Communication Action Plan Cybersecurity Hospitals and Healthcare Providers KLJVQz3cK3Qwcx0TtzYLX6JSH8 111664
Communication Action Plan Cybersecurity Hospitals and Healthcare Providers KLJVQz3cK3Qwcx0TtzYLX6JSH8 111664
COMMISSION
Brussels, 15.1.2025
COM(2025) 10 final
EN EN
1. Introduction
The EU’s security environment is rapidly changing, with an escalation of hybrid attacks and cyberattacks
that aim to destabilise our society, seeking division and disruption but also profits from cybercrime.
Europe must therefore urgently strengthen its preparedness for and resilience against this new reality,
across all sectors and in line with a ‘whole-of-society’ and ‘whole-of-government’ approach, as called
for in the report by the Special Adviser to the President of the European Commission, Sauli Niinistö.
Secure and resilient healthcare systems are a cornerstone of the EU’s social model. However, hospitals
and healthcare systems are facing mounting threats, particularly from ransomware gangs targeting them
for financial gain, driven by the high value of patient data, including electronic health records. The health
sector has indeed become the most attacked industry in the EU over the past four years, including during
the COVID-19 pandemic when health infrastructure was increasingly targeted by cyberattacks.
Cyberattacks on hospitals and healthcare providers are causing direct harm to people, delaying medical
procedures, causing gridlocks in emergency rooms and could, in extreme cases, lead to the loss of life.
The stakes are even higher as the sector undergoes a vital digital transformation. Digital health and the
use and reuse of health data can enable models of care better suited to people and patients’ needs and
preferences, by preventing the onset of disease or enabling earlier treatment. The integration of digital
tools and solutions in clinical processes as well as the use and reuse of health data can inform better
clinical decisions, contribute to automation in health as well as to faster and better patient care. Digital
tools, data usage, and medical devices – which are often connected to the internet and powered by
artificial intelligence (AI) – are also key to address challenges such as the shortage of healthcare
professionals.
At the same time, digital tools also expand the potential targets for cybercriminals. Moreover, certain
state actors do not shy away from targeting healthcare facilities, as witnessed by Russia’s ongoing war
of aggression against Ukraine. This makes the sector a potential target for cyberattacks as part of a wider
hybrid campaign. Cyberattacks not only jeopardise patient safety but also erode public trust in health
infrastructure and come with significant recovery costs. Beyond guarding against cyberattacks, a resilient
and secure digital infrastructure is also essential for supporting the implementation and full deployment
of the European Health Data Space1 (EHDS).
Therefore, it is time to level up and strengthen the cybersecurity and resilience of Europe’s hospitals and
healthcare providers, as emphasised by President von der Leyen in her Political Guidelines for the 2024-
2029 Commission2. This action plan responds to the urgency of the situation and the unique threats facing
the sector. There is no simple ‘silver bullet’ solution to the cybersecurity challenges in healthcare.
Instead, the action plan calls for strengthened prevention, preparedness, and a more coordinated approach
to solidarity while tapping into the expertise of the European cybersecurity industry. As such, the action
plan reflects the EU approach to security that will be further developed and formalised in the upcoming
European Internal Security Strategy, defining comprehensive response to face all internal security threats
1
https://www.consilium.europa.eu/en/press/press-releases/2024/03/15/european-health-data-space-council-and-parliament-
strike-provisional-deal/
2
https://commission.europa.eu/document/e6cd4328-673c-4e7a-8683-f63ffb2cf648_en
1
and focussing on the capacity to anticipate threats, to prevent harm and protect people, acting at all levels
with a whole-of-society approach.
The health sector includes a broad number of entities and actors, comprising hospitals, clinics, care
homes, rehabilitation centres and various healthcare providers, alongside the pharmaceutical, medical
and biotechnology industry, medical devices manufacturers, and health research institutions. This action
plan predominantly focuses on the cybersecurity of hospitals and healthcare providers, understood as
any natural or legal person – or any other entity – legally providing healthcare on the territory of a
Member State3. Hospitals and healthcare providers are interdependent with other health entities, and they
are closest to people. At the same time, measures to enhance the cybersecurity of hospitals and healthcare
providers should also address risks affecting the broader supply chain and ecosystem, stemming for
instance from entities that use health data for research and machine learning or that produce medical
devices, in particular digitally enabled medical devices that connect to the internet or other devices
(“internet of things”).
While securing health systems is primarily a national competence, health is also a critical sector under
the Directive on measures for a high common level of cybersecurity across the EU (NIS2)4.
Cybercriminals and other threat actors operate across borders, and the cybersecurity challenges faced by
healthcare organisations are also similar across Member States. Cooperation at the European level is
valuable for sharing and scaling up best EU-level and national practices. Therefore, the Action Plan
proposes EU-level coordination and measures, whilst also calling on Member States to take action to
make a difference for healthcare and the wider health ecosystem.
