Explore the key aspects of the NIS2 Directive, the latest EU cyber security legislation coming into effect in 2024. Learn how it impacts AI and security teams.
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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.
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The NIS2 Directive requires member states to adopt laws that will improve the cyber resilience of organizations within the EU. It impacts organizations that are “operators of essential services”. Under NIS 1, EU member states could choose what this meant. In an effort to ensure more consistent application, NIS2 has set out its own definition. It eliminates the distinction between operators of essential services and digital service providers from NIS1, instead defining a new list of sectors:
Energy (electricity, district heating and cooling, gas, oil, hydrogen)
Transport (air, rail, water, road)
Banking (credit institutions)
Financial market infrastructures
Health (healthcare providers and pharma companies)
Drinking water (suppliers and distributors)
Digital infrastructure (DNS, TLD registries, telcos, data center providers, etc.)
ICT service providers (B2B): MSSPs and managed service providers
Public administration (central and regional government institutions, as defined per member state)
Space
Postal and courier services
Waste management
Chemicals
Food
Manufacturing of medical devices
Computers and electronics
Machinery and equipment
Motor vehicles, trailers and semi-trailers and other transport equipment
Digital providers (online market places, online search engines, and social networking service platforms) and research organizations.
With these updates, it becomes harder to try and find industry segments not included within the scope. NIS2 represents legally binding cyber security requirements for a significant region and economy. Standout features that have garnered the most attention include the tight timelines associated with notification requirements. Under NIS 2, in-scope entities must submit an initial report or “early warning” to the competent national authority or computer security incident response team (CSIRT) within 24 hours from when the entity became aware of a significant incident. This is a new development from the first iteration of the Directive, which used more vague language of the need to notify authorities “without undue delay”.
Another aspect gaining attention is oversight and regulation – regulators are going to be empowered with significant investigation and supervision powers including on-site inspections.
The stakes are now higher, with the prospect of fines that are capped at €10 million or 2% of an offending organization’s annual worldwide turnover – whichever is greater. Added to that, the NIS2 Directive includes an explicit obligation to hold members of management bodies personally responsible for breaches of their duties to ensure compliance with NIS2 obligations – and members can be held personally liable.
The risk management measures introduced in the Directive are not altogether surprising – they reflect common best practices. Many organizations (especially those that are newly in scope for NIS2) may have to expand their cyber security capabilities, but there’s nothing controversial or alarming in the required measures. For organizations in this situation, there are various tools, best practices, and frameworks they can leverage. Darktrace in particular provides capabilities in the areas of visibility, incident handling, and reporting that can help.
NIS2 and Cyber AI
The use of AI is not an outright requirement within NIS2 – which may be down to lack of knowledge and expertise in the area, and/or the immaturity of the sector. The clue to this might be in the timing: the provisional agreement on the NIS2 text was reached in May 2022 – six months before ChatGPT and other open-source Generative AI tools propelled broader AI technology into the forefront of public consciousness. If the language were drafted today, it's not far-fetched to imagine AI being mentioned much more prominently and perhaps even becoming a requirement.
NIS2 does, however, very clearly recommend that “member states should encourage the use of any innovative technology, including artificial intelligence”[1]. Another section speaks directly to essential and important entities, saying that they should “evaluate their own cyber security capabilities, and where appropriate, pursue the integration of cyber security enhancing technologies, such as artificial intelligence or machine learning systems…”[2]
One of the recitals states that “member states should adopt policies on the promotion of active cyber protection”. Where active cyber protection is defined as “the prevention, detection, monitoring, analysis and mitigation of network security breaches in an active manner.”[3]
From a Darktrace perspective, our self-learning Cyber AI technology is precisely what enables our technology to deliver active cyber protection – protecting organizations and uplifting security teams at every stage of an incident lifecycle – from proactively hardening defenses before an attack is launched, to real-time threat detection and response, through to recovering quickly back to a state of good health.
The visibility provided by Darktrace is vital to understanding the effectiveness of policies and ensuring policy compliance. NIS2 also covers incident handling and business continuity, which Darktrace HEAL addresses through AI-enabled incident response, readiness reports, simulations, and secure collaborations.
