CER Directive · Physical Resilience · EU

CER compliance:
Do for physical security what you do for cyber

The CER Directive is the physical counterpart to NIS2. It requires operators of critical entities to systematically test and demonstrate their physical resilience – just as NIS2 requires for cybersecurity. Those who ignore this face personal liability.

CER-compliant audit evidence Focus on physical resilience Free initial consultation
What you get
Physical resilience evidence
Documented proof that your physical security measures have been tested and assessed – usable for CER audits and regulatory submissions.
Real attack simulation
No theoretical risk model – we actually test whether unauthorised access to your critical areas is possible.
Physical & social engineering combined
Most physical security gaps arise through the human factor. We test both together – for a realistic picture.
Clear remediation recommendations
Every finding with a concrete measure: what needs immediate attention, what can be addressed mid-term?
Our report documents physical vulnerabilities in line with CER Directive requirements and is suitable for internal and external audits as well as regulatory submissions.
NIS2 meets CER

What you do for cyber – now also for physical security

Many organisations have introduced and regularly tested extensive cybersecurity measures. The CER Directive requires exactly the same for physical security. The concept is identical – only the attack vectors are different.

Cybersecurity (NIS2)

Penetration test on IT systems
Firewall & access control review
Vulnerability scans & risk analysis
Documented audit report for regulators
CER requires the same

Physical security (CER)

Physical pentest on buildings & facilities
Access control & lock systems tested
Social engineering & tailgating simulated
Documented resilience evidence for regulators

Organisations that already take NIS2 seriously have learned: systematic testing is better than blindly trusting security measures. CER transfers this principle to the physical world – with the same legal consequences for non-compliance.

Affected entities

Who does the CER Directive apply to?

CER applies to operators of critical entities in eleven sectors – with significant overlap with NIS2. Many operators are subject to both directives simultaneously and must provide evidence on both levels.

Energy
💧Water & Wastewater
🏥Health
🏴Food
🏢Government & public entities
🚂Transport & Traffic
💻Digital infrastructure
📊Finance & Banking
🛰Space
🔬Research institutions
Chemical & hazardous substances

What are the consequences of non-compliance?

CER is not a recommendation catalogue – it is binding EU law with real consequences.
Fines of up to 2% of global annual turnover for essential entities – comparable to GDPR sanctions
Orders for immediate remediation from competent authorities, including possible temporary operational restrictions
Public disclosure of violations – with significant reputational damage towards customers, partners, and investors
Civil liability towards third parties in the event of incidents where security obligations were demonstrably neglected

Personal liability of management – non-delegable

CER explicitly places responsibility for physical resilience at board level. This means: managing directors and board members face personal liability if audit obligations are not fulfilled. It is not sufficient to delegate the matter to IT or the security officer. The duty to provide evidence lies with management – and so does the personal liability in the event of damage.

CER requirements

What Art. 13 CER requires of operators

Article 13 CER defines concrete measures for physical resilience. A physical penetration test is the audit instrument for the most important ones – and the evidence that regulators expect.

ART. 13 CER

Physical access controls

Operators must ensure that only authorised persons have access to critical areas. A pentest shows whether these controls hold up in practice – or only exist on paper.

Physical pentest
ART. 13 CER

Perimeter security

Fences, cameras, lighting, and barriers must be effective. We test whether they actually stop a determined attacker – or merely serve as a deterrent.

Physical pentest
ART. 13 CER

Protection against insider threats

Not all threats come from outside. Social engineering and insider scenarios show how resilient your organisation truly is against internal risks.

Social engineering
ART. 13 CER

Employee security awareness

Employees are the first and last line of defence. We test whether they recognise tailgating, pretexts, and manipulation attempts – or willingly hold the door open.

Social engineering
ART. 13 CER

Incident detection & response

How quickly is a physical intruder detected and reported? We test the detection and response capability of your organisation under realistic conditions.