The focus of the Action Plan is on building the sector’s capacities to prevent cybersecurity incidents in
the first place, because prevention is always better than the cure. Secondly, the Action Plan details actions
to improve cybersecurity information-sharing and capability to detect cyber threats, allowing a faster
reaction. Thirdly, it provides measures to better respond to incidents, and to recover from them. Finally,
the Action Plan envisages ways to deter cyber threat actors from launching attacks against health systems
in Europe.
The Action Plan will be implemented hand in hand with healthcare providers and the wider health
ecosystem, Member States, and the cybersecurity community. A collaborative approach is key to further
defining and refining the most impactful actions so that all of Europe’s critical healthcare providers can
benefit from them. Therefore, this Communication will be accompanied by the launch of a
comprehensive consultation with stakeholders, industry and Member States.International cooperation is
important for cybersecurity due to the borderless and interconnected nature of cyberthreats. Comparable
cybersecurity threats are present also in the enlargement and neighbourhood countries and other EU
strategic partner countries. This can ultimately endanger the security of critical infrastructure in the EU.
It will therefore be important to reflect the lessons learned from implementing the Action Plan also in
3
Article 3, point (g), of Directive 2011/24/EU of the European Parliament and of the Council on the application of patients’
rights in cross-border healthcare, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:32011L0024
4
Directive (EU) 2022/2555 of the European Parliament and of the Council of 14 December 2022 on measures for a high
common level of cybersecurity across the Union (NIS 2 Directive), https://eur-lex.europa.eu/eli/dir/2022/2555
2
the EU’s cooperation with both enlargement and other partner countries, in light of the threat levels to
which they are respectively exposed.
5
Cybersecurity Ventures (1 June 2024): “Global Ransomware Damage Costs Predicted To Exceed $265 Billion By 2031”.
Available at https://cybersecurityventures.com/global-ransomware-damage-costs-predicted-to-reach-250-billion-usd-by-
2031/.
6
Regulation (EU) 2019/881 of the European Parliament and of the Council of 17 April 2019 on ENISA (the European
Union Agency for Cybersecurity) and on information and communications technology cybersecurity certification
(Cybersecurity Act), https://eur-lex.europa.eu/eli/reg/2019/881/oj/eng
7
ENISA Threat Landscape: Health Sector (July 2023).
8
ENISA Threat Landscape 2024.
9
ENISA Threat Landscape: Health Sector (July 2023). The report analysed healthcare providers, as well as other types of
organisations including organisations conducting health-related research, entities manufacturing certain health-related
products, health authorities, health insurance organisations, and residential treatment facilities and social services providers.
Available at https://www.enisa.europa.eu/publications/health-threat-landscape
10
European Commission: Joint Research Centre, Reina, V. and Griesinger, C., Cyber security in the health and medicine
sector – A study on available evidence of patient health consequences resulting from cyber incidents in healthcare settings,
Publications Office of the EU, 2024, https://data.europa.eu/doi/10.2760/693487
3
Moreover, ransomware attacks are often coupled with breaches of patient data 11, which often includes
sensitive health-related data and violates people’s fundamental right to protection of personal data.
At the same time, with the increasing digitalisation of healthcare, the attack surface is growing.
According to the Report on the State of the Digital Decade 2024, an average of 79% of EU citizens have
online access to their electronic health records in primary care12. Electronic health records, clinical
information systems, hospital workflow systems, IT systems for handling reimbursement of treatments,
medical imaging systems, and medical devices used for diagnostic purposes or for patient monitoring
are all examples of digital tools that can play a major role in boosting the efficiency and performance of
the health sector, but are also potential targets of a cybersecurity attack. Specific healthcare activities
such as intensive care and radiological imaging, or medical fields such as oncology and cardiology, that
are highly dependent on digitally enabled devices, are at a particular risk of cyberattacks. In addition,
supply chain issues may lead to the procurement of devices with insufficient cyber security, exacerbating
existing general risks.
For example, during the COVID-19 pandemic, a ransomware attack paralysed large parts of the Irish
health care system, leading to cancellation of at least some services at 31 of the 54 acute hospitals on the
morning of the incident.13 Health services had to revert to paper records, slowing down the efficiency of
operations. The attack originated from a phishing email containing a malicious attachment.14 The
incident demonstrated the potential of cyberattacks spreading across different systems, and consequently
the importance of protecting the entirety of a healthcare organisation’s attack surface. It also underlined
the importance of ensuring fundamental cyber hygiene and cybersecurity culture throughout
organisations.
11
According to the ENISA Threat Landscape for the Health Sector, breach or theft of data was confirmed in 43% of
ransomware incidents analysed.
