Executive Summary

The European Union has launched the European Cybersecurity Reserve, a new initiative designed to strengthen the bloc's collective response to major cyber incidents. The Reserve is a central pillar of the Cyber Solidarity Act (Regulation (EU) 2025/38), which came into force in February 2025. With an initial budget of €36 million, the Reserve is managed by the EU Agency for Cybersecurity (ENISA) and comprises a pool of 45 trusted private sector cybersecurity companies. These firms can be rapidly deployed to provide incident response support to Member States, EU institutions, or associated countries facing significant, large-scale cyberattacks.

Regulatory Details

The European Cybersecurity Reserve operationalizes the EU's commitment to collective cyber defense. It moves beyond policy harmonization to create a tangible, shared resource. Key details of the initiative include:

• Mandate: To provide cross-border incident response support for major cyber incidents, particularly those affecting critical infrastructure.
• Funding: €36 million for the first three years, funded through the Digital Europe Programme 2025-2027.
• Management: Coordinated and managed by ENISA.
• Composition: A pool of 45 pre-selected private companies (Managed Security Service Providers), including SMEs and large corporations like Airbus Protect and Spike Reply.
• Activation: The Reserve can be activated at the request of a Member State, an EU institution, or a third country associated with the Digital Europe Programme.

Affected Organizations

The primary beneficiaries of the Reserve are the governments and critical infrastructure operators within the 27 EU Member States. The Reserve acts as a support mechanism for national Computer Security Incident Response Teams (CSIRTs) and other relevant authorities when they are overwhelmed by a major incident.

Compliance Requirements

For the private sector providers, becoming part of the Reserve involves a stringent vetting process. Key requirements include:

• EU Establishment: The company must be legally established within an EU Member State.
• Ownership Control: Providers must undergo an Ownership Control Assessment (OCA) to ensure they are free from non-European controlling influence, a measure to prevent foreign espionage risks.
• Proven Capabilities: Companies must demonstrate extensive experience in incident response, 24/7 availability, and compliance with relevant standards such as the NIS2 Directive or ISO 27001.

The goal is to have the Reserve fully operational by the end of 2025, with coordination exercises planned to ensure its readiness.

Impact Assessment

The establishment of the Cybersecurity Reserve marks a significant maturation of the EU's cybersecurity strategy. It creates a formal mechanism for mutual assistance, pooling top-tier private sector expertise to benefit the entire Union. This can help level the playing field, allowing smaller Member States with fewer resources to access world-class incident response capabilities. For the private sector, being selected as a trusted provider is a prestigious and potentially lucrative position. The initiative will likely foster a stronger public-private partnership in cybersecurity across Europe and improve the overall resilience of the EU's critical infrastructure against sophisticated, large-scale attacks.

Compliance Guidance

For EU Member States and critical infrastructure operators, the key is to understand the process for requesting assistance from the Reserve. National cybersecurity authorities should integrate the Reserve into their national incident response plans as a potential escalation path. They should familiarize themselves with the request procedures managed by ENISA. For private companies aspiring to join the Reserve in the future, they should focus on building a strong track record in incident response, achieving relevant certifications (ISO 27001), and ensuring their corporate structure aligns with the EU's ownership control requirements.