Blog
/
Compliance
/
February 11, 2025

NIS2 Compliance: Interpreting 'State-of-the-Art' for Organisations

This blog explores key technical factors that define state-of-the-art cybersecurity. Drawing on expertise from our business, academia, and national security standards, outlining five essential criteria.
Inside the SOC
Darktrace cyber analysts are world-class experts in threat intelligence, threat hunting and incident response, and provide 24/7 SOC support to thousands of Darktrace customers around the globe. Inside the SOC is exclusively authored by these experts, providing analysis of cyber incidents and threat trends, based on real-world experience in the field.
Written by
Livia Fries
Public Policy Manager, EMEA
Default blog imageDefault blog imageDefault blog imageDefault blog imageDefault blog imageDefault blog image
11
Feb 2025

NIS2 Background

17 October 2024 marked the deadline for European Union (EU) Member States to implement the NIS2 Directive into national law. The Directive aims to enhance the EU’s cybersecurity posture by establishing a high common level of cybersecurity for critical infrastructure and services. It builds on its predecessor, the 2018 NIS Directive, by expanding the number of sectors in scope, enforcing greater reporting requirements and encouraging Member States to ensure regulated organisations adopt ‘state-of-the-art' security measures to protect their networks, OT and IT systems.  

Timeline of NIS2
Figure 1: Timeline of NIS2

The challenge of NIS2 & 'state-of-the-art'

Preamble (51) - "Member States should encourage the use of any innovative technology, including artificial intelligence, the use of which could improve the detection and prevention of cyberattacks, enabling resources to be diverted towards cyberattacks more effectively."
Article 21 - calls on Member States to ensure that essential and important entities “take appropriate and proportionate” cyber security measures, and that they do so by “taking into account the state-of-the-art and, where applicable, relevant European and international standards, as well as the cost of implementation.”

Regulartory expectations and ambiguity of NIS2

While organisations in scope can rely on technical guidance provided by ENISA1 , the EU’s agency for cybersecurity, or individual guidelines provided by Member States or Public-Private Partnerships where they have been published,2 the mention of ‘state-of-the-art' remains up to interpretation in most Member States. The use of the phrase implies that cybersecurity measures must evolve continuously to keep pace with emerging threats and technological advancements without specifying what ‘state-of-the-art’ actually means for a given context and risk.3  

This ambiguity makes it difficult for organisations to determine what constitutes compliance at any given time and could lead to potential inconsistencies in implementation and enforcement. Moreover, the rapid pace of technological change means that what is considered "state-of-the-art" today will become outdated, further complicating compliance efforts.

However, this is not unique to NIS regulation. As EU scholars have noted, while “state-of-the-art" is widely referred to in legal text relating to technology, there is no standardised legal definition of what it actually constitutes.4

Defining state-of-the-art cybersecurity

In this blog, we outline technical considerations for state-of-the-art cybersecurity. We draw from expertise within our own business and in academia as well as guidelines and security standards set by national agencies, such as Germany’s Federal Office for Information Security (BSI) or Spain’s National Security Framework (ENS), to put forward five criteria to define state-of-the-art cybersecurity.

The five core criteria include:

  • Continuous monitoring
  • Incident correlation
  • Detection of anomalous activity
  • Autonomous response
  • Proactive cyber resilience

These principles build on long-standing security considerations, such as business continuity, vulnerability management and basic security hygiene practices.  

Although these considerations are written in the context of the NIS2 Directive, they are likely to also be relevant for other jurisdictions. We hope these criteria help organisations understand how to best meet their responsibilities under the NIS2 Directive and assist Competent Authorities in defining compliance expectations for the organisations they regulate.  

Ultimately, adopting state-of-the-art cyber defences is crucial for ensuring that organisations are equipped with the best tools to combat new and fast-growing threats. Leading technical authorities, such as the UK National Cyber Security Centre (NCSC), recognise that adoption of AI-powered cyber defences will offset the increased volume and impact of AI on cyber threats.5

State of the art cybersecurity in the context of NIS2

1. Continuous monitoring

Continuous monitoring is required to protect an increasingly complex attack surface from attackers.

First, organisations' attack surfaces have expanded following the widespread adoption of hybrid or cloud infrastructures and the increased adoption of connected Internet of Things (IoT) devices.6 This exponential growth creates a complex digital environment for organisations, making it difficult for security teams to track all internet-facing assets and identify potential vulnerabilities.

Second, with the significant increase in the speed and sophistication of cyber-attacks, organisations face a greater need to detect security threats and non-compliance issues in real-time.  

Continuous monitoring, defined by the U.S. National Institute of Standards and Technology (NIST) as the ability to maintain “ongoing awareness of information security, vulnerabilities, and threats to support organizational risk management decisions,”7 has therefore become a cornerstone of an effective cybersecurity strategy. By implementing continuous monitoring, organisations can ensure a real-time understanding of their attack surface and that new external assets are promptly accounted for. For instance, Spain’s technical guidelines for regulation, as set forth by the National Security Framework (Royal Decree 311/2022), highlight the importance of adopting continuous monitoring to detect anomalous activities or behaviours and to ensure timely responses to potential threats (article 10).8  

This can be achieved through the following means:  

All assets that form part of an organisation's estate, both known and unknown, must be identified and continuously monitored for current and emerging risks. Germany’s BSI mandates the continuous monitoring of all protocol and logging data in real-time (requirement #110).9 This should be conducted alongside any regular scans to detect unknown devices or cases of shadow IT, or the use of unauthorised or unmanaged applications and devices within an organisation, which can expose internet-facing assets to unmonitored risks. Continuous monitoring can therefore help identify potential risks and high-impact vulnerabilities within an organisation's digital estate and eliminate potential gaps and blind spots.