12
Report on the State of the Digital Decade 2024
13
Irish Health Service Executive (2021): ‘Conti cyber attack on the HSE: Independent Post Incident Review’.
14
Irish Health Service Executive: ‘Cyber-attack and HSE response’. Available at https://www2.hse.ie/services/cyber-
attack/what-happened/.
4
serious damage and harm to patients even in small-scale healthcare facilities, including clinics or
emergency medical services which provide an essential service to a relatively low number of users.
According to the 2024 ENISA Report on the State of Cybersecurity in the Union15, the EU health sector’s
cybersecurity maturity is moderate and there are wide differences in the level of cybersecurity maturity
between healthcare entities across Europe. Deficiencies can be observed in key areas such as sufficient
human resources, organisations’ knowledge of their information and communications technology (ICT)
supply chains, and installation of up-to-date security features in products. The sector struggles with basic
cyber hygiene and fundamental security measures, as illustrated by the fact that nearly all health
organisations surveyed face challenges when it comes to performing cybersecurity risk assessments,
while almost half have never performed a risk analysis.16
Another significant challenge for the cybersecurity of hospitals is the intersection of information
technology (IT) and operational technology (OT), where different security priorities meet as regards
confidentiality, availability and reliability, and where a breach in one area can affect the other. The 2024
ENISA Report on the State of Cybersecurity in the Union further stresses that the health sector is not
performing adequately in ensuring the security of the ICT products and processes it uses, due to the large
variety of health entities, devices and products.
This diversity, combined with varying levels of cyber awareness among hospital staff and management,
creates a complex challenge for ensuring the cybersecurity of healthcare systems. For instance, according
to the 2024 Eurobarometer on Cyberskills, only 25% of surveyed companies in the health, education and
social care sector had provided training or awareness-raising about cybersecurity in the previous 12
months17. Action is needed to foster a culture of cybersecurity awareness among frontline healthcare
professionals. For example, staff rotations, use of shared workstations, poor authentication management
and the use of removable media are additional sources of vulnerabilities affecting healthcare providers’
cybersecurity18.
In many cases, IT and OT are at least partly outsourced. The 2024 Eurobarometer found that the share
of companies outsourcing at least some aspects of their cybersecurity is the highest in the health,
education and social care sector, with 57% of surveyed companies doing so19. Similarly, there is a strong
trend of migrating to cloud computing, driven by the need for scalable data storage and management,
cost efficiency, improved collaboration, and support for advanced technologies like AI and the Internet
of Medical Things. In 2022, 58% of health organisations used a cloud-based digital health platform20.
However, while this shift can bring significant efficiencies, it also entails risks that require informed
decisions about procurement and secure configuration.
15
ENISA: 2024 Report on the State of Cybersecurity in the Union (September 2024). Available at
https://www.enisa.europa.eu/publications/enisa-threat-landscape-2024
16
ENISA Threat Landscape: Health Sector (July 2023). Available at https://www.enisa.europa.eu/publications/health-threat-
landscape
17
Flash Eurobarometer 547 on Cyberskills (May 2024). Available at https://europa.eu/eurobarometer/surveys/detail/3176
18
Panacea – People-centric cybersecurity in healthcare (2021): White Paper – Lessons learnt from PANACEA on the cyber-
protection of hospitals and care centres.
19
Flash Eurobarometer 547 on Cyberskills.(May 2024). Available at https://europa.eu/eurobarometer/surveys/detail/3176
20
ENISA: NIS Investments Report 2022 (November 2022). Available at https://www.enisa.europa.eu/publications/nis-
investments-2022
5
Overarching all of these challenges is the question of capacity building and funding. Funding for
cybersecurity in the health sector has been limited and remains a universal challenge across the EU21.
Furthermore, these funding challenges arise against the background of an ageing population, which is
expected to create widespread budgetary pressures on Europe’s health systems in the coming decades.
The continued use of obsolete tools and legacy systems, limited resources to prevent or react to incidents,
and gaps in cybersecurity maturity often stem from funding shortfalls. Hospitals face a continuous
challenge to balance an up-to-date secure and digital infrastructure with other necessary investments to
improve patient care, such as hiring of doctors and other healthcare professionals, implementation of
novel diagnostic and treatment methods, and acquisition of devices. According to ENISA22, the health
sector ranks only 7th of the 12 sectors studied when it comes to the proportion of information security
spending out of the total IT spending, with 8.3% being the median in the health sector.
21
The organisation and delivery of health services and medical care is a national competence under Article 168 Treaty on the
Functioning of the European Union, and financing of healthcare systems varies across Member States.
22
ENISA: NIS Investments Report 2022 (November 2022). Available at https://www.enisa.europa.eu/publications/nis-
investments-2022.
