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NCA cybersecurity controls: do they apply to your startup?

Do the NCA's ECC and CCC controls apply to your startup? Who they bind, what government buyers ask suppliers, and how to prepare without a security team.

Fanann Team8 min read
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Quick answer

The National Cybersecurity Authority's controls, such as the Essential Cybersecurity Controls (ECC-2:2024) and Cloud Cybersecurity Controls (CCC-2:2024), mainly bind government bodies, critical national infrastructure and their suppliers. If your startup sells to consumers or ordinary private companies, you are usually not directly bound, but if you want to contract with a government or critical-sector entity, the requirements reach you through the contract. Either way, adopting the basics early makes your product safer and easier to sell to enterprises.

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Do NCA cybersecurity controls apply to your startup?

If you run a startup in Saudi Arabia and have heard about the Essential Cybersecurity Controls (ECC) or the Cloud Cybersecurity Controls (CCC), the natural question is: do they apply to my company? The usual answer is not directly, unless you are a government body, an entity within critical national infrastructure, or a supplier providing services to those entities.

The current versions are ECC-2:2024 and CCC-2:2024, both issued by the National Cybersecurity Authority (NCA). Their purpose is to raise the security baseline of organizations whose disruption or breach would affect the public interest. A small online store or a salon booking app is not normally asked to prove compliance with them.

The picture changes the moment you decide to sell to a government body or a large company in a critical sector. The requirements then reach you through the contract, the tender documents and security questionnaires, and you may be asked for written evidence of your practices. This guide shows how to tell where you stand and what to start with when you do not have a full security team.

The controls may not bind you today, but your next customer might bind you to them tomorrow.

Who do the ECC and CCC apply to?

Your situationAre you involved?How requirements reach you
Selling only to consumers (store, booking app)Usually not directlyNot normally requested, but the basics still protect you
Selling to ordinary private companiesUsually not directlySecurity questionnaires from some customers
Selling to a critical-sector or infrastructure companyOften yes, as a supplierContract clauses and security reviews
Providing a service or software to a government bodyYes, in most casesTender documents, contract and the entity's requirements
Providing a cloud service to bound entitiesYes, and the cloud controls apply tooCCC requirements and cloud computing rules

The core idea is that obligations flow down the supply chain. The bound entity is responsible for the security of what it uses, so it asks its suppliers for assurances. That is why a small company can find itself asked for specific security practices: its customer is the one who is bound.

What do the controls cover, in broad terms?

Without going control by control, the essential controls revolve around familiar cybersecurity themes. Understanding them helps you assess your product and company even if you are not bound.

  • Governance: written security policies, a named person responsible for security, risk management and periodic review.
  • Defense: identity and access management, protection of systems and networks, encryption, and vulnerability and patch management.
  • Resilience: backups, the ability to restore, and business continuity when something goes wrong.
  • Third parties and cloud: requirements on suppliers and cloud service providers.
  • Logging and monitoring: recording important events, watching them and responding to incidents.

The Cloud Cybersecurity Controls (CCC-2:2024) add requirements specific to cloud providers and the organizations that use them. On data location: ECC-2:2024 no longer contains a blanket in-Kingdom hosting requirement, while government-classified data stays in the Kingdom under the cloud rules of the Communications, Space and Technology Commission (CST). Details are in our guide to hosting your app's data in Saudi Arabia.

What is the minimum a startup should start with?

You do not need a full security team to begin. These basics appear in most security questionnaires, and a two-person company can put them in place within a few weeks.

  1. 1
    Name a security owner

    Even if it is the founder. What matters is that one named person owns security decisions and follow-up.

  2. 2
    Write a short policy

    Two pages are enough at first: passwords, permissions, backups, incident handling and suppliers.

  3. 3
    Turn on two-factor authentication

    On email, the code repository, hosting and payment dashboards, and every admin account.

  4. 4
    Apply least privilege

    Every employee and user sees only what they need. Clear roles and permissions in the app and the admin panel.

  5. 5
    Encrypt and protect data

    HTTPS everywhere, encryption at rest, and keys and secrets kept out of the code.

  6. 6
    Back up and test restores

    At least daily backups and a documented restore test from time to time, because an untested backup cannot be trusted.

