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NCA Non-CNI cybersecurity controls (NCNICC-1:2025): what Saudi private companies need to do

For the first time, the National Cybersecurity Authority has set mandatory cybersecurity controls for ordinary private companies, not just critical infrastructure. Here’s who is in scope, what Category A and Category B mean, and the IT work involved. See also our cyber security services in Riyadh.
The short answer

The Non-CNI Private Sector Entities Cybersecurity Controls (NCNICC-1:2025) are the NCA’s minimum cybersecurity requirements for private companies in Saudi Arabia that are not critical national infrastructure. Large companies (Category A: more than 250 staff or more than SAR 200 million revenue) must meet 65 mandatory controls. SMEs (Category B: 6 to 249 staff or SAR 3 million to 200 million revenue) must meet 26. The controls cover governance, technical defence, and third parties and cloud. The NCA can assess compliance at any time, so the practical goal is to have the controls running and the evidence ready.

Key points
  • NCNICC-1:2025 was issued in December 2025, after public consultation on a 2024 draft.
  • Category A (large companies) has 65 mandatory controls across 22 sub-components. Category B (SMEs) has 26 mandatory controls across 13.
  • Companies already covered by a sector framework, such as ECC for critical infrastructure or SAMA’s framework for banks, are generally outside it.
  • Reports indicate the NCA is bringing companies into scope by notifying them individually, rather than setting one national deadline.
  • Compliance is continuous: the NCA can assess at any time, and SDAIA separately enforces the PDPL’s security requirements.

Who do the NCA Non-CNI controls apply to?

The controls apply to private sector organisations in Saudi Arabia that are not classified as critical national infrastructure. They are split by size:

CategoryWhoControls
Category A: large entitiesMore than 250 full-time employees, or annual revenue above SAR 200 million65 mandatory controls across 22 sub-components
Category B: small and medium entities6 to 249 full-time employees, or annual revenue between SAR 3 million and SAR 200 million26 mandatory controls across 13 sub-components; the rest are recommended

Very small companies below the Category B thresholds are not currently in scope, although the NCA keeps the discretion to bring specific organisations in where the risk warrants it. Organisations already subject to the NCA’s Essential Cybersecurity Controls (ECC-2:2024) or to SAMA’s cybersecurity framework follow those instead. See our guide to NCA ECC-2:2024.

How are the controls structured?

The controls sit under three main components, built on people, processes and technology. Each control follows the same cycle: define, document and approve it; implement it; and review it periodically.

ComponentSub-componentsCategory B?
1. Cybersecurity governanceCybersecurity management; policies and procedures; risk management; review and audit; awareness and trainingAll five
2. Cybersecurity defenceAssets; identities and privileges; systems and devices; email; backups; vulnerabilities; incident managementThese seven
2. Cybersecurity defence (Category A only)Networks; mobile devices; data protection; encryption; penetration testing; security monitoring; physical security; web applicationsRecommended, not mandatory
3. Third-party and cloud cybersecuritySuppliers, contracts, cloud computing and hostingYes

What do the controls actually ask for?

Law firm summaries of the controls highlight requirements such as:

  • Governance: an approved cybersecurity policy, defined roles, a documented risk management method, staff awareness and regular review. For larger entities, a cybersecurity function independent of IT.
  • Identity and access: managed accounts and privileges, including multi-factor authentication for remote access.
  • Devices and systems: secure configuration and hardening, endpoint protection and patching.
  • Email: email security controls, aligned with the NCA’s Haseen platform.
  • Backups and vulnerabilities: working backups with restore testing, and regular vulnerability management.
  • Incidents: a way to detect, handle and learn from cybersecurity incidents.
  • Encryption: aligned with the NCA’s National Cryptographic Standards (mandatory for Category A).
  • Suppliers and cloud: cybersecurity terms in third-party contracts, including incident notification, and cloud terms covering data classification, separation from other customers and getting your data back in a usable format if you leave.

When do companies have to comply?