23
In this document, “Support Centre” is used interchangeably.
24
Regulation (EU) 2019/881 of the European Parliament and of the Council of 17 April 2019 on ENISA (the European
Union Agency for Cybersecurity) and on information and communications technology cybersecurity certification and
repealing Regulation (EU) No 526/2013 (Cybersecurity Act), OJ L 151, 7.6.2019, p. 15–69.
6
Competence Centre (ECCC), will inform further actions at the EU level including the work of the
Support Centre.
Figure 1: Concepts for the Support Centre’s service catalogue for hospitals and healthcare providers
Basic cybersecurity measures, such as ensuring that systems are kept up to date, managing backups, and
implementing multi-factor authentication can, according to one estimate, protect organisations from up
7
to 98% of attacks25. Many of the most impactful cyber hygiene and risk-management measures are
relatively straightforward to adopt, making them a low-hanging fruit for improving cybersecurity. One
of the key roles of the Support Centre should therefore be to develop clear, targeted guidance that
highlights the most critical cybersecurity practices and aids healthcare providers in implementing
them. This support must extend beyond large hospitals to include tailored advice for smaller entities,
such as local General Practitioner’s offices and specialist clinics, which often lack the resources for
dedicated cybersecurity teams but remain equally vulnerable to attacks. Furthermore, it is necessary to
consider the regional importance of specific healthcare entities for ensuring patient care, for instance in
sparsely populated areas. Health research institutes that handle large amounts of sensitive personal data
could also benefit from receiving guidance on basic cybersecurity measures to enhance their resilience.
Healthcare organisations are also subject to a range of cybersecurity-related obligations stemming from
EU legislation26. While the obligations are crucial for ensuring a high common baseline for cyber and
data security, it is essential to ensure that the regulatory landscape is not needlessly difficult and
burdensome to navigate. A heavy focus on compliance should not run counter to the objective of fostering
a strong cybersecurity culture. An easy-access regulatory mapping tool can help minimise the
administrative burden for entities subject to multiple regulatory instruments. Along with
developing guidance and toolkits, the Support Centre should work closely with the Commission and
Member States to develop and disseminate such a tool as soon as possible. The Support Centre would
therefore play an important role in making cybersecurity rules simple to understand and to implement,
for instance by providing implementation guidance27 and where necessary promoting relevant standards.
The forthcoming European Digital Identity Wallets are another tool for facilitating simple
implementation of good cyber hygiene practices. Reducing the reliance on weak identification
mechanisms, such as passwords, is essential to mitigate the risks of unauthorised access to health data.
A shift towards secure sign-on solutions based on reliable identification is critical. The EU Digital
25
Microsoft Digital Defense Report 2022. Available from https://www.microsoft.com/en-us/security/security-
insider/intelligence-reports/microsoft-digital-defense-report-2022.
26
Such as the NIS2 Directive; Regulation (EU) 2024/2847 of the European Parliament and of the Council of 23 October
2024 on horizontal cybersecurity requirements for products with digital elements (Cyber Resilience Act), https://eur-
lex.europa.eu/eli/reg/2024/2847/oj/enghttps://eur-lex.europa.eu/eli/reg/2024/2847/oj/eng; Regulation (EU) 2017/745 of the
European Parliament and of the Council of 5 April 2017 on medical devices, https://eur-
lex.europa.eu/eli/reg/2017/745/oj/enghttps://eur-lex.europa.eu/eli/reg/2017/745/oj/eng (Medical Devices Regulation),
https://eur-lex.europa.eu/eli/reg/2017/745/oj/eng, the Medical Device Regulation; Regulation (EU) 2017/746 of the
European Parliament and of the Council of 5 April 2017 on in vitro diagnostic medical devices (In vitro diagnostic medical
devices Regulation), https://eur-lex.europa.eu/eli/reg/2017/746/oj/enghttps://eur-lex.europa.eu/eli/reg/2017/746/oj/eng;
Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural
persons with regard to the processing of personal data and on the free movement of such data (General Data Protection
Regulation), https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32016R0679https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX:32016R0679; Regulation (EU) 2024/1689 of the European Parliament and of the Council of
13 June 2024 laying down harmonised rules on artificial intelligence (Artificial Intelligence Act), https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R1689; Proposal for a REGULATION OF THE EUROPEAN
PARLIAMENT AND OF THE COUNCIL on the European Health Data Space, COM(2022)197 final, https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=celex:52022PC0197. Negotiations concluded with a political agreement in spring
2024 and, following finalisation, publication in the Official Journal is expected for spring 2025
27
The development of guidelines on the interpretation of the General Data Protection Regulation (GDPR) falls within the
responsibility of the European Data Protection Board (EDPB). The development of guidance by ENISA should fully respect
the EDPB’s prerogatives.