  7. 7
    Log and monitor

    Access logs for the admin panel and sensitive actions, plus alerts on outages or unusual activity.

If your app was built with AI, also run through the security checklist for AI-built apps before pitching to an enterprise customer.

How to prepare a security pack for government and enterprise buyers

What delays large deals most is rarely a weak product. It is the lack of ready answers. Prepare a short security pack for your product that answers the recurring questions.

Pack sectionWhat to write
Product and data overviewWhat the product does, what data it stores and how that data is classified
Hosting and data locationGeographic region, backups, and an in-Kingdom hosting option if available
Identity and accessSign-in method, two-factor authentication, single sign-on (SSO) and roles
EncryptionIn transit and at rest, plus how keys and secrets are managed
ContinuityBackups, restore, update rollback and the committed service level
Logs and incidentsAudit logs, monitoring and incident response steps
Sub-processorsList of third-party providers and the role of each

Common startup mistakes

What often happens
  • Believing every Saudi company is bound by every control, and delaying launch
  • Or the opposite: ignoring security entirely, then bidding for a government tender
  • One admin account shared by the whole team
  • Backups that have never been restored
  • Hosting whose exact location the founder does not know
What works better
  • Work out first whether you or your customer is a bound entity
  • Adopt the basics early, then extend them per contract
  • One account per person, with roles and access logs
  • A periodic, documented restore test
  • Data location and suppliers documented on one page

Remember too that cybersecurity is tied to the Personal Data Protection Law, which applies to anyone processing personal data in the Kingdom regardless of size.

How Fanann helps you get ready

When you build with Fanann, many basics come ready: in-region hosting with SSL, daily backups and instant rollback, a managed database, phone-number sign-in, and roles and permissions. Enterprise plans add in-country hosting, single sign-on (SSO), audit logs, approvals and an SLA. Because you own the full code and can export it to GitHub, your customer's security team can review it when needed.

This does not make you compliant with the controls automatically; compliance also covers your company's policies, procedures and people. But it spares you from building the technical foundation from scratch.

Copy-ready prompt for a security-minded internal tool

Build an internal maintenance request system for a company that serves government clients. Roles: requester, maintenance technician, supervisor and system admin. Each role sees only what belongs to it. Add an audit log that records who signed in, when, and what they changed on each request, and that nobody can delete. Use phone-number sign-in with an OTP code and an automatic sign-out after inactivity. Do not store national ID numbers. Add an admin dashboard showing open and overdue requests, and a page to export logs as CSV. Deploy on in-region hosting with daily backups, and make the interface Arabic right-to-left with both Hijri and Gregorian dates.

Try it in Fanann

Key takeaways

  • ECC and CCC mainly bind government bodies, critical infrastructure and their suppliers, not every Saudi company.
  • A startup becomes involved in practice when it contracts with a bound entity, which passes the requirements down.
  • ECC-2:2024 dropped a blanket in-Kingdom hosting requirement, but government-classified data stays in the Kingdom under the CST cloud rules.
  • The basics behind the controls help any product: clear permissions, encryption, backups, logs and supplier management.
  • Prepare a short security pack for your product before your first tender. It saves weeks in any large deal.

Frequently asked questions

Do NCA cybersecurity controls apply to private companies?
They mainly bind government bodies, critical national infrastructure entities and their suppliers. An ordinary private company is usually not directly bound, but becomes involved if it provides services to a bound entity.
What is the difference between ECC and CCC?
The Essential Cybersecurity Controls (ECC-2:2024) set the general security baseline for covered entities, while the Cloud Cybersecurity Controls (CCC-2:2024) add requirements specific to cloud providers and the organizations that use them.
What cybersecurity requirements apply to Saudi government contracts?
They vary by entity and contract and usually appear in the tender documents. Expect questions on hosting location, permissions, encryption, backups, logs and suppliers. Request the requirements early, before you submit a proposal.
Do the NCA controls require hosting data inside Saudi Arabia?
ECC-2:2024 no longer contains a blanket requirement to do so, but government-classified data stays in the Kingdom under the cloud computing rules, and a contract may require local hosting.
How can a startup prepare for cybersecurity without a big team?
Name an owner, write a short policy, enable two-factor authentication, apply least privilege, encrypt data, back up and test restores, and turn on logging. Then put together a short security pack for your product.

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