A client from the manufacturing sector called me on a Wednesday morning with a question I hear more and more often: “Justyna, an auditor is asking us about our risk management policy, we have a contract with a German client that requires ISO 27001 compliance, and we just received a letter asking about NIS2. We have no CISO. What should we do?” The board was considering immediate recruitment. A LinkedIn ad, a headhunter, a process. The figure on the first offer from a recruitment agency — 480,000 Polish zloty per year as the minimum salary range for a candidate with adequate experience, plus employer costs, plus several months of vacancy before the new person implements anything.
For a company with 120 employees and a turnover of 40 million zloty, that is a decision that reshapes the cost structure of the entire IT department. And yet the need for strategic leadership in cybersecurity existed here and now, not in a year’s time. The answer was a virtual CISO — a model that allows midsize companies to draw on the competencies of a security director exactly where they are needed, without the commitments of a permanent role and without months of waiting for the right candidate. In this article I explain how it works in practice and how to make this decision consciously.
Why does a midsize company need CISO competencies but cannot afford a full-time hire?
A midsize company in Poland — let us say 50 to 200 employees, turnover from 20 to 150 million zloty — has reached a specific point of maturity. It is already too large to manage security “informally”, where the IT administrator also configures the firewall and manages permissions on the side. But at the same time it is too small to justify the budget for a genuine CISO position, which in Poland today costs 35,000 to 55,000 zloty gross per month — and that is for a candidate with average experience, not a leader with an exceptional portfolio.
Pressure on this group of companies is growing from several directions simultaneously. NIS2 — being implemented into Polish law through the amendment of the Act on the National Cybersecurity System — imposes obligations on important and essential entities regardless of their size, provided they meet the sectoral and revenue criteria. Corporate clients, especially from Western markets, are including contractual clauses requiring documented security policies, penetration tests and compliance audits. Cyber insurers are increasingly making the conclusion or renewal of a policy conditional on submitting a completed technical questionnaire — and refusing to insure companies that lack a formal security strategy.
At the same time, the CISO job market is one of the most difficult markets in the entire IT industry. According to ISC2 data, the shortage of cybersecurity specialists in Europe exceeds 300,000 positions per year. Recruiting a CISO typically takes six to twelve months — and that assumes the company is an attractive employer, offers a competitive salary and has a recognisable brand. For a manufacturer in Opole or a distributor in Lublin, the odds of beating a bank or technology company in that recruitment race are low.
The virtual CISO model resolves this dilemma structurally: the company gains strategic security leadership from day one of the engagement, without the risk of vacancy, without recruitment costs and without the commitments of permanent employment.
The cost of a vCISO in a model tailored to the needs of a company with 50–200 employees is typically 12,000 to 25,000 zloty per month, depending on the scope and level of engagement. Relative to the cost of a full-time position, that is 30 to 50 percent of the value — while simultaneously providing access to an expert with years of multi-industry experience, a team of analysts and lawyers in the background, and tools whose individual licensing would be uneconomical.
📚 Read the complete guide: AI Security: AI w cyberbezpieczeństwie - zagrożenia, obrona, przyszłość
What tasks does a virtual CISO perform in a company with 50–200 employees?
I often hear a certain mistaken image of the vCISO from clients: that it is a consultant who comes in once a month, talks to the board and sends an invoice. The reality is entirely different. A virtual CISO is a continuous, structured engagement in the life of the organisation — one that is delivered in a fractional model rather than full eight-hour days.
The first and fundamental task is developing and maintaining a cybersecurity strategy. For most companies in the 50–200 employee range, such a strategy simply does not exist — there is a collection of tools purchased in response to immediate needs, without a plan, without priorities, without coherence. In the first weeks of the engagement, the vCISO conducts an assessment of the current state, identifies gaps, builds a risk register and presents the board with a roadmap for 12 to 24 months. This document becomes the foundation for all subsequent budget and technology decisions.
Risk management is another area that disappears from the agenda when no one is formally responsible for it. The vCISO maintains the risk register, updates it regularly, prioritises remediation actions and reports to the board not in technical language but in financial and operational terms: “Risk X could cost the company Y zloty in an incident scenario. Mitigation costs Z zloty. Recommendation: implement in Q3.” This is precisely the level of conversation the board needs in order to make informed decisions.