Organisations looking to implement more efficient continuous monitoring strategies may turn to automation, but, as the BSI notes, it is important for responsible parties to be immediately warned if an alert is raised (reference 110).10 Following the BSI’s recommendations, the alert must be examined and, if necessary, contained within a short period of time corresponding with the analysis of the risk at hand.

Finally, risk scoring and vulnerability mapping are also essential parts of this process. Continuous monitoring helps identify potential risks and significant vulnerabilities within an organisation's digital assets, fostering a dynamic understanding of risk. By doing so, risk scoring and vulnerability mapping allows organisations to prioritise the risks associated with their most critically exposed assets.

2. Correlation of incidents across your entire environment

Viewing and correlating incident alerts when working with different platforms and tools poses significant challenges to SecOps teams. Security professionals often struggle to cross-reference alerts efficiently, which can lead to potential delays in identifying and responding to threats. The complexity of managing multiple sources of information can overwhelm teams, making it difficult to maintain a cohesive understanding of the security landscape.

This fragmentation underscores the need for a centralised approach that provides a "single pane of glass" view of all cybersecurity alerts. These systems streamline the process of monitoring and responding to incidents, enabling security teams to act more swiftly and effectively. By consolidating alerts into a unified interface, organisations can enhance their ability to detect and mitigate threats, ultimately improving their overall security posture.  

To achieve consolidation, organisations should consider the role automation can play when reviewing and correlating incidents. This is reflected in Spain’s technical guidelines for national security regulations regarding the requirements for the “recording of activity” (reinforcement R5).12 Specifically, the guidelines state that:  

"The system shall implement tools to analyses and review system activity and audit information, in search of possible or actual security compromises. An automatic system for collection of records, correlation of events and automatic response to them shall be available”.13  

Similarly, the German guidelines stress that automated central analysis is essential not only for recording all protocol and logging data generated within the system environment but also to ensure that the data is correlated to ensure that security-relevant processes are visible (article 115).14

Correlating disparate incidents and alerts is especially important when considering the increased connectivity between IT and OT environments driven by business and functional requirements. Indeed, organisations that believe they have air-gapped systems are now becoming aware of points of IT/OT convergence within their systems. It is therefore crucial for organisations managing both IT and OT environments to be able to visualise and secure devices across all IT and OT protocols in real-time to identify potential spillovers.  

By consolidating data into a centralised system, organisations can achieve a more resilient posture. This approach exposes and eliminates gaps between people, processes, and technology before they can be exploited by malicious actors. As seen in the German and Spanish guidelines, a unified view of security alerts not only enhances the efficacy of threat detection and response but also ensures comprehensive visibility and control over the organisation's cybersecurity posture.

3. Detection of anomalous activity  

Recent research highlights the emergence of a "new normal" in cybersecurity, marked by an increase in zero-day vulnerabilities. Indeed, for the first time since sharing their annual list, the Five Eyes intelligence alliance reported that in 2023, the majority of the most routinely exploited vulnerabilities were initially exploited as zero-days.15  

To effectively combat these advanced threats, policymakers, industry and academic stakeholders alike recognise the importance of anomaly-based techniques to detect both known and unknown attacks.

As AI-enabled threats become more prevalent,16 traditional cybersecurity methods that depend on lists of "known bads" are proving inadequate against rapidly evolving and sophisticated attacks. These legacy approaches are limited because they can only identify threats that have been previously encountered and cataloged. However, cybercriminals are constantly developing new, never-before-seen threats, such as signatureless ransomware or living off the land techniques, which can easily bypass these outdated defences.

The importance of anomaly detection in cybersecurity can be found in Spain’s technical guidelines, which states that “tools shall be available to automate the prevention and response process by detecting and identifying anomalies17” (reinforcement R4 prevention and automatic response to "incident management”).  

Similarly, the UK NCSC’s Cyber Assessment Framework (CAF) highlights how anomaly-based detection systems are capable of detecting threats that “evade standard signature-based security solutions” (Principle C2 - Proactive Security Event Discovery18). The CAF’s C2 principle further outlines:  

“The science of anomaly detection, which goes beyond using pre-defined or prescriptive pattern matching, is a challenging area. Capabilities like machine learning are increasingly being shown to have applicability and potential in the field of intrusion detection.”19

By leveraging machine learning and multi-layered AI techniques, organisations can move away from static rules and signatures, adopting a more behavioural approach to identifying and containing risks. This shift not only enhances the detection of emerging threats but also provides a more robust defence mechanism.