Physical pentest
ART. 13 CER

Protection of critical resources

Servers, control systems, operations centres: the most sensitive areas need the highest protection. We test their security specifically – and show where the gaps are.

Physical pentest
Our approach

CER physical pentest in 5 steps

Systematic, documented, and CER-compliant – our approach delivers the evidence the directive requires and regulators expect.

SCHRITT 01

Scoping & target definition

Which areas, buildings, and scenarios should be tested? We jointly define the scope – taking your operational requirements and CER obligations into account.

SCHRITT 02

Reconnaissance & preparation

Information gathering about your site, publicly visible security measures, employee movements, and potential entry points.

SCHRITT 03

Physical penetration test

Simulated break-in attempt under realistic conditions: tailgating, lock picking, perimeter tests, social engineering – within the agreed scope.

SCHRITT 04

Documentation & analysis

Complete logging of all test actions, findings, and timestamps. Assessment by severity, exploitability, and regulatory relevance.

SCHRITT 05

CER-compliant final report

Complete report with all findings, recommendations, and CER mapping per Art. 13. Suitable as audit evidence for regulatory authorities and management.

11
Sectors affected by CER
Art. 13
CER core article for physical measures
2 %
Max. fine of global annual turnover
27+
EU member states affected
What our CER report contains
Complete documentation of all test actions performed with timestamps
Assessment of every finding by severity and exploitability
Mapping to Art. 13 CER requirements catalogue
Prioritised remediation plan with concrete recommendations
Management summary for board, supervisory board, and regulators
Relevant pentest modules

The building blocks of your CER evidence

CER focuses on physical resilience. These three modules cover the central requirements of the directive – and deliver the evidence regulators expect.

Physical penetration test

Simulated break-in attempt at your facilities: tailgating, lock picking, perimeter tests. The core module for CER evidence – we test whether unauthorised access is possible.

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Social engineering assessment

Phishing, vishing, personal manipulation: most physical security gaps arise through the human factor. We show how far targeted deception goes.

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Resilience documentation

For CER, the test alone is not enough – the evidence must also be documented and suitable for regulators. We deliver a structured final report as a complete audit document.

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Frequently asked questions

CER & physical security testing – your questions

NIS2 regulates the cybersecurity of critical entities – protecting IT systems, networks, and data. CER is the physical counterpart: it requires the same operators to systematically test and ensure their physical resilience. In short: NIS2 covers the digital side, CER covers the physical. Both are binding EU law – and both have real sanctions for non-compliance.
CER does not prescribe a specific testing method, but requires operators to test, assess, and document their physical security measures. A physical penetration test is the recognised and practical instrument for this – it delivers real insights rather than theoretical risk models and provides the audit evidence regulators expect. Organisations that rely solely on paper documentation without ever actually testing their measures will find themselves without evidence when it matters.
No – and this is one of the most important aspects of the CER Directive. The duty to ensure physical resilience lies explicitly at board level. Managing directors and board members face personal liability for the fulfilment of these obligations. The topic can be coordinated internally, but the responsibility remains with management. In the event of damage, regulators and courts will examine whether senior management fulfilled their supervisory duty.
CER provides for fines of up to 2% of global annual turnover – comparable to GDPR sanctions. In addition, there are orders for immediate remediation, possible operational restrictions, and public disclosure of violations. Proven negligence also exposes organisations to civil liability towards third parties. The combination of fines, reputational damage, and personal liability makes inaction the most expensive option.
Yes – and we recommend this for all operators subject to both directives. A combined assessment tests both physical and digital attack vectors in one engagement and delivers an integrated report that serves as evidence for both directives. This saves effort and provides the complete security picture. Talk to us about a tailored combination package.
There is no one-size-fits-all answer – scope, number of sites, desired scenarios, and reporting depth all significantly affect the effort involved. What we can say: a test not conducted that results in a fine of 2% of annual turnover is by far the more expensive option. After a free initial consultation you will receive a transparent fixed-price offer.

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