The NCA’s Essential Cybersecurity Controls (ECC) represent one of the most comprehensive national cybersecurity frameworks in the Middle East. Updated to ECC-2:2024, it now covers 5 domains, 29 subdomains, and 114 controls — and enforcement is real.
If you’re a Saudi organization (government entity, critical infrastructure operator, or their vendors), this isn’t guidance. It’s mandatory.
Understanding ECC’s Structure
ECC follows a logical hierarchy that, once understood, makes implementation significantly more tractable:
The Five Domains
- Cybersecurity Governance — Strategy, policies, roles, risk management
- Cybersecurity Defense — Asset management, identity, network, app, and data security
- Cybersecurity Resilience — Business continuity, disaster recovery, incident response
- Third-Party & Cloud Cybersecurity — Vendor management, cloud security, outsourcing
- Industrial Control Systems (ICS) Cybersecurity — OT-specific controls
The Implementation Roadmap
Based on dozens of ECC implementations across Saudi entities, here’s the phased approach that works:
Phase 1: Scoping & Gap Assessment (Weeks 1-4)
The most critical phase. Get this wrong, and everything downstream is wasted effort.
⚠️ Common Mistake: Applying all 114 controls uniformly. ECC has applicability criteria — not every control applies to every entity. ICS controls (Domain 5) only apply to organizations with operational technology. Cloud controls only apply if you use cloud services. Scope first, implement second.
Key activities:
- Identify applicable domains based on entity type and operations
- Map existing controls to ECC requirements (you’ll likely find 40-60% partial coverage)
- Prioritize gaps by risk severity, not control numbering
- Establish a compliance steering committee with executive sponsorship
Phase 2: Governance Foundation (Weeks 3-8)
Domain 1 controls form the foundation everything else rests on. Without governance, technical controls are unmanaged.
| Control | Requirement | Common Gap | Quick Win |
|---|---|---|---|
| 1-1-1 | Cybersecurity strategy | No documented strategy | Align with national cyber strategy |
| 1-2-1 | Cybersecurity roles | No dedicated CISO | Appoint CISO or vCISO, define RACI |
| 1-3-1 | Risk management | Risk register exists but outdated | Quarterly risk review cadence |
| 1-5-1 | Cybersecurity awareness | Annual training only | Monthly phishing simulations + role-based training |
Phase 3: Technical Implementation (Weeks 6-16)
This is where Domain 2 (Defense) comes alive. The key principle: don’t buy tools to satisfy controls — configure existing tools to produce evidence.
Most organizations already have 70%+ of the technical capabilities. They just haven’t documented them in ECC-aligned language.
💡 Pro Tip: Evidence-First Implementation
For each control, ask: “What evidence will NCA expect during assessment?” Then configure your systems to produce that evidence automatically. A SIEM that generates monthly access review reports is worth more than a perfectly configured SIEM with no reporting.
Phase 4: Resilience & Third-Party (Weeks 12-20)
Domain 3 (Resilience) and Domain 4 (Third-Party) are where organizations consistently underperform:
- Business continuity plans exist but haven’t been tested
- Incident response procedures are documented but the team has never rehearsed them
- Vendor security assessments are checkbox exercises with no follow-up
- Cloud security relies entirely on the CSP’s default configurations
The fix: tabletop exercises for BCP/IR (quarterly), vendor risk tiering with proportional assessment depth, and cloud security posture management tooling.
Phase 5: Continuous Compliance (Ongoing)
ECC isn’t a one-time exercise. NCA conducts periodic assessments, and compliance drift is real.
“The organizations that struggle most with NCA assessments aren’t the ones with gaps — it’s the ones who were compliant 12 months ago and assumed nothing changed.”
Build continuous monitoring into your program:
- Automated evidence collection (integrations with Active Directory, cloud platforms, SIEM)
- Monthly control effectiveness reviews
- Quarterly risk register updates
- Annual full reassessment against the latest ECC version
ECC + SAMA CSF: The Dual Compliance Challenge
Financial institutions in Saudi Arabia face a unique challenge: they must comply with both NCA ECC and SAMA Cybersecurity Framework. The good news? There’s approximately 70% overlap.
The bad news? The remaining 30% includes SAMA-specific requirements around transaction security, financial data protection, and sector-specific incident reporting that require dedicated attention.
Smart organizations map both frameworks simultaneously, implement shared controls once, and maintain separate evidence for framework-specific requirements.
The Path Forward
ECC compliance is a journey, not a destination. The organizations that succeed treat it as an opportunity to genuinely improve their security posture — not just a regulatory checkbox.
Start with governance, build technical controls on a solid foundation, and invest in automation early. The regulatory burden will only increase from here.
Complyan provides pre-built NCA ECC control libraries with automated mapping to SAMA CSF, ISO 27001, and NIST CSF. Reduce your implementation timeline from months to weeks with structured workflows, evidence management, and continuous compliance monitoring. Talk to our team →