A key component of this strategy is behavioral zero trust, which focuses on identifying unauthorized and out-of-character attempts by users, devices, or systems. Implementing a robust procedure to verify each user and issuing the minimum required access rights based on their role and established patterns of activity is essential. Organisations should therefore be encouraged to follow a robust procedure to verify each user and issue the minimum required access rights based on their role and expected or established patterns of activity. By doing so, organisations can stay ahead of emerging threats and embrace a more dynamic and resilient cybersecurity strategy.  

4. Autonomous response

The speed at which cyber-attacks occur means that defenders must be equipped with tools that match the sophistication and agility of those used by attackers. Autonomous response tools are thus essential for modern cyber defence, as they enable organisations to respond to both known and novel threats in real time.  

These tools leverage a deep contextual and behavioral understanding of the organisation to take precise actions, effectively containing threats without disrupting business operations.

To avoid unnecessary business disruptions and maintain robust security, especially in more sensitive networks such as OT environments, it is crucial for organisations to determine the appropriate response depending on their environment. This can range from taking autonomous and native actions, such as isolating or blocking devices, or integrating their autonomous response tool with firewalls or other security tools to taking customized actions.  

Autonomous response solutions should also use a contextual understanding of the business environment to make informed decisions, allowing them to contain threats swiftly and accurately. This means that even as cyber-attacks evolve and become more sophisticated, organisations can maintain continuous protection without compromising operational efficiency.  

Indeed, research into the adoption of autonomous cyber defences points to the importance of implementing “organisation-specific" and “context-informed” approaches.20  To decide the appropriate level of autonomy for each network action, it is argued, it is essential to use evidence-based risk prioritisation that is customised to the specific operations, assets, and data of individual enterprises.21

By adopting autonomous response solutions, organisations can ensure their defences are as dynamic and effective as the threats they face, significantly enhancing their overall security posture.

5. Proactive cyber resilience  

Adopting a proactive approach to cybersecurity is crucial for organisations aiming to safeguard their operations and reputation. By hardening their defences enough so attackers are unable to target them effectively, organisations can save significant time and money. This proactive stance helps reduce business disruption, reputational damage, and the need for lengthy, resource-intensive incident responses.

Proactive cybersecurity incorporates many of the strategies outlined above. This can be seen in a recent survey of information technology practitioners, which outlines four components of a proactive cybersecurity culture: (1) visibility of corporate assets, (2) leveraging intelligent and modern technology, (3) adopting consistent and comprehensive training methods and (4) implementing risk response procedures.22 To this, we may also add continuous monitoring which allows organisations to understand the most vulnerable and high-value paths across their architectures, allowing them to secure their critical assets more effectively.  

Alongside these components, a proactive cyber strategy should be based on a combined business context and knowledge, ensuring that security measures are aligned with the organisation's specific needs and priorities.  

This proactive approach to cyber resilience is reflected in Spain’s technical guidance (article 8.2): “Prevention measures, which may incorporate components geared towards deterrence or reduction of the exposure surface, should eliminate or reduce the likelihood of threats materializing.”23 It can also be found in the NCSC’s CAF, which outlines how organisations can achieve “proactive attack discovery” (see Principle C2).24 Likewise, Belgium’s NIS2 transposition guidelines mandate the use of preventive measures to ensure the continued availability of services in the event of exceptional network failures (article 30).25  

Ultimately, a proactive approach to cybersecurity not only enhances protection but also lowers regulatory risk and supports the overall resilience and stability of the organisation.

Looking forward

The NIS2 Directive marked a significant regulatory milestone in strengthening cybersecurity across the EU.26 Given the impact of emerging technologies, such as AI, on cybersecurity, it is to see that Member States are encouraged to promote the adoption of ‘state-of-the-art' cybersecurity across regulated entities.  

In this blog, we have sought to translate what state-of-the-art cybersecurity may look like for organisations looking to enhance their cybersecurity posture. To do so, we have built on existing cybersecurity guidance, research and our own experience as an AI-cybersecurity company to outline five criteria: continuous monitoring, incident correlation, detection of anomalous activity, autonomous response, and proactive cyber resilience.

By embracing these principles and evolving cybersecurity practices in line with the state-of-the-art, organisations can comply with the NIS2 Directive while building a resilient cybersecurity posture capable of withstanding evolutions in the cyber threat landscape. Looking forward, it will be interesting to see how other jurisdictions embrace new technologies, such as AI, in solving the cybersecurity problem.

NIS2 white paper

Get ahead with the NIS2 White Paper

Get a clear roadmap for meeting NIS2 requirements and strengthening your cybersecurity posture. Learn how to ensure compliance, mitigate risks, and protect your organization from evolving threats.

Download Here!

