CSA 2 Needs an Execution Substrate: SMB-Viable Continuous Governance for Cyber Resilience

SA 2 makes important strides toward harmonization, simplification, and cross-border coherence. However, the proposal still assumes the existence of a continuous governance substrate that most SMBs do not have and cannot practically build. As written, CSA 2 risks reproducing the same structural gap seen in NIS 2, CRA, and the AI Act: policy goals without the operational mechanisms required to generate evidence, maintain compliance, or demonstrate good-faith behavior. Static certification frameworks and outcome-based language fail SMBs in the same way—they describe the destination without providing the execution layer that produces verifiable behavioral signals. A ransomware safe-harbor provision, for example, is only meaningful if an organization can generate a continuous audit trail showing patching behavior, access-control changes, model-update decisions, and incident-response actions. Most SMBs lack the telemetry, automation, and governance primitives needed to produce this evidence. The first recommendation below is foundational to all that follow: without a defined minimal execution substrate, recommendations on certification alignment, safe-harbor eligibility, and open tooling have no operational floor to stand on. Similarly, 'harmonized risk management' cannot be realized if the underlying behavioral signal is absent. CI/CD pipelines, cloud-native architectures, and increasingly agentic AI systems require governance that is embedded at the substrate layer: machine-readable controls, automated attestations, and continuous evidence generation. Without this, harmonization becomes an administrative exercise rather than a resilience-building mechanism.

Authors

Institutions

Publication Details

Journal
Zenodo (CERN European Organization for Nuclear Research)
Published
2026-04-28
DOI
https://doi.org/10.5281/zenodo.19834324
Primary Topic
Cybersecurity and Cyber Warfare Studies
Type
article
Field-Weighted Citation Impact
0.00
Controls
|||
ALL TIME
JAN
FEB
MAR
APR
MAY
JUN
JUL
AUG
SEP
OCT
article

CSA 2 Needs an Execution Substrate: SMB-Viable Continuous Governance for Cyber Resilience

Narnaiezzsshaa Truong
Zenodo (CERN European Organization for Nuclear Research)
Cybersecurity and Cyber Warfare Studies
article

CSA 2 Needs an Execution Substrate: SMB-Viable Continuous Governance for Cyber Resilience

Narnaiezzsshaa Truong
article en

Abstract

SA 2 makes important strides toward harmonization, simplification, and cross-border coherence. However, the proposal still assumes the existence of a continuous governance substrate that most SMBs do not have and cannot practically build. As written, CSA 2 risks reproducing the same structural gap seen in NIS 2, CRA, and the AI Act: policy goals without the operational mechanisms required to generate evidence, maintain compliance, or demonstrate good-faith behavior. Static certification frameworks and outcome-based language fail SMBs in the same way—they describe the destination without providing the execution layer that produces verifiable behavioral signals. A ransomware safe-harbor provision, for example, is only meaningful if an organization can generate a continuous audit trail showing patching behavior, access-control changes, model-update decisions, and incident-response actions. Most SMBs lack the telemetry, automation, and governance primitives needed to produce this evidence. The first recommendation below is foundational to all that follow: without a defined minimal execution substrate, recommendations on certification alignment, safe-harbor eligibility, and open tooling have no operational floor to stand on. Similarly, 'harmonized risk management' cannot be realized if the underlying behavioral signal is absent. CI/CD pipelines, cloud-native architectures, and increasingly agentic AI systems require governance that is embedded at the substrate layer: machine-readable controls, automated attestations, and continuous evidence generation. Without this, harmonization becomes an administrative exercise rather than a resilience-building mechanism.

Zenodo (CERN European Organization for Nuclear Research)
American Rock Mechanics Association (US)
Openalex Percentile: Top 3%
Cybersecurity and Cyber Warfare Studies
AI Navigator

Ask Laika to Summarize, Analyze, and Connect papers live on the map.

Summarize Papers & Methodologies

Extract key findings, datasets, and comparative methods across publications.

Benchmark Rankings & Visual Analytics

Rank top research institutions, authors, funders, topics, and journals by Field-Weighted Citation Impact (FWCI) and paper volume with instant charts.

Connect Distant Disciplines

Bridge topological clusters on the map to find hidden collaborative intersections.

CSA 2 Needs an Execution Substrate: SMB-Viable Continuous Governance for Cyber Resilience — Narnaiezzsshaa Truong · Zenodo (CERN European Organization for Nuclear Research) (2026) | TGRS Research Map | TGRS