Compliance and regulatory conformance is an area that in 2025 and 2026 is absorbing an enormous amount of energy in midsize companies. NIS2, GDPR, sector-specific requirements, ISO 27001 certifications — each of them has its own documentary, procedural and technical requirements. The vCISO pilots the company through these requirements, manages the audit schedule, prepares documentation and coordinates remediation actions after an audit.
The virtual CISO does not perform all tasks independently — they coordinate the work of the internal IT team, external suppliers and specialist partners. It is the role of a conductor, not the first violin.
The vCISO’s scope also includes managing security vendors — selecting and overseeing companies that carry out penetration tests, SOC as a Service, vulnerability management and backup. Without coordination at the CISO level, these services often operate in silos: each doing their own thing, with no one looking at the whole picture. The vCISO ensures coherence and synergy among vendors. They also build security awareness among employees — from policies and procedures, through training, to phishing simulations and social engineering tests.
How does a virtual CISO help meet NIS2 requirements without expanding the team?
NIS2 is probably the most common trigger that leads companies to begin a conversation about vCISO. The directive imposes specific, verifiable obligations on important and essential entities, with sanctions attached — up to 10 million euros or 2% of global turnover for essential entities. Importantly, responsibility for implementation rests directly with the organisation’s management: the board and supervisory board.
For a company without an experienced security leader, the NIS2 requirements list looks like an iceberg: the visible tip is “create policies and procedures”, while hidden beneath the surface lies the reality of supply chain risk management, incident response requirements, CERT Polska reporting standards, encryption and business continuity requirements, and on top of that — training obligations for the board.
The virtual CISO delivers the NIS2 project in a structured manner. It begins with a gap analysis — an assessment of where the company stands today relative to the directive’s requirements. The results of the analysis are presented to the board as a prioritised list of gaps with cost estimates for closing them. The vCISO then leads the implementation project: creating policies, building processes, implementing technical controls or overseeing their implementation by vendors, training staff and the board.
The key value of the vCISO in the context of NIS2 is that the company does not need to build these competencies from scratch internally. A single expert who has delivered NIS2 projects in several or even a dozen organisations brings ready-made templates, proven methodologies and knowledge of how regulators interpret individual requirements. This shortens the implementation timeline by several months and reduces the risk of costly misinterpretations.
Companies from the manufacturing, logistics, energy and digital services sectors that meet the criteria for important entities under NIS2 should treat a vCISO as the minimum response to regulatory requirements — not as an optional enhancement.
An important aspect: NIS2 requires regular reporting to the board and documentation of risk-related decisions. The vCISO ensures continuity of this documentation — every meeting, every decision, every incident and every risk assessment are recorded in a manner that withstands scrutiny from an auditor or regulator. This protects the board against personal liability, which the directive explicitly provides for.
How much does a company save by choosing a virtual CISO over recruitment?
This is a question where I like to be specific. The numbers speak for themselves — and not to the detriment of the vCISO.
A full-time CISO with adequate experience to manage a security programme in a 100-person company commands a salary of 35,000 to 50,000 zloty gross per month. On top of that come employer costs — social insurance contributions, employee capital plans, the Labour Fund — which increase the cost by approximately 20 percent. Benefits: a company car, phone, group insurance, a sports card, health insurance — another 3,000 to 5,000 zloty per month. Training and certifications for the CISO are an indispensable expense of around 15,000 to 30,000 zloty per year, because without up-to-date knowledge and certifications (CISSP, CISM, CISA) such an expert will quickly lose market value. Then there is the recruitment cost: a headhunter typically charges 20 to 25 percent of annual salary, meaning 80,000 to 150,000 zloty as a one-off, plus several months of HR and management time on interviews.
| Cost component | Full-time CISO (year 1) | Virtual CISO Silver (4 days/month) |
|---|---|---|
| Salary / subscription | PLN 420,000 – 600,000 | PLN 144,000 – 240,000 |
| Employer costs (social security, pension plan) | PLN 84,000 – 120,000 | — |
| Benefits | PLN 36,000 – 60,000 | — |
| Training and certifications | PLN 15,000 – 30,000 | included in subscription |
| Recruitment (headhunter) | PLN 84,000 – 150,000 | — |
| Time to full effectiveness | 3–6 months | 2–4 weeks |
| Total year 1 | PLN 639,000 – 960,000 | PLN 144,000 – 240,000 |
| Total subsequent years | PLN 555,000 – 810,000 | PLN 144,000 – 240,000 |
Savings in the first year: from 400,000 to over 700,000 zloty. With the Silver model (2 to 4 days per month) — typical for a company with 50–120 employees — the difference is fivefold to sixfold.