References

[1] https://www.enisa.europa.eu/publications/implementation-guidance-on-nis-2-security-measures

[2] https://www.teletrust.de/fileadmin/user_upload/2023-05_TeleTrusT_Guideline_State_of_the_art_in_IT_security_EN.pdf

[3] https://kpmg.com/uk/en/home/insights/2024/04/what-does-nis2-mean-for-energy-businesses.html

[4] https://orbilu.uni.lu/bitstream/10993/50878/1/SCHMITZ_IFIP_workshop_sota_author-pre-print.pdf

[5]https://www.ncsc.gov.uk/report/impact-of-ai-on-cyber-threat

[6] https://www.sciencedirect.com/science/article/pii/S2949715923000793

[7] https://csrc.nist.gov/glossary/term/information_security_continuous_monitoring

[8] https://ens.ccn.cni.es/es/docman/documentos-publicos/39-boe-a-2022-7191-national-security-framework-ens/file

[9] https://www.bsi.bund.de/SharedDocs/Downloads/DE/BSI/KRITIS/Konkretisierung_Anforderungen_Massnahmen_KRITIS.html

[10] https://www.bsi.bund.de/SharedDocs/Downloads/DE/BSI/KRITIS/Konkretisierung_Anforderungen_Massnahmen_KRITIS.html

[12] https://ens.ccn.cni.es/es/docman/documentos-publicos/39-boe-a-2022-7191-national-security-framework-ens/file

[13] https://ens.ccn.cni.es/es/docman/documentos-publicos/39-boe-a-2022-7191-national-security-framework-ens/file

[14] https://www.bsi.bund.de/SharedDocs/Downloads/DE/BSI/KRITIS/Konkretisierung_Anforderungen_Massnahmen_KRITIS.html

[15] https://therecord.media/surge-zero-day-exploits-five-eyes-report

[16] https://www.ncsc.gov.uk/report/impact-of-ai-on-cyber-threat

[17] https://ens.ccn.cni.es/es/docman/documentos-publicos/39-boe-a-2022-7191-national-security-framework-ens/file

[18] https://www.ncsc.gov.uk/collection/cyber-assessment-framework/caf-objective-c-detecting-cyber-security-events/principle-c2-proactive-security-event-discovery

[19] https://www.ncsc.gov.uk/collection/cyber-assessment-framework/caf-objective-c-detecting-cyber-security-events/principle-c2-proactive-security-event-discovery

[20] https://cetas.turing.ac.uk/publications/autonomous-cyber-defence-autonomous-agents

[21] https://cetas.turing.ac.uk/publications/autonomous-cyber-defence-autonomous-agents

[22] https://www.researchgate.net/publication/376170443_Cultivating_Proactive_Cybersecurity_Culture_among_IT_Professional_to_Combat_Evolving_Threats

[23] https://ens.ccn.cni.es/es/docman/documentos-publicos/39-boe-a-2022-7191-national-security-framework-ens/file

[24] https://www.ncsc.gov.uk/collection/cyber-assessment-framework/caf-objective-c-detecting-cyber-security-events/principle-c2-proactive-security-event-discovery

[25] https://www.ejustice.just.fgov.be/mopdf/2024/05/17_1.pdf#page=49

[26] ENISA, NIS Directive 2

Inside the SOC
Darktrace cyber analysts are world-class experts in threat intelligence, threat hunting and incident response, and provide 24/7 SOC support to thousands of Darktrace customers around the globe. Inside the SOC is exclusively authored by these experts, providing analysis of cyber incidents and threat trends, based on real-world experience in the field.
Written by
Livia Fries
Public Policy Manager, EMEA

More in this series

No items found.

Blog

/

Compliance

/

June 9, 2025

Modernising UK Cyber Regulation: Implications of the Cyber Security and Resilience Bill

Two individuals sitting at a desk working on a documentDefault blog imageDefault blog image

The need for security and continued cyber resilience

The UK government has made national security a key priority, and the new Cyber Security and Resilience Bill (CSRB) is a direct reflection of that focus. In introducing the Bill, Secretary of State for Science, Innovation and Technology, Peter Kyle, recognised that the UK is “desperately exposed” to cyber threats—from criminal groups to hostile nation-states that are increasingly targeting the UK's digital systems and critical infrastructure[1].

Context and timeline for the new legislation

First announced during the King’s Speech of July 2024, and elaborated in a Department for Science, Innovation and Technology (DSIT) policy statement published in April 2025, the CSRB is expected to be introduced in Parliament during the 2025-26 legislative session.

For now, organisations in the UK remain subject to the 2018 Network and Information Systems (NIS) Regulations – an EU-derived law which was drafted before today’s increasing digitisation of critical services, rise in cloud adoption and emergence of AI-powered threats.

Why modernisation is critical

Without modernisation, the Government believes UK’s infrastructure and economy risks falling behind international peers. The EU, which revised its cybersecurity regulation under the NIS2 Directive, already imposes stricter requirements on a broader set of sectors.

The urgency of the Bill is also underscored by recent high-impact incidents, including the Synnovis attack which targeted the National Health Service (NHS) suppliers and disrupted thousands of patient appointments and procedures[2]. The Government has argued that such events highlight a systemic failure to keep pace with a rapidly evolving threat landscape[3].

What the Bill aims to achieve

This Bill represents a decisive shift. According to the Government, it will modernise and future‑proof the UK’s cyber laws, extending oversight to areas where risk has grown but regulation has not kept pace[4]. While the legislation builds on previous consultations and draws lessons from international frameworks like the EU’s NIS2 directive, it also aims to tailor solutions to the UK’s unique threat environment.

Importantly, the Government is framing cybersecurity not as a barrier to growth, but as a foundation for it. The policy statement emphasises that strong digital resilience will create the stability businesses need to thrive, innovate, and invest[5]. Therefore, the goals of the Bill will not only be to enhance security but also act as an enabler to innovation and economic growth.

