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Implementing NIS2

One account.
Everything gone?
Not necessarily.

NIS2 Article 21 defines ten risk measures, two of which determine in practice whether a company can operate again within hours after an attack or within weeks. Managed Red Tenant and Dark Tenant cover exactly those two, technically.

Abstract security map with route lines and blue X markers on an orange background
Webcast on Red and Dark Tenant for NIS2 risk mitigation

Managed Red Tenant and Managed Dark Tenant: how we implement the risk measures from NIS2 Article 21

What made the Stryker attack on March 11, 2026 remarkable wasn't the number of affected devices — though 80,000 devices across 79 countries is a striking figure — but the banality of the method: no exploit, no zero-day, no sophisticated attack on obscure infrastructure components. A single compromised Intune admin account was enough, and from the outside the attack looked like normal operations — because technically it was, just executed by someone else. What exactly happened is covered in the Stryker attack blog post.

Most enterprise infrastructures are built in a way that makes this kind of damage possible — not because anyone was negligent, but because privileged accounts with broad permissions have been considered practical for years: one account with access to everything saves time in daily operations, and time is notoriously the one thing even scarcer than budget in IT departments. NIS2 Article 21 draws the consequences from this practice: privileged identities must be isolated in a way that prevents their compromise from taking down the entire infrastructure, and those who still get hit must be able to operate again within hours.

What NIS2 is and who it applies to is covered here. This page is about the technical implementation of those two requirements with Managed Red Tenant and Managed Dark Tenant.

24 days

average downtime after a ransomware attack (Coveware, 2024)

€267bn

annual damage from cyberattacks in Germany (Fire Drills)

30,000

companies in Germany subject to NIS2 (BSI)

< 4 hrs

to first operational capability with Managed Dark Tenant

Abstract security map with routes and markers symbolizing isolated privileged access

Managed Red Tenant: so a compromised account doesn't become a master key

The attack pattern that worked in the Stryker incident isn't new: attackers compromise an account that gives them access to privileged systems, move laterally from there to the rest of the infrastructure, and cause the damage their permissions allow. It works so reliably because most organizations have no structural separation between standard work environments and the administrative access that would be sufficient to take over the entire infrastructure.

Managed Red Tenant breaks this pattern by moving administrative identities and their associated endpoints into a fully separated Microsoft tenant — with dedicated Entra ID accounts, dedicated hardened devices, and no network connection to the production environment that an attacker could use for lateral movement. Anyone trying to move from a compromised standard workstation toward critical systems runs into a boundary that didn't exist before.

Managed Red Tenant
Managed Dark Tenant visual with MVC and MDR components

Managed Dark Tenant: the prepared environment for the scenario that shouldn't happen but might

After a large-scale ransomware attack, the problems a company faces fall into two categories: the technical ones, which are solvable — if not quickly — and the organizational ones, where no one defined in advance who does what in a crisis, in what order decisions get made, or what communication can even be trusted when the company's own infrastructure is no longer reliable. Coveware puts the average downtime after a ransomware attack at 24 days, and incident experience shows the delay is rarely caused by a lack of technical resources — it's caused by having to invent, under extreme pressure, processes that were never needed during normal operations.

Managed Dark Tenant is a pre-provisioned, fully isolated Microsoft environment that gets activated in a crisis via a 24/7 hotline and gives the response team operational communication, Windows 365 workstations, and an AD recovery pipeline within hours — all built on Infrastructure as Code, all defined and tested before it's needed. The underlying architecture principle is called Minimum Viable Company: communication first, then critical documents, then core applications — in an order that's defined in advance and regularly tested through Fire Drills.

Managed Dark Tenant

Seven of the ten risk measures from NIS2 Article 21. We cover them.

Seven of the ten risk measures from NIS2 Article 21 can be covered with Managed Red Tenant and Managed Dark Tenant — regardless of whether the motivation is compliance or the straightforward conclusion that both make sense with or without NIS2.

Risk Measures | GK ServicesNIS2CSOCAPT ResponsePreventive ServicesManaged Red TenantManaged Dark TenantData SecurityWorkplace / Azure
Risk Analysis and Information System Security
21.2 a)
Incident Handling
21.2 b)
NEU
NEU
Business Continuity
21.2 c)
NEU
Supply Chain Security
21.2 d)
NEU
Security in Network and Information Systems
21.2 e)
Effectiveness of Cybersecurity Risk Management Measures
21.2 f)
NEU
NEU
Basic Computer Hygiene Practices and Cybersecurity Training
21.2 g)
Cryptography
21.2 h)
Human Resources Security, Access Control Policies and Asset Management
21.2 i)
NEU
Multifactor Authentication or Secured Communication
21.2 j)
NEU

How we set up Red and Dark Tenant for you

From assessment to ongoing operations in three steps. The organizational side of NIS2 compliance — from applicability analysis to gap assessment — is handled by a specialized partner.
  • Assessment and Architecture
    Assessment and Architecture
    Together, we identify which identities and workloads belong to Tier 0 and Tier 1, and define the Minimum Viable Company — the critical processes and communication channels that need to be restored first in a crisis. The result is an architecture design for both tenants, aligned with existing Microsoft licenses, current incident response processes, and the customer's Active Directory topology.
  • Deployment on Infrastructure as Code
    Deployment on Infrastructure as Code
    Both tenants are provisioned from our proven blueprints. Every configuration is defined as code, auditable, and traceable. Every change goes through a multi-stage testing process with dedicated pre-tenants before reaching the production environment. Changes to production require explicit approval — because in high-privilege environments, control over every change isn't bureaucratic overhead, it's security architecture.
  • 24/7 Operations and Fire Drills
    24/7 Operations and Fire Drills
    The CSOC monitors the Red Tenant around the clock. The Dark Tenant hotline with Manager on Duty is reachable at any time. Regular Fire Drills test recovery paths under realistic conditions — because a disaster recovery environment that has never been activated is a hypothesis, not a solution.

Further reading

Start your NIS2 check

Find out in an initial conversation how you can implement NIS2 requirements pragmatically and securely.
Jan Geisbauer
NIS2 is more than a legal obligation. It is an opportunity to anchor cybersecurity strategically. With Microsoft technologies, a cloud-first approach and deep expertise, we guide you on your path to NIS2 compliance.
Jonathan Haist & Jonathan ZabelSOC Architect & Cyber Security Architect