8
Identity Wallet offers a harmonised, EU-wide approach to electronic identification for healthcare
professionals, providing a robust and unified solution as of end of 2026. All online health information
systems required to implement strong user authentication will be obliged to accept the Wallet for
identification purposes as of the end of 202728.
28
Article 5(f)(1)–(2) of Regulation (EU) 910/2014.
29
European cyber crisis liaison organisation network
30
See the ENISA NIS Investments Report 2023 (November 2023), highlighting prominence of external support for
cybersecurity auditing and compliance. Available at https://www.enisa.europa.eu/publications/nis-investments-2023
9
threats and mitigating the risks associated with the misuse of emerging technologies. The resulting
deliverables include a suite of specialised tools, frameworks, and systems, such as risk assessment tools,
privacy-preserving data-sharing platforms, cryptographic solutions, cybersecurity awareness training
programmes, and real-time threat detection systems. Notably, these solutions have been rigorously
validated through real-world pilot implementations in healthcare environments, ensuring their
effectiveness and practical applicability in protecting against cyber threats.
31
Pursuant to Article 22 of the NIS2 Directive.
32
In a first step, as of 1 August 2025, broad categories of radio equipment, not falling within the scope of the Medical
Device Regulation and the Regulation on in vitro diagnostic medical devices, will be required to comply with the essential
requirements of the Radio Equipment Directive that relate to cybersecurity when they are placed in the Single Market. In a
second stage, as of 11 December 2027, the Cyber Resilience Act will enter into application.
33
In December 2019, the Medical Devices Cooperation Group issued guidance on cybersecurity for medical devices,
supporting manufacturers in fulfilling the requirements of Annex I of the two Regulations:
https://ec.europa.eu/docsroom/documents/41863.
34
Building on the 2020 ENISA Procurement Guidelines for Cybersecurity in Hospitals (February 2020). Available at
https://www.enisa.europa.eu/publications/good-practices-for-the-security-of-healthcare-services
10
For cloud, further action is needed to address the unique challenges of managing sensitive healthcare
data, including heightened security, privacy, and operational risks. To strengthen safeguards, experts
recommend embedding "Security by Default and by Design" into cloud services. This approach
prioritises secure infrastructure, proactive vulnerability management, and a mix of governmental and
private cloud solutions. Continuous monitoring and vendor-specific attestations—such as security
provider certifications and compliance audits with national and international standards—are also
essential for ensuring robust security practices.
For services like Infrastructure-as-a-Service (IaaS), Platform-as-a-Service (PaaS), and Software-as-a-
Service (SaaS), security implementation often falls to the customer. However, many healthcare
organisations lack the resources to meet these requirements independently. To address this, cloud service
providers should be encouraged to implement baseline security measures as a standard feature.
These measures would reduce the risk of misconfigurations, maintain consistent protection across
customer-managed environments, and provide greater assurance to users. Establishing a default security
baseline would aim to balance robust protection with practicality, ensuring usability for a wide range of
healthcare organisations. This effort would involve close collaboration between cloud providers and the
health sector, leveraging industry best practices to create effective and scalable solutions.
Having a workforce with in-demand skills is important for long-term sustainable growth and
competitiveness in Europe, as well as for high-quality services, including healthcare services. The
shortage of qualified cybersecurity professionals is a significant challenge across Europe, with an
estimated gap of 299,000 professionals to fill workforce needs in the EU35. According to the 2024
Eurobarometer on Cyberskills36, 81% of companies view difficulties in hiring cybersecurity staff as a
key risk for potential cyberattacks. In the education, health, and social work sectors, 66% of
cybersecurity roles are filled by employees transitioning from non-cybersecurity positions, highlighting
the urgent need for reskilling and upskilling.
To address this challenge, the Support Centre should collaborate with the future cybersecurity skills
European Digital Infrastructure Consortium (EDIC) foreseen in the Commission Communication on the
Cybersecurity Skills Academy37. The work should facilitate exchanges among cybersecurity
professionals in the health sector, such as Chief Information Security Officers (CISOs). One potential
action would be to create a European Health CISOs Network , starting with a pool of experts to share
and develop best practices, talent retention strategies, and solutions for attracting cybersecurity
professionals to the health sector. Furthermore, under the umbrella of the Cybersecurity Skills Academy,
resources should be developed to enhance the cybersecurity workforce in the health sector with the
35
The 2024 cybersecurity landscape: insights from the ISC2 cybersecurity workforce study | Digital Skills and Jobs
Platform
36
Flash Eurobarometer 547 on Cyberskills.
37
Communication from the Commission to the European Parliament and the Council: Closing the cybersecurity talent gap
to boost the EU’s competitiveness, growth and resilience (‘The Cybersecurity Skills Academy’). COM(2023) 207 final.