Recognition that AI changes cyber threats

The CSRB policy statement recognises that AI is fundamentally reshaping the threat landscape, with adversaries now leveraging AI and commercial cyber tools to exploit vulnerabilities in critical infrastructure and supply chains. Indeed, the NCSC has recently assessed that AI will almost certainly lead to “an increase in the frequency and intensity of cyber threats”[6]. Accordingly, the policy statement insists that the UK’s regulatory framework “must keep pace and provide flexibility to respond to future threats as and when they emerge”[7].

To address the threat, the Bill signals new obligations for MSPs and data centres, timely incident reporting and dynamic guidance that can be refreshed without fresh primary legislation, making it essential for firms to follow best practices.

What might change in day-to-day practice?

New organisations in scope of regulation

Under the existing Network and Information Systems (NIS) Regulations[8], the UK already supervises operators in five critical sectors—energy, transport, drinking water, health (Operators of Essential Services, OES) and digital infrastructure (Relevant Digital Service Providers, RDSPs).

The Cyber Security and Resilience Bill retains this foundation and adds Managed Service Providers (MSPs) and data centres to the scope of regulation to “better recognise the increasing reliance on digital services and the vulnerabilities posed by supply chains”[9]. It also grants the Secretary of State for Science, Innovation and Technology the power to add new sectors or sub‑sectors via secondary legislation, following consultation with Parliament and industry.

Managed service providers (MSPs)

MSPs occupy a central position within the UK’s enterprise information‑technology infrastructure. Because they remotely run or monitor clients’ systems, networks and data, they hold privileged, often continuous access to multiple environments. This foothold makes them an attractive target for malicious actors.

The Bill aims to bring MSPs in scope of regulation by making them subject to the same duties as those placed on firms that provide digital services under the 2018 NIS Regulations. By doing so, the Bill seeks to raise baseline security across thousands of customer environments and to provide regulators with better visibility of supply‑chain risk.

The proposed definition for MSPs is a service which:

  1. Is provided to another organisation
  2. Relies on the use of network and information systems to deliver the service
  3. Relates to ongoing management support, active administration and/or monitoring of AI systems, IT infrastructure, applications, and/or IT networks, including for the purpose of activities relating to cyber security.
  4. Involves a network connection and/or access to the customer’s network and information systems.

Data centres

Building on the September 2024 designation of data centres as critical national infrastructure, the CSRB will fold data infrastructure into the NIS-style regime by naming it an “relevant sector" and data centres as “essential service”[10].

About 182 colocation facilities run by 64 operators will therefore come under statutory duties to notify the regulator, maintain proportionate CAF-aligned controls and report significant incidents, regardless of who owns them or what workloads they host.

New requirements for regulated organisations

Incident reporting processes

There could be stricter timelines or broader definitions of what counts as a reportable incident. This might nudge organisations to formalise detection, triage, and escalation procedures.

The Government is proposing to introduce a new two-stage incident reporting process. This would include an initial notification which would be submitted within 24 hours of becoming aware of a significant incident, followed by a full incident report which should be submitted within 72 hours of the same.

Supply chain assurance requirements

Supply chains for the UK's most critical services are becoming increasingly complex and present new and serious vulnerabilities for cyber-attacks. The recent Synnovis ransomware attacks on the NHS[11] exemplify the danger posed by attacks against the supply chains of important services and organisations. This is concerning when reflecting on the latest Cyber Security Breaches survey conducted by DSIT, which highlights that fewer than 25% of large businesses review their supply chain risks[12].

Despite these risks, the UK’s legacy cybersecurity regulatory regime does not explicitly cover supply chain risk management. The UK instead relies on supporting and non-statutory guidance to close this gap, such as the NCSC’s Cyber Assessment Framework (CAF)[13].

The CSRB policy statement acts on this regulatory shortcoming and recognises that “a single supplier’s disruption can have far-reaching impacts on the delivery of essential or digital services”[14].

To address this, the Bill would make in-scope organisations (OES and RDPS) directly accountable for the cybersecurity of their supply chains. Secondary legislation would spell out these duties in detail, ensuring that OES and RDSPs systematically assess and mitigate third-party cyber risks.

Updated and strengthened security requirements

By placing the CAF into a firmer footing and backing it with a statutory Code of Practice, the Government is setting clearer expectations about government expectations on technical standards and methods organisations will need to follow to prove their resilience.

How Darktrace can help support affected organizations

Demonstrate resilience

Darktrace’s Self-Learning AITM continuously monitors your digital estate across cloud, network, OT, email, and endpoint to detect, investigate, and autonomously respond to emerging threats in real time. This persistent visibility and defense posture helps organizations demonstrate cyber resilience to regulators with confidence.

Streamline incident reporting and compliance

Darktrace surfaces clear alerts and automated investigation reports, complete with timeline views and root cause analysis. These insights reduce the time and complexity of regulatory incident reporting and support internal compliance workflows with auditable, AI-generated evidence.

Improve supply chain visibility

With full visibility across connected systems and third-party activity, Darktrace detects early indicators of lateral movement, account compromise, and unusual behavior stemming from vendor or partner access, reducing the risk of supply chain-originated cyber-attacks.