Reporting is integral to NIS2 and organizations can leverage Darktrace’s incident reporting features to present the necessary technical details of an incident and provide a jump start to compiling a full report with business context and impact.
What’s next for NIS2
We don’t yet know the details for how EU member states will transpose NIS2 into national law – they have until 17th October 2024 to work this out. The Commission also commits to reviewing the functioning of the Directive every three years. Given how much our overall understanding and appreciation for not only the dangers of AI but also its power (perhaps even necessity in the realm of cyber security) is changing, we may see many member states will leverage the recitals’ references to AI in order to make a strong push if not a requirement that essential and important organizations within their jurisdiction leverage AI.
Organizations are starting to prepare now to meet the forthcoming legislation related to NIS2. Download our CISO’s Guide to NIS2 Preparedness, which includes everything you need to know to get ahead of the directive.
[1] (51) on page 11 [2] (89) on page 17 [3] (57) on page 12
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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.
Customer Case Study: Leading Petrochemical Manufacturer
Headquartered in Saudi Arabia, this industry leading petrochemical manufacturer serves customers in more than 80 countries across diverse markets throughout Europe, Africa, Latin America, the Middle East, China, and Southeast Asia.
Cyber resiliency critical to growth strategy
This leading petrochemical manufacturer’s vision is to be one of the major global players in the production and marketing of designated petrochemicals and downstream products. The company aims to significantly increase its capacity to up to a million metric tons within the next few years.
With cyber-attacks on critical infrastructure increasing 30% globally last year, cyber resiliency is essential to supporting the company’s strategic business goals of:
Maximizing production through efficient asset utilization
Maximizing sales by conducting 90% of its business outside Saudi Arabia
Optimizing resources and processes by integrating with UN Global Compact principles for sustainability and efficiency
Growing its business portfolio by engaging in joint ventures to diversify production and add value to the economy
However, the industry leader faced several challenges in its drive to fortify its cybersecurity defenses.
Visibility gaps delay response time
The company’s existing security setup provided limited visibility to the in-house security team, hindering its ability to detect anomalous network and user activity in real time. This resulted in delayed responses to potential incidents, making proactive issue resolution difficult and any remediation in the event of a successful attack costly and time-consuming.
Manual detection drains resources
Without automated detection and response capabilities, the organization’s security team had to manually monitor for suspicious activity – a time-consuming and inefficient approach that strained resources and left the organization vulnerable. This made it difficult for the team to stay current with training or acquire new skills and certifications, which are core to the ethos of both the company’s owners and the team itself.
Cyber-attacks on critical infrastructure increasing
The petrochemical manufacturer is part of a broader ecosystem of companies, making the protection of its supply chain – both upstream and downstream – critical. With several manufacturing entities and multiple locations, the customer’s internal structure is complex and challenging to secure. As cyber-attacks on critical infrastructure escalate, it needed a more comprehensive approach to safeguard its business and the wider ecosystem.
Keeping and growing skills and focus in-house
To strengthen its cybersecurity strategy, the company considered two options:
Make a significant initial and ongoing investment in a Security Operations Center (SOC), which would involve skills development outside the company and substantial management overhead.
Use a combination of new, automated tools and an outsourced Managed Detection and Response (MDR) service to reduce the burden on internal security specialists and allow the company to invest in upskilling its staff so they can focus on more strategic tasks.
Faced with this choice between entirely outsourcing security and augmenting the security team with new capabilities, the customer chose the second option, selecting Darktrace to automate the company’s monitoring, detection, and response. Today, the petrochemical manufacturer is using:
To alleviate the burden on its lean security team, the company augmented its in-house capabilities with Darktrace’s Managed Detection & Response service. This support acts as an extension of its SOC, providing 24/7 monitoring, investigation, and escalation of high-priority threats. With Darktrace’s global SOC managing alert triage and autonomously containing threats, the organization’s internal team can focus on strategic initiatives. The result is a stronger security posture and increased capacity to proactively address evolving cyber risks – without expanding headcount or sacrificing visibility.
A unique approach to AI
In its search for a new security platform, the company’s Director of Information Technology said Darktrace’s autonomous response capability, coupled with Self-Learning AI-driven threat reduction, were two big reasons for selecting Darktrace over competing products and services.