What matters even more than the amount, however, is time. Recruiting a CISO in Poland currently takes an average of eight to twelve months. During that time the company has no strategic security leadership — exposed to risk, without a person responsible for NIS2, without vendor coordination. A virtual CISO typically begins work two to four weeks after signing the contract. The difference in operational readiness time amounts to several quarters, during which incidents could occur that cost many times more than the annual cost difference between the two models.
A single successful ransomware attack on a manufacturing company can cost between 200,000 and several million zloty in downtime, data loss, recovery costs and potential regulatory fines. The cost of a vCISO who could have prevented such an incident is a fraction of that amount.
It is also worth bearing in mind the retention risk: according to research, the average CISO tenure in a single organisation is just 18 to 24 months. A CISO leaving after two years means repeating the entire recruitment process and — more dangerously — losing strategic continuity. A new CISO needs months to learn the organisation and build effective relationships. The vCISO model eliminates this risk structurally: even if the specific consultant changes, the knowledge of the organisation remains with the service provider.
What does a typical working week of a virtual CISO look like in a midsize company?
One of my clients — the operations director of a logistics company — once asked me directly: “What will this person actually be doing during those few days a month?” That is a very good question, because the answer dispels a great many doubts.
The vCISO Silver model — two to four days of engagement per month — looks roughly like this in practice: the first week begins with a review of incidents and alerts from the previous period. The vCISO is not a SOC, but must know the threat picture in order to assess the adequacy of controls. This is followed by a meeting with the IT administrator or security engineer (if one exists): a review of the status of open actions from the previous month and a discussion of technical issues requiring a strategic decision. Next comes work on documentation: policies, procedures, risk assessments, compliance reports. Towards the end of the week or at its beginning — a call or meeting with the board: a progress report on the plan, a presentation of new risks, decision recommendations.
The third week is typically devoted to a deeper strategic project: preparation for an ISO 27001 audit, a review of vendor contracts from a security requirements perspective, coordinating a penetration test with an external provider or discussing results and a remediation plan. In the Gold model — eight to twelve days per month — these activities are more extensive, the vCISO participates in a wider range of internal meetings and has time for deeper project work.
Between “vCISO days” there is no vacuum. A good vCISO remains available for key questions and escalations, processes information forwarded by the client and — importantly — keeps track of the schedule: compliance deadlines, audit dates, certificate expiry dates, employee training schedules. The company can count on nothing important “falling through the cracks” simply because no one had the time to deal with it.
A typical monthly vCISO report contains: the status of risks in the register (open, closed, new), progress on roadmap delivery, security metrics (e.g. number of incidents, SOC response time, phishing simulation results), recommendations for the next month and items requiring a board decision.
Emergency availability is also important in the vCISO model. A serious security incident does not wait for a scheduled vCISO day. A good vCISO service provider defines the SLA for critical situations in the contract — typically one to four hours for initial engagement in the case of an incident requiring CISO-level coordination. This is an important element that should be verified before signing a contract.
What risks does a virtual CISO eliminate in the first 30 days?
The first 30 days of working with a vCISO are an intensive diagnostic phase, after which the board is typically surprised — not because the situation is catastrophic, but because no one had ever looked at it holistically before. Risks emerge that no one knew existed, or knew about but had no one to prioritise them and recommend action.
The first risk that the vCISO eliminates or mitigates almost immediately is the absence of an owner responsible for security. This sounds like a truism, but in practice it means that security decisions are made by chance: by the IT administrator who has time, by the CEO who read an article about ransomware, or by the CFO who approved the purchase of a tool based on a sales offer. From day one, the vCISO becomes the responsible person and the first point of contact for all security matters.
The second risk is uncontrolled access permissions. In almost every company where there is no formal access management, the vCISO discovers in the first few weeks accounts belonging to former employees with active permissions, employees with access to resources they do not need, and applications with administrator privileges where standard privileges would suffice. Each of these discoveries is an open door for an attacker or a malicious insider.