Ensure MSPs can meet new standards

For managed service providers, Darktrace offers native multi-tenant support and autonomous threat response that can be embedded directly into customer environments. This ensures consistent, scalable security standards across clients—helping MSPs address increasing regulatory obligations.

[related-resource]

References

[1] https://www.theguardian.com/uk-news/article/2024/jul/29/uk-desperately-exposed-to-cyber-threats-and-pandemics-says-minister

[2] https://www.england.nhs.uk/2024/06/synnovis-cyber-attack-statement-from-nhs-england/

[3] https://www.gov.uk/government/publications/cyber-security-and-resilience-bill-policy-statement/cyber-security-and-resilience-bill-policy-statement

[4] https://www.gov.uk/government/publications/cyber-security-and-resilience-bill-policy-statement/cyber-security-and-resilience-bill-policy-statement

[5] https://www.gov.uk/government/publications/cyber-security-and-resilience-bill-policy-statement/cyber-security-and-resilience-bill-policy-statement

[6] https://www.ncsc.gov.uk/report/impact-ai-cyber-threat-now-2027

[7] https://www.gov.uk/government/publications/cyber-security-and-resilience-bill-policy-statement/cyber-security-and-resilience-bill-policy-statement

[8] https://www.gov.uk/government/collections/nis-directive-and-nis-regulations-2018

[9] https://www.gov.uk/government/publications/cyber-security-and-resilience-bill-policy-statement/cyber-security-and-resilience-bill-policy-statement

[10] https://www.gov.uk/government/publications/cyber-security-and-resilience-bill-policy-statement/cyber-security-and-resilience-bill-policy-statement

[11] https://www.england.nhs.uk/2024/06/synnovis-cyber-attack-statement-from-nhs-england/

[12] https://www.gov.uk/government/statistics/cyber-security-breaches-survey-2025/cyber-security-breaches-survey-2025

[13] https://www.ncsc.gov.uk/collection/cyber-assessment-framework

[14] https://www.gov.uk/government/publications/cyber-security-and-resilience-bill-policy-statement/cyber-security-and-resilience-bill-policy-statement

Continue reading
About the author
The Darktrace Community

Blog

/

Network

/

June 5, 2025

Unpacking ClickFix: Darktrace’s detection of a prolific social engineering tactic

Woman on laptop in office buildingDefault blog imageDefault blog image

What is ClickFix and how does it work?

Amid heightened security awareness, threat actors continue to seek stealthy methods to infiltrate target networks, often finding the human end user to be the most vulnerable and easily exploited entry point.

ClickFix baiting is an exploitation of the end user, making use of social engineering techniques masquerading as error messages or routine verification processes, that can result in malicious code execution.

Since March 2024, the simplicity of this technique has drawn attention from a range of threat actors, from individual cybercriminals to Advanced Persistent Threat (APT) groups such as APT28 and MuddyWater, linked to Russia and Iran respectively, introducing security threats on a broader scale [1]. ClickFix campaigns have been observed affecting organizations in across multiple industries, including healthcare, hospitality, automotive and government [2][3].

Actors carrying out these targeted attacks typically utilize similar techniques, tools and procedures (TTPs) to gain initial access. These include spear phishing attacks, drive-by compromises, or exploiting trust in familiar online platforms, such as GitHub, to deliver malicious payloads [2][3]. Often, a hidden link within an email or malvertisements on compromised legitimate websites redirect the end user to a malicious URL [4]. These take the form of ‘Fix It’ or fake CAPTCHA prompts [4].

From there, users are misled into believing they are completing a human verification step, registering a device, or fixing a non-existent issue such as a webpage display error. As a result, they are guided through a three-step process that ultimately enables the execution of malicious PowerShell commands:

  1. Open a Windows Run dialog box [press Windows Key + R]
  2. Automatically or manually copy and paste a malicious PowerShell command into the terminal [press CTRL+V]
  3. And run the prompt [press ‘Enter’] [2]

Once the malicious PowerShell command is executed, threat actors then establish command and control (C2) communication within the targeted environment before moving laterally through the network with the intent of obtaining and stealing sensitive data [4]. Malicious payloads associated with various malware families, such as XWorm, Lumma, and AsyncRAT, are often deployed [2][3].

Attack timeline of ClickFix cyber attack

Based on investigations conducted by Darktrace’s Threat Research team in early 2025, this blog highlights Darktrace’s capability to detect ClickFix baiting activity following initial access.

Darktrace’s coverage of a ClickFix attack chain

Darktrace identified multiple ClickFix attacks across customer environments in both Europe, the Middle East, and Africa (EMEA) and the United States. The following incident details a specific attack on a customer network that occurred on April 9, 2025.

Although the initial access phase of this specific attack occurred outside Darktrace’s visibility, other affected networks showed compromise beginning with phishing emails or fake CAPTCHA prompts that led users to execute malicious PowerShell commands.

Darktrace’s visibility into the compromise began when the threat actor initiated external communication with their C2 infrastructure, with Darktrace / NETWORK detecting the use of a new PowerShell user agent, indicating an attempt at remote code execution.