11
support of industry and academia. In this regard, industry stakeholders should be encouraged to pledge
support for enhancing cybersecurity training.
Incorporating digital competence and cybersecurity modules into educational curricula is crucial for
building a strong cybersecurity foundation in healthcare. These modules should address sector-specific
issues like patient-data protection and vulnerabilities in the security of medical devices. The development
of these resources should take into account prior actions, such as the BeWell project funded under the
Erasmus+ programme38 and the PANACEA project funded under Horizon 202039.
3.2.European capabilities for detecting cyber threats against the health sector
Effective cyber threat detection is essential for prompt response to incidents. Threat actors can leverage
techniques to make intrusions difficult to detect, enabling extended periods of unpermitted access to a
system40. Therefore, better threat detection capabilities can help stop cyberattacks in their tracks. For
example, in the ransomware attack against the Finnish psychotherapy service provider Vastaamo, during
which the perpetrator extorted patients whose confidential patient records were stolen, the initial
intrusion occurred in 2018, but only became known to the provider in 202041.
Efficient information sharing and collaboration are essential for enhancing threat detection and
situational awareness throughout the EU. Computer Security Incident Response Teams (CSIRTs) play a
vital role in receiving reports of incidents, near misses and potential threats, offering guidance on
mitigation measures at the national level. However, Member States are strongly encouraged to also
share all cyber incident notifications from hospitals and healthcare providers with ENISA’s
Support Centre to allow for EU situational awareness. Ideally, this should be accompanied by a
meaningful characterisation of various relevant incident dimensions, including known root
vulnerabilities and effects on healthcare services and patient adverse events. Furthermore, manufacturers
of medical and in vitro diagnostic devices are encouraged to voluntarily report, via the single reporting
platform to be established and managed by ENISA within the framework of the Cyber Resilience Act,
38
BeWell – Blueprint alliance for a future health workforce strategy on digital and green skills. Available from
https://bewell-project.eu/.
39
PANACEA – Protection and privAcy of hospital and health iNfrastructures with smArt Cyber sEcurity and cyber threat
toolkit for data and people. Available from https://cordis.europa.eu/project/id/826293.
40
ENISA Health Threat Landscape 2023.
41
Decision 1150/161/2021 of the Finnish Data Protection Ombudsman.
12
actively exploited vulnerabilities or severe cyber incidents having an impact on the security of these
devices, as well as potentially other vulnerabilities, incidents, near misses or cyber threats that may affect
the risk profile of these devices.
Where the information contained in the reports is no longer sensitive, the Support Centre could build up
an ENISA-sponsored European known exploited vulnerabilities (KEV) catalogue for medical devices,
electronic health record systems and providers of ICT equipment and software in health. To address
significant challenges of threat detection, the Support Centre should introduce an EU-wide early
warning subscription service for the health sector, delivering near-real-time alerts. This service
would draw on processed data from CSIRTs, healthcare entities and manufacturers, Open-Source
Intelligence (OSINT), and other relevant actors such as Cyber Hubs, Information Sharing and Analysis
Centres (ISACs) and law enforcement authorities. Enhanced cooperation between ENISA and the
European Union Agency for Law Enforcement Cooperation (Europol) – for example on patterns of
cybercrime against the health sector – would further boost situational awareness.
ISACs serve as central resources for cyber threat intelligence, fostering two-way information sharing
between the public and private sectors, and promoting trust-building. The Support Centre should step up
support for the European Health ISAC with tools and information exchange, sectorial situational
awareness reports, as well as fostering a trusted community for tactical and strategic collaboration.
Member States should encourage the development of national health ISACs42. The ISACs should also
be encouraged to bring together healthcare providers with manufacturers to give rise to a joint
understanding of cybersecurity threats, including in the supply chain, and facilitating a dialogue about
secure design of products that truly take into account the deployment realities on the ground.
Given the high sensitivity of patient health data and the potentially devastating effects of cyberattacks
on healthcare services, a swift and effective response to cybersecurity incidents is crucial to safeguarding
patient safety. When a hospital or healthcare provider faces a cyberattack, the first point of contact is the
relevant national CSIRT43. The CSIRT is responsible for providing timely support, ideally within 24
hours, to help manage significant incidents. However, if an incident exceeds the CSIRT’s capacity, EU
support should be available to ensure a swift and effective response.
The EU Cybersecurity Reserve, established under the Cyber Solidarity Act, provides incident response
services from trusted managed security providers to assist with significant or large-scale cybersecurity
incidents and initial recovery efforts. This reserve is designed to complement the efforts of Member
States’ CSIRTs, enabling them to request additional support in cases involving critical sectors like health.
