Identifying and Modeling Barriers to Compliance with the NIS2 Directive: A DEMATEL Approach

Abstract

The implementation of the NIS2 Directive expands the scope of cybersecurity regulation across the European Union, placing new demands on both essential and important entities. Despite its importance, organizations face multiple barriers that undermine compliance, including lack of awareness, technical complexity, financial constraints, and regulatory uncertainty. This study identifies and models these barriers to provide a clearer view of the systemic challenges of NIS2 implementation. Building on a structured literature review, fourteen barriers were defined and validated through expert input. The Decision-Making Trial and Evaluation Laboratory (DEMATEL) method was then applied to examine their interdependencies and to map causal relationships. The analysis highlights lack of awareness and the evolving threat landscape as key drivers (i.e., causal factors) that reinforce each other. Technical complexity and financial constraints act as mediators transmitting the influence of these causal factors toward operational and governance failures. Operational disruptions, high reporting costs, and inadequate risk assessment emerge as the most dependent outcomes (i.e., effect factors), absorbing the impact of the driving and mediating factors. The findings suggest that interventions targeted at awareness-building, resource allocation, and risk management capacity have the greatest leverage for improving compliance and resilience. By clarifying the cause-and-effect dynamics among barriers, this study supports policymakers and managers in designing more effective strategies for NIS2 implementation and contributes to current debates on cybersecurity governance in critical infrastructures.