Darktrace / NETWORK's detection of a device making an HTTP connection with new PowerShell user agent, indicating PowerShell abuse for C2 communications.
Figure 1: Darktrace / NETWORK's detection of a device making an HTTP connection with new PowerShell user agent, indicating PowerShell abuse for C2 communications.

Download of Malicious Files for Lateral Movement

A few minutes later, the compromised device was observed downloading a numerically named file. Numeric files like this are often intentionally nondescript and associated with malware. In this case, the file name adhered to a specific pattern, matching the regular expression: /174(\d){7}/. Further investigation into the file revealed that it contained additional malicious code designed to further exploit remote services and gather device information.

Darktrace / NETWORK's detection of a numeric file, one minute after the new PowerShell User Agent alert.
Figure 2: Darktrace / NETWORK's detection of a numeric file, one minute after the new PowerShell User Agent alert.

The file contained a script that sent system information to a specified IP address using an HTTP POST request, which also processed the response. This process was verified through packet capture (PCAP) analysis conducted by the Darktrace Threat Research team.

By analyzing the body content of the HTTP GET request, it was observed that the command converts the current time to Unix epoch time format (i.e., 9 April 2025 13:26:40 GMT), resulting in an additional numeric file observed in the URI: /1744205200.

PCAP highlighting the HTTP GET request that sends information to the specific IP, 193.36.38[.]237, which then generates another numeric file titled per the current time.
Figure 3: PCAP highlighting the HTTP GET request that sends information to the specific IP, 193.36.38[.]237, which then generates another numeric file titled per the current time.

Across Darktrace’s investigations into other customers' affected by ClickFix campaigns, both internal information discovery events and further execution of malicious code were observed.

Data Exfiltration

By following the HTTP stream in the same PCAP, the Darktrace Threat Research Team assessed the activity as indicative of data exfiltration involving system and device information to the same command-and-control (C2) endpoint, , 193.36.38[.]237. This endpoint was flagged as malicious by multiple open-source intelligence (OSINT) vendors [5].

PCAP highlighting HTTP POST connection with the numeric file per the URI /1744205200 that indicates data exfiltration to 193.36.38[.]237.
Figure 4: PCAP highlighting HTTP POST connection with the numeric file per the URI /1744205200 that indicates data exfiltration to 193.36.38[.]237.

Further analysis of Darktrace’s Advanced Search logs showed that the attacker’s malicious code scanned for internal system information, which was then sent to a C2 server via an HTTP POST request, indicating data exfiltration

Advanced Search further highlights Darktrace's observation of the HTTP POST request, with the second numeric file representing data exfiltration.
Figure 5: Advanced Search further highlights Darktrace's observation of the HTTP POST request, with the second numeric file representing data exfiltration.

Actions on objectives

Around ten minutes after the initial C2 communications, the compromised device was observed connecting to an additional rare endpoint, 188.34.195[.]44. Further analysis of this endpoint confirmed its association with ClickFix campaigns, with several OSINT vendors linking it to previously reported attacks [6].

In the final HTTP POST request made by the device, Darktrace detected a file at the URI /init1234 in the connection logs to the malicious endpoint 188.34.195[.]44, likely depicting the successful completion of the attack’s objective, automated data egress to a ClickFix C2 server.

Darktrace / NETWORK grouped together the observed indicators of compromise (IoCs) on the compromised device and triggered an Enhanced Monitoring model alert, a high-priority detection model designed to identify activity indicative of the early stages of an attack. These models are monitored and triaged 24/7 by Darktrace’s Security Operations Center (SOC) as part of the Managed Threat Detection service, ensuring customers are promptly notified of malicious activity as soon as it emerges.

Darktrace correlated the separate malicious connections that pertained to a single campaign.
Figure 6: Darktrace correlated the separate malicious connections that pertained to a single campaign.

Darktrace Autonomous Response

In the incident outlined above, Darktrace was not configured in Autonomous Response mode. As a result, while actions to block specific connections were suggested, they had to be manually implemented by the customer’s security team. Due to the speed of the attack, this need for manual intervention allowed the threat to escalate without interruption.

However, in a different example, Autonomous Response was fully enabled, allowing Darktrace to immediately block connections to the malicious endpoint (138.199.156[.]22) just one second after the initial connection in which a numerically named file was downloaded [7].

Darktrace Autonomous Response blocked connections to a suspicious endpoint following the observation of the numeric file download.
Figure 7: Darktrace Autonomous Response blocked connections to a suspicious endpoint following the observation of the numeric file download.

This customer was also subscribed to our Managed Detection and Response service, Darktrace’s SOC extended a ‘Quarantine Device’ action that had already been autonomously applied in order to buy their security team additional time for remediation.

Autonomous Response blocked connections to malicious endpoints, including 138.199.156[.]22, 185.250.151[.]155, and rkuagqnmnypetvf[.]top, and also quarantined the affected device. These actions were later manually reinforced by the Darktrace SOC.
Figure 8: Autonomous Response blocked connections to malicious endpoints, including 138.199.156[.]22, 185.250.151[.]155, and rkuagqnmnypetvf[.]top, and also quarantined the affected device. These actions were later manually reinforced by the Darktrace SOC.

