Saudi NCA Cybersecurity Controls for Non-Critical National Infrastructure Private Sector Entities (2025-2026)
What Private Companies in Saudi Arabia Must Do
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. Background: Why This Document Exists
Saudi Arabia’s National Cybersecurity Authority (NCA) issued this updated framework to strengthen cybersecurity across the private sector that does NOT operate Critical National Infrastructure (CNI).
This is a crucial point:
You do NOT need to be a bank, telecom, or energy company to be regulated anymore.
Small, medium, and large private companies are now explicitly required to implement baseline cybersecurity controls, aligned with Saudi national cybersecurity strategy and Vision 2030 goals
2. Who Must Comply?
The controls apply to private sector entities operating in Saudi Arabia that are NOT classified as CNI, including:
Entity categories
Large private entities
Medium-sized private entities
Small private entities
Classification is based on:
Number of full-time employees
Annual revenue
⚠️ Important:
If your company uses Saudi digital services, processes customer data, or connects to national platforms, NCA considers you in scope — even if you think you are “low risk”
3. Core Objectives of the Controls
The NCA framework is built around the CIA triad:
Confidentiality – protecting sensitive data
Integrity – preventing unauthorized modification
Availability – ensuring systems remain operational
These controls aim to reduce cyber risk from both internal and external threats, including phishing, ransomware, cloud misconfiguration, insider abuse, and third-party exposure
4. Structure of the NCA Controls (High Level)
The framework is divided into three main control domains:
1️⃣ Cybersecurity Governance
2️⃣ Cybersecurity Defense
3️⃣ Third-Party & Cloud Cybersecurity
This is intentional:
NCA expects management ownership, technical controls, and vendor/cloud risk management — not just IT firefighting.
5. Key Cybersecurity Requirements – Explained for Private Companies
Below is a plain-English summary of what private entities actually need to do.
A. Cybersecurity Governance (Mandatory)
Every private entity must:
✔ Establish cybersecurity ownership
Assign a dedicated cybersecurity function
Define roles and responsibilities
Ensure senior management oversight
✔ Maintain cybersecurity policies
Documented cybersecurity policies and procedures
Policies must be approved, communicated, and enforced
Regular reviews are required
✔ Perform cybersecurity risk management
Identify cyber risks
Assess impact and likelihood
Treat risks using documented plans
✔ Conduct periodic reviews and audits
Independent or internal reviews
Ensure controls are implemented and effective
✔ Run cybersecurity awareness & training
Staff must be trained on:
Phishing
Password hygiene
Incident reporting
Training must be ongoing, not one-time
B. Cybersecurity Defense (Technical Controls)
Private entities must implement baseline technical security controls, including:
✔ Asset management
Identify and track IT assets
Know what systems you have before protecting them
✔ Identity & Access Management (IAM)
Strong authentication (preferably MFA)
Least-privilege access
Periodic access reviews
✔ Endpoint & server protection
Malware protection
Secure configurations
Patch management
✔ Email security
Phishing protection
Spam filtering
Email authentication mechanisms
✔ Network security
Firewalls and segmentation
Secure remote access
Monitoring for suspicious activity
✔ Backup & recovery
Regular backups
Secure storage
Tested recovery procedures
✔ Incident management
Defined incident response process
Ability to detect, respond, and recover from cyber incidents
C. Third-Party & Cloud Cybersecurity (Often Overlooked)
This is one of the most important sections for modern companies.
Private entities must:
✔ Manage third-party cyber risk
Assess vendors before onboarding
Define security requirements in contracts
Monitor vendor compliance
✔ Secure cloud environments
Apply cybersecurity controls to cloud services
Ensure data protection and access control
Maintain visibility into cloud configurations
⚠️ Critical insight:
Using cloud services does NOT transfer cybersecurity responsibility to the cloud provider.
The customer remains accountable under Saudi regulations
6. Compliance, Enforcement & Updates
Compliance is mandatory
NCA has authority to assess adherence
Controls are updated periodically
Entities must follow the latest published version
Failure to comply may lead to:
Regulatory action
Increased scrutiny
Business and reputational risk
7. What Private Companies Should Do Next (Actionable Steps)
If you are a private company in Saudi Arabia, you should:
Map your current controls against NCNICC-1:2025
Identify gaps in:
Governance
IAM
Cloud security
Vendor management
Assign clear cybersecurity ownership
Document policies and procedures
Prioritize cloud and third-party risks
Prepare evidence, not just policies
Final Thought
This NCA framework makes one thing very clear:
Cybersecurity is no longer optional or size-dependent in Saudi Arabia.
Every private entity is expected to operate at a baseline level of cyber maturity.
If you work in cloud, compliance, security engineering, or risk management, this document is now foundational.
Disclaimer
This article is provided for informational and educational purposes only as a reference to official Saudi Arabian cybersecurity regulatory publications issued by the National Cybersecurity Authority (NCA). The Arabic version of the NCA document “Cybersecurity Controls for Private Sector Entities that Do Not Have Sensitive Infrastructures (NCNICC-1:2025)” is the legally binding and authoritative text for interpretation and compliance purposes.
Organizations should always refer to the official NCA publications and consult qualified legal, compliance, or cybersecurity professionals when implementing regulatory requirements.
Global Compliance Code provides vendor-neutral, source-based regulatory reference materials. All content is derived from official regulatory publications.
