on a 7-vendor SaaS stack. The register tracks data shared, residual risk score, and review cadence per supplier. We publish vendor names openly — see the Trust page for the live view.

VendorServiceCriticality
CloudflareCDN, DNS, WAF, TLS termination
Critical
Hetzner Online GmbHCloud infrastructure / hosting
Critical
AnthropicAI / LLM (Claude API for document generation)
Critical
StripePayment processing and billing
Critical
GitHubSource code hosting and CI/CD
Critical
Google Workspace + Drive (via rclone)Off-site backup destination
High
ResendTransactional email delivery
Medium

Full register including residual-risk scores and review dates lives in the product. The criticality classification above maps to the audit_classification field (critical / important / standard) used by the supplier-review reminder cron.

Effectiveness testing (Article 21(2)(f))

The Q2-2026 cycle (the first quarterly Article 21(2)(f) audit) recorded 5 effectiveness KPIs against their stated targets: Mean Time To Detect (MTTD), Mean Time To Restore (MTTR), critical-patch SLA compliance, backup restore drill execution, and supplier review completion. KPI count will grow with new policies — the spine is locked.

KPIArticle 21(2)(f) sub-controlTargetQ2-2026 observedStatus
Mean Time To Detect (MTTD)
Time from a cybersecurity event occurring to Reglyze detecting it. Hetzner uptime monitor + Docker healthchecks at solo-CTO scale; no SOC/SIEM.
nis2.21.2.f.1< 2 days0 incidents
On target
Mean Time To Restore (MTTR)
Time from incident detection to service fully restored. Pre-deploy backup + auto-rollback validated in two 2026-05 drills inside 3 min wall-clock.
nis2.21.2.f.2< 4 hours0 incidents
On target
Critical patch SLA compliance
Percentage of critical/high Dependabot security PRs merged within 7 days. Q2-2026: 3/3 (drizzle-orm, Next.js, @xmldom/xmldom).
nis2.21.2.f.3100%100%
On target
Backup restore drill execution
Successful restore drills per quarter. Staging restore 2026-05-03 + auto-RESTORE_DB-on-smoke-fail validated 2026-05-15.
nis2.21.2.f.4≥ 1 / quarter2 drills
Above target
Supplier review completion
Percentage of suppliers within review cadence. 7/7 vendors carry next_review_due_at in the future as of audit date.
nis2.21.2.f.5100%100%
On target

Per-KPI findings and corrective actions are recorded in effectiveness_reviews on the prod database (idempotent, append-only). Next cycle locks 2026-08-19.

Untested KPIs (MTTD, MTTR, supplier-review cadence) are honest dogfooding artefacts — Reglyze had zero cybersecurity incidents in Q2-2026, so the detection-and-restore controls could not be empirically validated. Patch SLA and backup restore drill are quantitatively validated.

Audit cycle summary

Single audit_logs row stamps the cycle completion. Reviewer signature is digital — the dogfooding promise: the management body is Cyril, the sole admin who clicked through every screen.

Cycle
Q2-2026
Last audited
Reviewer
Cyril Poder
Next audit due
KPIs reviewed
5
Overall maturity score
58.1 / 100
Implementation 53.7 / Documentation 62.5
On target: 4
Above target: 1
Below target: 0

Reglyze is NIS2 out-of-scope under Article 2(1); this audit is voluntary. Cadence locked to quarterly — same recommendation we make to paying customers.

Integrity guarantees

This page is part of the Reglyze website, served as a static Next.js route, and the redacted PDFs live in version control alongside it. Anyone can verify the timeline:

  • Source: apps/web/src/app/[locale]/compliance/page.tsx in the public Reglyze repository.
  • PDFs: apps/web/public/compliance-artifacts/ — each commit shows the redacted artifact + its approval date.
  • Hours-saved metric: docs/research/self-compliance-timing.md row-by-row timing log; total cited above is the agent wall-clock sum across Phase 1 tasks 1.2 – 1.7.
  • Quarterly cadence: docs/research/self-compliance/task-3.1/applied.sql is the idempotent SQL receipt for the Q2-2026 cycle (effectiveness_kpis + effectiveness_reviews + an audit_logs row action=effectiveness.quarterly_audit_completed). Re-running it produces zero new rows.
  • Per Article 21(2)(f) cadence, this page re-audits quarterly; the Last audited and Next audit due dates are the cycle anchors.

Want this for your company?

Start a free scoping in five minutes. If you are out of scope under Article 2(1) like us, you can still build the voluntary evidence base on the Free tier. If you are in scope, Reglyze's Pro plan covers the full Article 21 surface with AI doc generation, supplier register, and quarterly audits.