Conclusion

ClickFix baiting is a widely used tactic in which threat actors exploit human error to bypass security defenses. By tricking end point users into performing seemingly harmless, everyday actions, attackers gain initial access to systems where they can access and exfiltrate sensitive data.

Darktrace’s anomaly-based approach to threat detection identifies early indicators of targeted attacks without relying on prior knowledge or IoCs. By continuously learning each device’s unique pattern of life, Darktrace detects subtle deviations that may signal a compromise. In this case, Darktrace's Autonomous Response, when operating in a fully autonomous mode, was able to swiftly contain the threat before it could progress further along the attack lifecycle.

Credit to Keanna Grelicha (Cyber Analyst) and Jennifer Beckett (Cyber Analyst)

Appendices

NETWORK Models

  • Device / New PowerShell User Agent
  • Anomalous Connection / New User Agent to IP Without Hostname
  • Anomalous Connection / Posting HTTP to IP Without Hostname
  • Anomalous Connection / Powershell to Rare External
  • Device / Suspicious Domain
  • Device / New User Agent and New IP
  • Anomalous File / New User Agent Followed By Numeric File Download (Enhanced Monitoring Model)
  • Device / Initial Attack Chain Activity (Enhanced Monitoring Model)

Autonomous Response Models

  • Antigena / Network::Significant Anomaly::Antigena Significant Anomaly from Client Block
  • Antigena / Network::Significant Anomaly::Antigena Enhanced Monitoring from Client Block
  • Antigena / Network::External Threat::Antigena File then New Outbound Block
  • Antigena / Network::External Threat::Antigena Suspicious File Block
  • Antigena / Network::Significant Anomaly::Antigena Alerts Over Time Block
  • Antigena / Network::External Threat::Antigena Suspicious File Block

IoC - Type - Description + Confidence

·       141.193.213[.]11 – IP address – Possible C2 Infrastructure

·       141.193.213[.]10 – IP address – Possible C2 Infrastructure

·       64.94.84[.]217 – IP address – Possible C2 Infrastructure

·       138.199.156[.]22 – IP address – C2 server

·       94.181.229[.]250 – IP address – Possible C2 Infrastructure

·       216.245.184[.]181 – IP address – Possible C2 Infrastructure

·       212.237.217[.]182 – IP address – Possible C2 Infrastructure

·       168.119.96[.]41 – IP address – Possible C2 Infrastructure

·       193.36.38[.]237 – IP address – C2 server

·       188.34.195[.]44 – IP address – C2 server

·       205.196.186[.]70 – IP address – Possible C2 Infrastructure

·       rkuagqnmnypetvf[.]top – Hostname – C2 server

·       shorturl[.]at/UB6E6 – Hostname – Possible C2 Infrastructure

·       tlgrm-redirect[.]icu – Hostname – Possible C2 Infrastructure

·       diagnostics.medgenome[.]com – Hostname – Compromised Website

·       /1741714208 – URI – Possible malicious file

·       /1741718928 – URI – Possible malicious file

·       /1743871488 – URI – Possible malicious file

·       /1741200416 – URI – Possible malicious file

·       /1741356624 – URI – Possible malicious file

·       /ttt – URI – Possible malicious file

·       /1741965536 – URI – Possible malicious file

·       /1.txt – URI – Possible malicious file

·       /1744205184 – URI – Possible malicious file

·       /1744139920 – URI – Possible malicious file

·       /1744134352 – URI – Possible malicious file

·       /1744125600 – URI – Possible malicious file

·       /1[.]php?s=527 – URI – Possible malicious file

·       34ff2f72c191434ce5f20ebc1a7e823794ac69bba9df70721829d66e7196b044 – SHA-256 Hash – Possible malicious file

·       10a5eab3eef36e75bd3139fe3a3c760f54be33e3 – SHA-1 Hash – Possible malicious file

MITRE ATT&CK Mapping

Tactic – Technique – Sub-Technique  

Spearphishing Link - INITIAL ACCESS - T1566.002 - T1566

Drive-by Compromise - INITIAL ACCESS - T1189

PowerShell - EXECUTION - T1059.001 - T1059

Exploitation of Remote Services - LATERAL MOVEMENT - T1210

Web Protocols - COMMAND AND CONTROL - T1071.001 - T1071

Automated Exfiltration - EXFILTRATION - T1020 - T1020.001

References

[1] https://www.logpoint.com/en/blog/emerging-threats/clickfix-another-deceptive-social-engineering-technique/

[2] https://www.proofpoint.com/us/blog/threat-insight/security-brief-clickfix-social-engineering-technique-floods-threat-landscape

[3] https://cyberresilience.com/threatonomics/understanding-the-clickfix-attack/

[4] https://www.group-ib.com/blog/clickfix-the-social-engineering-technique-hackers-use-to-manipulate-victims/

[5] https://www.virustotal.com/gui/ip-address/193.36.38.237/detection

[6] https://www.virustotal.com/gui/ip-address/188.34.195.44/community

[7] https://www.virustotal.com/gui/ip-address/138.199.156.22/detection

Continue reading
About the author
Keanna Grelicha
Cyber Analyst
Your data. Our AI.
Elevate your network security with Darktrace AI