42
For example, Finland has a national ISAC for the social welfare and health care sector. See Finnish National
Cybersecurity Centre: ‘ISAC information sharing groups’, available at https://www.kyberturvallisuuskeskus.fi/en/our-
services/situation-awareness-and-network-management/isac-information-sharing-groups.
43
Article 23(1) of the NIS2 Directive sets a requirement for essential and important entities to notify significant incidents to
the relevant CSIRT or, where applicable, competent authority.
13
To enhance this system, the Commission and ENISA should ensure that the Reserve includes a
Rapid Response Service specifically for the health sector. In complementarity with other existing
frameworks, this service would deploy experts to manage significant or large-scale cybersecurity
incidents in healthcare without delay when national support is insufficient.
To improve response and recovery, the Support Centre, in collaboration with the NIS Cooperation
Group, the CSIRTs Network and, where relevant, Europol, should develop cyber incident response
playbooks tailored for healthcare. These playbooks would guide both CSIRTs and healthcare
organisations in responding to specific cybersecurity threats, including ransomware. Given the
importance of effective cooperation among CSIRTs and law enforcement authorities in responding to
and investigating cybersecurity incidents of criminal nature, the playbooks should, among other aspects,
provide clear guidance on the reporting of such incidents to law enforcement. Furthermore, the Support
Centre could facilitate a wide roll-out of national cybersecurity exercises, building on experiences
from exercises like ENISA's Cyber Europe 2022 exercise, to test the playbooks and strengthen
incident response protocols.
To inform policies and assess the effectiveness of measures taken against ransomware attacks, it is
necessary to collect further data. To this effect, Member States should request entities subject to the NIS2
Directive, including healthcare organisations, to report on any ransom payments made and on ransom
payments they intend to make, alongside other information they provide when reporting on significant
cybersecurity incidents. Such reporting supports the effective investigation of ransomware incidents,
including the tracing of payments on cryptocurrency exchange platforms in order to identify the
recipients.
Recovery speed is a critical factor in maintaining resilience and public trust, particularly in healthcare,
where downtime can disrupt patient care. For effective recovery from ransomware attacks, healthcare
providers must have secure, up-to-date, and isolated backups that can be quickly restored. As part of its
service catalogue, the Support Centre could offer a ransomware recovery subscription service,
helping hospitals and healthcare providers prepare recovery plans in advance. ENISA and Europol
should collaborate to identify the most common ransomware strains targeting healthcare organisations
and expand the repository of decryption tools available through the No More Ransom project44. They
should also develop and promote accessible guidance to help healthcare providers avoid paying ransoms
by using decryption tools.
The International Counter Ransomware Initiative45 is a valuable arena for exchange on specific
ransomware incidents, as well as for building the capacities of member countries to strengthen their
cybersecurity frameworks and investigation capabilities against ransomware actors. The Commission,
working together with the High Representative, will continue to advance cooperation in the Counter
Ransomware Initiative, including against ransomware threats to the health sector. Moreover, the
Commission will seek cooperation in the G7 Cybersecurity Working Group, to strengthen the
cybersecurity of the health sector. In particular, the Working Group could consider possibilities to support
44
https://www.nomoreransom.org/en/index.html.
45
https://www.counter-ransomware.org/
14
the health sector against threats such as ransomware, building on reflections such as the Joint Statement
on Ransomware Attacks Against Healthcare Facilities of 8 November 2024 presented in the context of
the United Nations Security Council46.
4. National Actions
The capacity of this Action Plan to improve cybersecurity in the health sector hinges on the active
involvement and commitment of Member States. To successfully implement the Action Plan, Member
States could designate National Cybersecurity Support Centres specifically for hospitals and
healthcare providers. These centres would act as the primary points of contact for the health sector at
national level, collaborating closely with the ENISA Support Centre. Where possible and relevant,
Member States should designate existing bodies, such as national health CSIRTs or relevant authorities,
as National Cybersecurity Support Centres.
Member States are also encouraged to create national action plans focused on cybersecurity in the
health sector. These plans would outline the specific cybersecurity risks faced by healthcare systems
and the national actions being taken to address them, while also ensuring that European-level resources
and practices are effectively used. The ENISA Support Centre can assist in developing these plans, taking
into account already existing national plans and coordinating efforts to ensure that the resources and
strategies of individual Member States complement each other.
Another key focus for Member States is facilitating resource sharing among healthcare providers, which
could be achieved through joint procurement or pooled resources at the national, regional, or even
European level. This approach would reduce the financial burden on individual entities while increasing
their bargaining power with cybersecurity service providers.
For example, the French CaRE programme47 has introduced a number of measures at national and
regional level to address challenges in resourcing: a cyber catalogue provides an overview of cyber
solutions and packages made available to hospitals through the national cybersecurity agency, the digital
health agency, regional agencies, national purchasing organisations as well as commercial solutions. This
is complemented by additional funding for regional agencies to offer shared resources.