The third risk is unknown assets — systems, applications, servers and devices that exist in the company’s infrastructure but are not managed by IT. Shadow IT in companies with 50–200 employees is rampant: someone launched a SaaS application without IT’s knowledge, someone else configured a server for a project and forgot to shut it down, the marketing department uses social media management tools that have access to customer data. The vCISO initiates an inventory process and brings these assets under proper oversight.
Within 30 days, the vCISO delivers to the company what it has lacked for years: a coherent picture of risks, an owner responsible for security and a prioritised list of actions for immediate implementation.
The fourth risk that the vCISO addresses immediately is the absence of an incident response plan. What will the company do if ransomware encryption shuts down its production systems on a Monday morning? Who decides? Who calls the insurer? Who contacts CERT Polska and when? Who communicates with clients? Without a documented plan, the response to an incident becomes a chaotic improvisation that extends downtime and increases losses. The vCISO creates or validates this plan in the first month of the engagement and ensures that key employees know their roles.
How does a virtual CISO work with an external SOC and the IT team?
The collaboration model that works in the vast majority of cases looks as follows: the internal IT administrator or engineer is responsible for the operational maintenance of the infrastructure — updates, configurations, user support, server management. The external SOC (Security Operations Center) monitors the environment 24/7, detects anomalies, manages alerts and responds to operational incidents. The virtual CISO links these two elements at the strategic and management level.
This distinction is crucial and often misunderstood. The vCISO does not sit in the SIEM and analyse logs. They do not configure firewalls or manage tickets. The vCISO’s task is to ensure that the SOC has the correct escalation instructions, that internal IT understands security priorities and implements them in their work, and that the board receives a consolidated picture of the situation rather than confused reports from several different sources.
The vCISO’s collaboration with the SOC begins by defining the monitoring scope and escalation rules: which types of alerts require immediate contact with the vCISO, which can be handled by the SOC autonomously, which go to internal IT. The vCISO participates in monthly reviews with the SOC, evaluating trends, detection quality and areas requiring improvement. When the SOC reports a growing number of unauthorised access attempts, it is the vCISO — not the IT administrator — who decides whether this requires architecture changes, additional access controls or an immediate investigation.
The relationship with the internal IT team requires tact and emotional intelligence from the vCISO. The IT administrator may feel threatened or evaluated by an external expert. A good vCISO builds a relationship of partnership, not supervision: treats IT as an ally, appreciates their knowledge of the environment, consults decisions and explains context rather than issuing directives. This relationship is the foundation of the entire model’s effectiveness.
The vCISO acts as the central coordination point between the board, internal IT, the external SOC and other security vendors. It eliminates information silos and ensures that all elements of the security system operate coherently.
An important practical point: the vCISO should participate in procurement processes for security tools and services. Too often companies buy solutions under the influence of a persuasive salesperson or an industry article, rather than driven by risk analysis and strategy. The vCISO evaluates proposals in the context of the company’s overall security picture — not whether a tool is good in itself, but whether it fits the environment, covers identified gaps and is worth the price compared to alternatives.
When should a company move from a virtual CISO to a full-time CISO?
This is a question that typically arises after 12 to 24 months of successful engagement with a vCISO, when the company has grown, matured and is beginning to consider internalising security competencies. The answer is not straightforward — it depends on many factors.
The first signal that a company may be ready for a full-time CISO is growth in organisational complexity to a level that requires the constant presence of a security leader. If the company has more than 300 to 400 employees, operates across multiple locations, processes critical data or operates in a highly regulated sector with a high risk profile (fintech, healthcare, critical infrastructure), the fractional model may begin to fall short.
The second signal is the building of an internal security team. If the company has already hired two or three security analysts or engineers specialising in security, they need a leader who is available every day, builds relationships with them and is responsible for their development. A vCISO with a few days per month cannot fulfil the role of a manager for an internal security team.
The third signal is the risk profile. A company that has become an essential entity under NIS2 in a critical sector, that has experienced a serious security incident, or that due to the nature of its business is exposed to advanced, targeted attacks, should consider a full-time position.
