Saudi Cybersecurity: Non-CNI vs CNI — What’s the Difference?
With the release of the NCA Cybersecurity Controls for Non-CNI Private Sector Entities (NCNICC-1:2025), many companies are asking a simple but critical question:
“Are we Non-CNI or CNI — and what does that actually mean?”
Here is a clear, practical explanation.
Official document (in Arabic): https://nca.gov.sa/ar/news/2086/
This post is a high-level English summary based strictly on the official Arabic publication issued by the Saudi National Cybersecurity Authority (NCA). In case of any discrepancy, the original Arabic document prevails.
1. What Is CNI (Critical National Infrastructure)?
CNI entities are organizations whose disruption would have a direct impact on national security, public safety, or the economy.
Examples typically include:
Energy & utilities
Telecommunications
Financial market infrastructure
Government systems
Transportation, water, healthcare at national scale
-> CNI entities are subject to the full NCA Essential Cybersecurity Controls (ECC) and enhanced regulatory oversight.
2. What Is Non-CNI?
Non-CNI entities are private sector organizations not designated as critical infrastructure, but still operating digital systems, data, and services.
This includes:
Most private companies
SaaS providers
Technology firms
Industrial, retail, logistics, professional services
SMEs and mid-sized enterprises
-> Non-CNI does NOT mean “low risk” or “optional compliance”.
3. Key Regulatory Difference (At a Glance)
| Area | Non-CNI Private Entities | CNI Entities |
|---|---|---|
| Governing framework | NCNICC-1:2025 | NCA ECC (full) |
| Regulatory intent | Baseline, scalable controls | High-assurance, national-level protection |
| Mandatory | ✅ Yes | ✅ Yes |
| Scope | Governance, defense, third-party & cloud | Expanded technical, operational, national requirements |
| Oversight intensity | Proportionate | Strict, high-touch |
| Outsourcing allowed | Allowed, with controls | Highly restricted |
| Cloud usage | Allowed, with risk controls | Often restricted / sovereign conditions |
4. What Changed With NCNICC-1:2025?
For Non-CNI private companies, the NCA has now made it explicit that:
There is a mandatory minimum cybersecurity baseline
Controls scale by company size, but are not optional
Governance and accountability are required — not just technical tools
Third-party and cloud risks must be actively managed
In short:Non-CNI ≠ no cybersecurity obligations
5. Why This Distinction Matters
Understanding whether you are Non-CNI or CNI affects:
Compliance obligations
Cloud architecture decisions
Third-party and outsourcing contracts
Audit readiness
Risk exposure during regulatory reviews
Misclassification can lead to under-compliance or over-engineering — both costly.
Final Thought
Saudi Arabia is moving toward tiered, risk-based cybersecurity regulation:
CNI → maximum assurance
Non-CNI → enforceable baseline, proportionate controls
Disclaimer
This article is provided for informational purposes only and does not constitute legal, regulatory, or professional advice. The content herein summarizes aspects of official Saudi National Cybersecurity Authority (NCA) publications and is intended as a general reference. The official Arabic version of any Saudi regulatory text is the legally authoritative source for interpretation and compliance obligations. Organizations should consult the original NCA documents and seek qualified legal or cybersecurity advisory support when implementing cybersecurity frameworks or controls.
Global Compliance Code provides vendor-neutral, source-based regulatory reference materials. All content is derived from official regulatory publications.