Member States should also address the insufficient levels of investment in cybersecurity within the health
sector. To ensure adequate funding, they should set non-binding benchmarks and monitor funding
targets aimed specifically at cybersecurity, while ensuring that these investments do not detract from
essential patient care. These funding targets should also aim to integrate security considerations into all
46
https://usun.usmission.gov/joint-statement-on-ransomware-attacks-against-healthcare-facilities/
47
French Digital Health Agency: Cybersécurité acceleration et Résilience des Établissements (CaRE). Available at
https://esante.gouv.fr/strategie-nationale/cybersecurite.
15
digital investments in the sector. Member States can exchange best practices and advice on these targets
through platforms such as the eHealth Network48.
5. Public-Private Cooperation
Public-private cooperation and consultation with healthcare providers, other health sector entities, as
well as relevant cybersecurity industry players, is essential for the successful implementation of the
Action Plan. To further feed into the work of the Support Centre, the Commission, supported by
ENISA, will set up a joint Health Cybersecurity Advisory Board with high-level representatives of
both fields, healthcare and cybersecurity, which can advise the Commission and the Support Centre on
impactful actions and discuss the further development of public-private partnerships in this field. The
board will build on existing efforts for public-private partnerships, including the European Health ISAC.
Furthermore, the Commission will launch a call for action for cybersecurity companies, foundations,
educational institutions, and industry stakeholders to pledge actions to address the challenges in the
sector. Building on the experience of the Cybersecurity Skills Academy, such commitments could be for
instance pledges under the Cybersecurity Skills Academy to include the provision of training courses
and materials with a focus on health sector for cybersecurity professionals49. Other commitments could
also address awareness raising activities or the provision of managed security services to specifically
vulnerable entities for free or at reduced cost in order to increase their preparedness and cybersecurity
resilience. Moreover, the commitments could consist in sharing cyber threat intelligence with the ENISA
Support Centre. The Support Centre should maintain an overview of pledges made under the call for
action, with the goal of ensuring their coherence and complementarity.
48
The eHealth Network is a voluntary network of national authorities responsible for eHealth designated by the Member
States and established under Article 14 of Directive 2011/24/EU.
49
Cyber Skills Academy: Get Involved | Digital Skills and Jobs Platform
16
Holding criminal actors accountable for their actions is an important deterrent. Therefore, Member States
should ensure that law enforcement is fully integrated into their national action plans. In particular, they
should make full use of the provisions under the Directive on attacks against information systems50 and
under the Council of Europe’s Budapest Convention on Cybercrime to deter attacks, bring criminals to
justice and to dismantle criminal infrastructures facilitating attacks51. Successful implementation of these
tools should ensure that criminal and malicious actions against healthcare are punished.
8. Next steps
This Communication has set out an ambitious agenda for a more cybersecure health sector in the EU.
With the proposed development of the Cybersecurity Support Centre for Hospitals and Healthcare
Providers at the heart of ENISA, the Action Plan sets out an avenue towards the creation of a coherent
and shared European approach to the challenge of cybersecurity in the sector.
50
Directive 2013/40/EU of the European Parliament and of the Council of 12 August 2013 on attacks against information
systems and replacing Council Framework Decision 2005/222/JHA: https://eur-lex.europa.eu/eli/dir/2013/40/oj/eng
51
The Convention on Cybercrime (Budapest Convention, ETS No. 185) and its Protocols:
https://www.coe.int/en/web/cybercrime/the-budapest-convention
52
ENISA, EU Cybersecurity Index, Framework and Methodological Note (2024). Available at
https://www.enisa.europa.eu/sites/default/files/2024-12/eu_csi_methodological_note_v1-0.pdf.
17
This Communication should be seen as the start of a process to improve cybersecurity in the health sector.
Therefore, the adoption of the Action Plan will be accompanied by the launch of comprehensive
stakeholder consultations and the continuation of exchanges with Member States and relevant networks
to collect insights. Based on the results of the consultations, the Commission intends to come forward
with recommendations in the fourth quarter of 2025 to further refine the Action Plan.
The Commission calls on Member States and all stakeholders to work together in delivering on the
ambition of the Action Plan.
18
ANNEX – Overview of proposed actions
The Commission:
Public-Private Cooperation
19
Counter Ransomware Initiative, working together
with the High Representative
Next steps
ENISA:
20
Design and promote training modules and courses for Q1 2026
healthcare professionals
European capabilities for detecting cyber threats against the health sector
National Actions
21
In consultation with the Commission, regularly 2025-2026
provide updates of the work of the Cybersecurity
Support Centre to relevant networks of Member States
Member States:
European capabilities for detecting cyber threats against the health sector
National Actions
22