The key question is: does the company need someone to manage security, or someone to operationally oversee it every single day? If the answer is the latter — it is time for a full-time hire.
It is worth remembering, however, that transitioning from a vCISO to a full-time hire does not necessarily mean ending the relationship with the provider. An in-house CISO can draw on external team support for specialised projects (penetration tests, architecture assessments, certification preparation) or as a second opinion on key decisions. The hybrid model — a full-time CISO plus external specialist support — is in many organisations the optimal response to growing needs.
If the company is at the stage where it is considering this decision, it is helpful to carry out a thorough analysis: how many hours per month does the vCISO actually engage, how many tasks remain undelivered due to the constraints of the fractional model, what is the cost of improvements that could be implemented but require the constant presence of a leader. An honest answer to these questions will reveal whether the break-even point for a full-time CISO has been reached.
How to choose a virtual CISO service provider — what to look for?
The vCISO services market in Poland is growing fast, and the quality of offerings varies enormously. I know companies that sell vCISO as a consulting package with a documentation review once a quarter, and companies that offer genuine, strategic partnership with built-in access to an entire ecosystem of security competencies. The choice is of fundamental importance to whether the investment will deliver real value.
| Criterion | What to look for | Red flags | Weight |
|---|---|---|---|
| Consultant experience | 10+ years, work with companies of a similar profile and industry, certifications (CISSP, CISM, CISA) | Only certifications without practical references; vague description of experience | High |
| Engagement model | Clearly defined monthly scope, SLA for incidents, emergency availability clause | No SLA, no escalation procedures, vCISO without SLA for critical incidents | High |
| Service continuity | What happens when “your” vCISO is unavailable? Is there a backup consultant? | No substitute, dependency on a single person, no continuity procedure | High |
| Team in the background | Access to specialists (pentesters, lawyers, engineers) at no additional cost | Consultant operates solo without specialist support | Medium |
| References and retention | Long-term clients (2+ years), ability to speak with references | Refusal to provide references, high client turnover | High |
| Reporting transparency | Monthly reports, risk dashboard, decision documentation | No structured reporting, relationship conducted exclusively by email | Medium |
| Conflict of interest | Policy on serving competitors, NDA, confidentiality clauses | No conflict of interest policy, serving direct competitors | High |
| Pricing model | Clear subscription with defined scope, transparent rules for billing additional hours | Billing exclusively by the hour without a defined scope, hidden costs | Medium |
A few practical tips for the selection process. First: ask about specific projects, not general competencies. “How did you implement NIS2 for a client in the manufacturing sector?” yields far more information than “How long have you been operating in the market?”. Second: check who will actually be your vCISO, not only who makes the sales pitch. Meet the specific person, assess their communication style and check whether they understand your business. Third: ask to speak with one of the provider’s current clients. A credible company will not refuse this request.
Fourth: assess whether the provider delivers only competencies or an entire ecosystem. A vCISO backed by a team of pentesters, SOC analysts and GDPR lawyers is significantly more valuable than a lone consultant — because when the need arises for a penetration test, a legal assessment or a technical implementation, the company does not have to go looking for another vendor on the open market.
How does nFlo tailor the virtual CISO service to the needs of midsize companies?
nFlo works with more than 200 clients from the SME and corporate sectors, and the vCISO service is one of our key responses to the dilemma I encounter every day in conversations: the company needs a security strategy, but recruiting a full-time CISO is out of reach or simply the suboptimal solution at this stage.
Our vCISO model begins with a deep understanding of the business context — not only the technical state of the infrastructure, but the company’s goals, its operational risks, its relationships with clients and vendors, and planned changes (expansion, mergers, new products). Security only makes sense as an element of a broader business strategy, not as an isolated technical project. That is why our consultants are not only engineers — they are people with experience working at the intersection of security and management.
Within the first four weeks, the client receives a full current-state assessment: a risk register, a gap analysis against applicable regulations (NIS2, GDPR, sector-specific requirements) and a prioritised roadmap for 12 months. This phase is specific and documented — no generic recommendations, only actions with deadlines, owners and cost estimates.
Behind every vCISO stands the full ecosystem of nFlo’s competencies: 500 completed projects in penetration testing, SOC as a Service, vulnerability management, regulatory compliance and technology implementations. The client does not need to search for additional vendors for every new challenge — they can count on the entire process being coordinated by a single partner, with single accountability and a single report to the board.