AI was a huge factor – no one else was doing what Darktrace was doing with [AI].”
Demonstrated visibility
Before Darktrace, the customer had no visibility into the network activity to and from remote worker devices. Some employees need the ability to connect to its networks at any time and from any location, including the Director of Information Technology. The trial deployment of Darktrace / ENDPOINT was a success and gave the team peace of mind that, no matter the location or device, high-value remote workers were protected by Darktrace.
Modular architecture
Darktrace's modular architecture allowed the company to deploy security controls across its complex, multi-entity environment. The company’s different locations run on segregated networks but are still interconnected and need to be protected. Darktrace / NETWORK provides a unified view and coordinated security response across the organization’s entire network infrastructure, including endpoint devices.
Results
The petrochemical manufacturer is using Darktrace across all of its locations and has achieved total visibility across network and user activity. “Darktrace is increasing in value every day,” said the Director of Information Technology.
I don’t have a big team, and Darktrace makes our lives very, very easy, not least the automation of some of the tasks that require constant manual review.”
Time savings frees analysts to focus on proactive security
Darktrace / NETWORK provides continuous, AI-driven monitoring and analysis of the company’s network activity, user behavior, and threat patterns, establishing a baseline of what normal activity looks like, and then alerting analysts to any deviations from normal traffic, activity, and behaviors. Darktrace’s autonomous response capabilities speed up response to detected threats, meaning intervention from the security team is required for fewer incidents and alerts.
In October 2024 alone, Darktrace Cyber AI Analyst saved the team 810 investigation hours, and autonomously responded to 180 anomalous behaviors that were uncovered during the investigations. With Darktrace managing the majority of threat detection and response efforts, the security team has been able to change its day-to-day activity from manual review of traffic and alerts and belated response to activity, to proactively fortifying its detection and response posture and upskilling to meet evolving requirements.
Layered email protection reduces phishing threats
The company’s email infrastructure posed a challenge due to petrochemical industry regulations requiring on-premises email servers, with some security delivered via Microsoft Azure. By integrating Darktrace / EMAIL into the Azure stack, the organization has reduced the volume of phishing emails its users receive by 5%.
“Now we have one more layer of security related to email – every email goes through two filters. If something is not being caught or traced by Azure, it is being detected by Darktrace,” said the Director of Information Technology. “As a result, we’re now seeing only about 15% to 20% of the phishing emails we used to receive before implementing Darktrace.”
Preparing for a secure future
The time saved using Darktrace has helped the security team take proactive steps, including preparing for new cyber resilience regulations for Saudi Arabia’s Critical National Infrastructure, as mandated by the National Cybersecurity Authority (NCA).
“The team now has ample time to prepare policies and procedures that meet the new NCA regulations and, in some cases, enhance the requirements of the new law,” said the Director of Information Technology. “All of this is possible because they don’t need to keep watch; Darktrace takes on so much of that task for them.”
Tracking CVE-2025-31324: Darktrace’s detection of SAP Netweaver exploitation before and after disclosure
Introduction: Exploiting SAP platforms
Global enterprises depend extensively on SAP platforms, such as SAP NetWeaver and Visual Composer, to run critical business processes worldwide. These systems; however, are increasingly appealing targets for well-resourced adversaries:
In March 2025, CISA issued an alert confirming active exploitation of a 2017 SAP NetWeaver vulnerability (CVE‑2017‑12637), enabling attackers to perform directory traversal and exfiltrate sensitive files, including credentials, from internet-facing systems
CVE-2025-31324 affects SAP’s NetWeaver Visual Composer, a web-based software modeling tool. SAP NetWeaver is an application server and development platform that runs and connects SAP and non-SAP applications across different technologies [2]. It is commonly used by process specialists to develop application components without coding in government agencies, large enterprises, and by critical infrastructure operators [4].
CVE-2025-31324 affects SAP’s Netweaver Visual Composer Framework 7.1x (all SPS) and above [4]. The vulnerability in a Java Servlet (/irj/servlet_jsp) would enable an unauthorized actor to upload arbitrary files to the /developmentserver/metadatauploader endpoint, potentially resulting in remote code execution (RCE) and full system compromise [3]. The issue stems from an improper authentication and authorization check in the SAP NetWeaver Application Server Java systems [4].