There is no single published national deadline. Reports from compliance advisers indicate the NCA is applying the controls by notifying organisations individually and giving each a compliance timeline. Separately, the NCA can assess compliance at any time and without advance notice, and expects compliance to be continuous rather than a one-off project.

In practice, the risk is being asked to show evidence at short notice. Companies that start now, with a gap assessment and a plan, are in a much better position than those that wait for a letter.

A Category B (SME) checklist

  1. Confirm your category from your headcount and revenue, and check you are not already under ECC or SAMA’s framework.
  2. Appoint a named person responsible for cybersecurity, and approve a short cybersecurity policy.
  3. Write down your main cyber risks and how you are treating them. Review at least once a year.
  4. Run awareness training for all staff, with phishing examples.
  5. Keep an up-to-date list of laptops, servers, cloud services and the data they hold.
  6. Turn on multi-factor authentication for every account, starting with email, admin and remote access.
  7. Remove local admin rights, and review who has access to what every quarter.
  8. Harden and patch laptops and servers, and run endpoint protection on all of them.
  9. Secure email: anti-phishing filtering, plus SPF, DKIM and DMARC on your domain.
  10. Back up critical data, keep a copy offline or immutable, and test restores.
  11. Scan for vulnerabilities regularly and fix the critical ones first.
  12. Have a written incident response plan, and know who to call.
  13. Add cybersecurity and incident-notification terms to supplier and cloud contracts.
  14. Collect the evidence as you go: policies, access reviews, patch reports, backup tests, training records.

How do the NCA controls relate to the PDPL?

They are separate rules from separate regulators, but they overlap. The NCA’s controls set the cybersecurity baseline. The Personal Data Protection Law, enforced by SDAIA, separately requires appropriate security for personal data and breach notification. SDAIA has also proposed changes to the PDPL’s Implementing Regulation that point organisations outside the NCA’s scope to “recognised cybersecurity standards”.

In practice, one set of well-run controls serves both. See our Saudi PDPL IT checklist and our guide to SDAIA’s proposed PDPL changes.

How Cre8 IT can help

Cre8 IT is registered with the National Cybersecurity Authority (NCA) as a cybersecurity service provider through the Haseen platform. We’re also ISO 27001:2022 certified, and we help Riyadh organisations run the controls in this guide day to day: Microsoft 365 security, multi-factor authentication, endpoint protection, patching, backups, 24/7 monitoring and incident response, with the evidence kept ready.

Not sure whether you’re Category A or B, or how far you are from compliance? Ask us for a gap assessment.

Sources and further reading

Written by
CEO, Cre8 IT
Rob Crossley is CEO of Cre8 IT, a Dubai-born managed IT and cyber security company that has supported businesses across the UAE, Saudi Arabia and the UK since 2012. Cre8 IT is certified to ISO 27001:2022 and ISO 9001 and is a certified Microsoft Partner.
FAQ

Frequently asked questions

What is NCNICC-1:2025?

The Non-CNI Private Sector Entities Cybersecurity Controls, issued by Saudi Arabia’s National Cybersecurity Authority. They set minimum cybersecurity requirements for private companies that are not critical national infrastructure.

Is my company Category A or Category B?

Category A covers large entities with more than 250 full-time employees or more than SAR 200 million annual revenue. Category B covers small and medium entities with 6 to 249 employees or revenue between SAR 3 million and SAR 200 million.

How many controls do SMEs have to meet?

Category B entities must meet 26 mandatory controls across 13 sub-components. The remaining controls that apply to large entities are recommended for SMEs rather than mandatory.

What is the deadline for NCNICC compliance?

There is no single national deadline. The NCA is reported to be notifying organisations individually with their own timelines, and it can assess compliance at any time, so it is sensible to start now.

Do the Non-CNI controls replace NCA ECC?

No. ECC-2:2024 continues to apply to government entities and critical national infrastructure. The Non-CNI controls cover private companies outside that scope.

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