Our SLA for critical incidents is under 15 minutes for first response — a standard that is encoded in the DNA of our entire organisation, not just in contracts. 98 percent of our clients continue the engagement after the first year, which we consider the best measure of the real value we deliver.
If your company is facing a decision about the security management model — recruitment, vCISO or something in between — I encourage you to have a conversation. We analyse needs without a predetermined answer and recommend a solution that genuinely makes sense for your situation, not the one that looks best in an offer.
For companies that are just beginning this conversation, we also offer a free initial consultation: 60 minutes with an experienced expert who will help assess what stage of maturity the company has reached and what the most pressing actions are — regardless of whether the next step will be a vCISO from nFlo, a full-time CISO or a set of specific technical projects.
Frequently asked questions
Can a virtual CISO represent the company before a regulator or auditor?
Yes, provided that the vCISO role is formally defined within the organisation — for example, through an appropriate power of attorney or a provision in the security policy. In practice, the vCISO regularly participates in meetings with external auditors, prepares documentation for regulators and represents the company in compliance-related correspondence. It is important that the vCISO provider has experience in direct communication with regulators — this is a verifiable competency that is worth checking before selecting a partner.
How does a vCISO access the company’s sensitive data and systems?
This matter is governed by the vCISO service agreement, which typically contains extensive NDA clauses, the scope of access permissions and security procedures relating to the provider itself. A good vCISO provider should apply the principle of least privilege — access to exactly what is necessary for carrying out the tasks — and be able to demonstrate their own certifications or security audits (e.g. ISO 27001). It is also worth checking whether the provider uses secure methods for communication and document storage.
How long does vCISO onboarding take and when will the first results appear?
Onboarding — getting to know the environment, collecting data, speaking with key individuals — typically takes two to four weeks. The first measurable results appear within the first month: a list of priority risks, an action plan, a defined compliance scope, an initial incident response policy. Strategic results — risk reduction, improvement in security metrics, preparation for audit — materialise over a period of three to six months. It is important to note that a vCISO is not a one-off project but a continuous process — the longer the engagement, the deeper the understanding of the organisation and the higher the value delivered.
Will a vCISO replace the need to hire anyone for internal security?
Not always, but it depends on the size of the company and the scale of operational tasks. For a company with fewer than 100 employees, a vCISO combined with an external SOC can be a complete solution. In companies with 100 to 200 employees, a hybrid model is often optimal: a vCISO at the strategic level plus one internal security analyst or engineer responsible for operational tasks and daily liaison between IT and the vCISO. The right configuration depends on the risk profile, industry regulations and the complexity of the environment.
How can you assess whether the collaboration with a vCISO is delivering results?
Measurable indicators of vCISO effectiveness include: reduction in the number of open high-level risks in the register, progress on the security roadmap (percentage of initiatives implemented), incident response time, phishing simulation results over time, degree of compliance with NIS2 or ISO 27001 requirements (gap analysis before and after), and the number and quality of policies and procedures (with documentation before and after). A good vCISO provides monthly reports with these indicators — if the provider does not measure results, that is a warning signal.
Sources
- ISC2 Cybersecurity Workforce Study 2024, https://www.isc2.org/Research/Workforce-Study
- NIS2 Directive (EU 2022/2555) — official text, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32022L2555
- ENISA — NIS2 Implementation Guidelines 2024, https://www.enisa.europa.eu/publications/nis2-implementation-guidelines
- CISO Executive Network — CISO Tenure and Compensation Report 2024, https://www.ciso.com/research
- Gartner — Market Guide for Virtual CISO Services 2023, https://www.gartner.com/en/documents/4229099
- KPMG — Cybersecurity in Polish Enterprises Report 2025, https://home.kpmg/pl/pl/home/insights/2025/02/cyberbezpieczenstwo-w-polskich-przedsiebiorstwach.html
- Ponemon Institute — Cost of a Data Breach Report 2024, https://www.ibm.com/reports/data-breach
- Act of 5 July 2018 on the National Cybersecurity System (Journal of Laws 2018 item 1560, as amended), https://isap.sejm.gov.pl/isap.nsf/DocDetails.xsp?id=WDU20180001560
Related terms
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