What is the severity rating of CVE-2025-31324?
The vulnerability, first disclosed on April 24, 2025, carries the highest severity rating (CVSS v3 score: 10.0) and could allow remote attackers to upload malicious files without requiring authentication [1][5]. Although SAP released a workaround on April 8, many organizations are hesitant to take their business-critical SAP NetWeaver systems offline, leaving them exposed to potential exploitation [2].
How is CVE-2025-31324 exploited?
The vulnerability is exploitable by sending specifically crafted GET, POST, or HEAD HTTP requests to the /developmentserver/metadatauploader URL using either HTTP or HTTPS. Attackers have been seen uploading malicious files (.jsp, .java, or .class files to paths containing “\irj\servlet_jsp\irj\”), most of them being web shells, to publicly accessible SAP NetWeaver systems.
External researchers observed reconnaissance activity targeting this vulnerability in late January 2025, followed by a surge in exploitation attempts in February. The first confirmed compromise was reported in March [4].
Multiple threat actors have reportedly targeted the vulnerability, including Chinese Advanced Persistent Threats (APTs) groups Chaya_004 [7], UNC5221, UNC5174, and CL-STA-0048 [8], as well as ransomware groups like RansomEXX, also known as Storm-2460, BianLian [4] or Qilin [6] (the latter two share the same indicators of compromise (IoCs)).
Following the initial workaround published on April 8, SAP released a security update addressing CVE-2025-31324 and subsequently issued a patch on May 13 (Security Note 3604119) to resolve the root cause of the vulnerability [4].
Darktrace’s coverage of CVE-2025-31324 exploitation
Darktrace has observed activity indicative of threat actors exploiting CVE-2025-31324, including one instance detected before the vulnerability was publicly disclosed.
In April 2025, the Darktrace Threat Research team investigated activity related to the CVE-2025-31324 on SAP devices and identified two cases suggesting active exploitation of the vulnerability. One case was detected prior to the public disclosure of the vulnerability, and the other just two days after it was published.
Early detection of CVE 2025-31324 by Darktrace
Figure 1: Timeline of events for an internet-facing system, believed to be a SAP device, exhibiting activity indicative of CVE-2025-31324 exploitation.
On April 18, six days prior to the public disclosure of CVE-2025-31324, Darktrace began to detect unusual activity on a device belonging to a logistics organization in the Europe, the Middle East and Africa (EMEA) region. Multiple IoCs observed during this incident have since been linked via OSINT to the exploitation of CVE-2025-31324. Notably, however, this reporting was not available at the time of detection, highlighting Darktrace’s ability to detect threats agnostically, without relying on threat intelligence.
The device was observed making domain name resolution request for the Out-of-Band Application Security Testing (OAST) domain cvvr9gl9namk9u955tsgaxy3upyezhnm6.oast[.]online. OAST is often used by security teams to test if exploitable vulnerabilities exist in a web application but can similarly be used by threat actors for the same purpose [9].
Four days later, on April 22, Darktrace observed the same device, an internet-facing system believed to be a SAP device, downloading multiple executable (.exe) files from several Amazon Simple Storage Service (S3). Darktrace’s Threat Research team later found these files to be associated with the KrustyLoader malware [23][24][25].
KrustyLoader is known to be associated with the Chinese threat actor UNC5221, also known as UTA0178, which has been reported to aggressively target devices exposed to the internet [10] [14] [15]. It is an initial-stage malware which downloads and launches a second-stage payload – Sliver C2. Sliver is a similar tool to Cobalt Strike (an open-source post-exploitation toolkit). It is used for command-and-control (C2) connections [11][12]13]. After its successful download, KrustyLoader deletes itself to evade detection. It has been reported that multiple Chinese APT groups have deployed KrustyLoader on SAP Netweaver systems post-compromise [8].
The actors behind KrustyLoader have also been associated with the exploitation of zero-day vulnerabilities in other enterprise systems, including Ivanti devices [12]. Notably, in this case, one of the Amazon S3 domains observed (abode-dashboard-media.s3.ap-south-1.amazonaws[.]com ) had previously been investigated by Darktrace’s Threat Research team as part of their investigation into Ivanti Connect Secure (CS) and Policy Secure (PS) appliances.
In addition to the download of known malicious files, Darktrace also detected new IoCs, including several executable files that could not be attributed to any known malware families or previous attacks, and for which no corresponding OSINT reporting was available.
Post-CVE publication detection
Exploit Validation
Between April 27 and 29, Darktrace observed unusual activity from an SAP device on the network of a manufacturing customer in EMEA.
Figure 2: Darktrace / NETWORK’s detection of an SAP device performing a large volume of suspicious activity between April 27 and April 29.
The device was observed making DNS requests for OAST domains (e.g. aaaaaaaa.d06qqn7pu5a6u25tv9q08p5xhbjzw33ge.oast[.]online and aaaaaaaaaaa.d07j2htekalm3139uk2gowmxuhapkijtp.oast[.]pro), suggesting that a threat actor was testing for exploit validation [9].
Figure 3: Darktrace / NETWORK’s detection of a SAP device making suspicious domain name resolution requests for multiple OAST domains.
Privilege escalation tool download attempt
One day later, Darktrace observed the same device attempting to download an executable file from hxxp://23.95.123[.]5:666/xmrigCCall/s.exe (SHA-1 file hash: e007edd4688c5f94a714fee036590a11684d6a3a).
Darktrace / NETWORK identified the user agents Microsoft-CryptoAPI/10.0 and CertUtil URL Agent during the connections to 23.95.123[.]5. The connections were made over port 666, which is not typically used for HTTP connections.
Multiple open-source intelligence (OSINT) vendors have identified the executable file as either JuicyPotato or SweetPotato, both Windows privilege escalation tools[16][17][18][19]. The file hash and the unusual external endpoint have been associated with the Chinese APT group Gelsemium in the past, however, many threat actors are known to leverage this tool in their attacks [20] [21].
Figure 4: Darktrace’s Cyber AI Analyst’s detection of a SAP device downloading a suspicious executable file from hxxp://23.95.123[.]5:666/xmrigCCall/s.exe on April 28, 2025.
Darktrace deemed this activity highly suspicious and triggered an Enhanced Monitoring model alert, a high-priority security model designed to detect activity likely indicative of compromise. As the customer was subscribed to the Managed Threat Detection service, Darktrace’s Security Operations Centre (SOC) promptly investigated the alert and notified the customer for swift remediation. Additionally, Darktrace’s Autonomous Response capability automatically blocked connections to the suspicious IP, 23.95.123[.]5, effectively containing the compromise in its early stages.
Figure 5: Actions taken by Darktrace’s Autonomous Response to block connections to the suspicious external endpoint 23.95.123[.]5. This event log shows that the connections to 23.95.123[.]5 were made over a rare destination port for the HTTP protocol and that new user agents were used during the connections.
Conclusion
The exploitation of CVE-2025-31324 to compromise SAP NetWeaver systems highlights the persistent threat posed by vulnerabilities in public-facing assets. In this case, threat actors leveraged the flaw to gain an initial foothold, followed by attempts to deploy malware linked to groups affiliated with China [8][20].
Crucially, Darktrace demonstrated its ability to detect and respond to emerging threats even before they are publicly disclosed. Six days prior to the public disclosure of CVE-2025-31324, Darktrace detected unusual activity on a device believed to be a SAP system, which ultimately represented an early detection of the CVE. This detection was made possible through Darktrace’s behavioral analysis and anomaly detection, allowing it to recognize unexpected deviations in device behavior without relying on signatures, rules or known IoCs. Combined with its Autonomous Response capability, this allowed for immediate containment of suspicious activity, giving security teams valuable time to investigate and mitigate the threat.
Credit to Signe Zaharka (Principal Cyber Analyst), Emily Megan Lim, (Senior Cyber Analyst) and Ryan Traill (Analyst Content Lead)
Appendices
List of IoCs
23.95.123[.]5:666/xmrigCCall/s.exe - URL- JuicyPotato/SweetPotato - high confidence
29274ca90e6dcf5ae4762739fcbadf01- MD5 file hash - JuicyPotato/SweetPotato - high confidence