The Phishing Simulation Masterplan: A Strategic Guide to Segmentation, Metrics, and ROI for NIS2 Compliance

The NIS2 Directive fundamentally transforms cybersecurity from an IT problem into a core board-level accountability issue. To meet these new standards, organizations must move beyond tracking simple failure rate metrics. A modern phishing simulation program is no longer just a training drill; it is a critical strategic tool to quantify human risk, demonstrate due diligence, and generate tangible, reportable ROI.

With phishing remaining the undisputed #1 attack vector, your simulation program is the frontline for NIS2 compliance. The directive explicitly demands measurable and demonstrable risk management, and legacy awareness training—unlike a modern phishing simulation program—simply fails to provide the data needed to prove effectiveness to auditors and the C-suite.

The primary mistake is treating simulations as a simple pass/fail test. A low failure rate can create a misleading sense of safety. The true value of a phishing simulation program lies in using it as a diagnostic tool to understand why and where your human risk hotspots exist.

This article provides the masterplan to build that program. We will guide you from basic metrics to an advanced strategy built on intelligent segmentation, sophisticated KPIs, and a clear business case for your leadership.

Core Concepts: NIS2, Risk, and Due Diligence

How does this masterplan help manage human risk? 

This plan shifts the focus from "awareness" to "behavior". By using advanced segmentation and metrics, you can identify your most vulnerable users, roles, and departments, allowing you to apply targeted interventions and demonstrably reduce your organization's overall attack surface.

Why the 'Failure Rate' Isn't Enough: Moving to Maturity Metrics

Relying solely on the phishing failure rate (or click rate) from your phishing simulation is a critical mistake in a modern risk management program. This single metric is dangerously misleading; a low failure rate doesn't necessarily mean you are secure. It often indicates that your simulations are too simple or that employees are suffering from testing fatigue. True security isn't just about not clicking—it's about building a resilient workforce that actively reports threats.

The limitations of the failure rate as a standalone metric

For years, the failure rate was the default KPI for security awareness. But what does a 5% failure rate truly tell you as a CISO or HR leader?

In our experience, this often means the simulations are so obvious they don't reflect the sophisticated, AI-generated attacks targeting your executives. Worse, it could signal employee disengagement, where staff simply ignore all suspicious emails (including your simulation) to avoid "failing the test," depriving your SOC of valuable threat intelligence.

Most importantly, the failure rate only measures a negative outcome. It completely ignores the positive, defensive behaviors you want to encourage.

Leading analysts echo this view. A guide on security awareness training, notes that the click rate is often a "vanity metric" that teams can "easily game". Chasing a 0% failure rate is unrealistic and fosters fear rather than a culture of defense.

Metrics that reveal true human resilience

To effectively manage human risk and satisfy NIS2's demand for demonstrable proof, your program must evolve. You need to track phishing KPIs that measure proactive defense and behavioral change. Tracking these metrics provides a holistic view of true human resilience and gives you actionable data for your board.

Your dashboard should prioritize these resilience metrics:

• Report Rate: This is your new primary KPI. What percentage of employees actively reported the simulated phish using the proper channels? A high report rate is a far better indicator of a strong security culture than a low failure rate.
• Mean Time to Report (MTTR): How long does it take, on average, for an employee to report a threat? A shorter MTTR means your SOC can react faster, neutralizing a real threat before it spreads.
• Repeat Click Rate: What percentage of employees who failed a simulation fail again within a set period (e.g., 6 months)? This helps identify high-risk groups needing targeted intervention, not just generic training.
• Individual/Departmental Resilience Scores: A composite metric that combines click rates, report rates, and learning progress to provide an auditable risk score for every part of the business.

Answering Your Questions on Phishing Metrics

What is a good phishing report rate? 

Unlike the failure rate, "higher is always better" for the report rate. Many mature programs aim for a report rate that is significantly higher than their failure rate (e.g., >70% report rate vs. <5% click rate), as this indicates a vigilant and engaged workforce.

How do these new phishing KPIs help with NIS2? 

NIS2 requires you to prove your risk management measures are working. Showing auditors a chart where your report rate increases and your Mean Time to Report (MTTR) decreases is tangible, measurable evidence of due diligence and continuous improvement.

Should I stop tracking the failure rate completely? 

No, but it should never be your only metric. Use it as one data point in a larger dashboard, alongside the report rate and MTTR, to get the full picture of your human risk posture.

The Cornerstone of Success: Advanced Segmentation for Effective Phishing Simulations

Advanced phishing segmentation is the most effective way to make your simulations relevant and accurately measure human risk. By tailoring your phishing simulation to specific employee groups, you move beyond generic, ineffective tests and gather actionable data on your true vulnerabilities. A one-size-fits-all program is inefficient, creates testing fatigue, and fails to provide the granular evidence of risk management required by NIS2.

Beyond the "one-size-fits-all" approach: Why segment your workforce

Sending the same generic "IT Password Reset" email to your entire workforce is an outdated method. It’s a box-ticking exercise, not a risk management strategy. This blanket approach is counterproductive.

It treats a C-suite executive with access to M&A data the same as a junior salesperson. Their access levels, knowledge, and the real-world threats they face are completely different. The result? The simulation is too easy for some, irrelevant for others, and you fail to measure the actual risk associated with each critical role.

Strategic segmentation criteria

To build a mature program, your workforce segmentation must be dynamic and risk-based. This approach is fundamental to authoritative frameworks like the NIST SP 800-50 Revision 1, which emphasizes tailoring awareness and training content to specific audiences.

Your segmentation strategy should go beyond simple department lists. Create dynamic groups based on:

1. Role and Access Privileges: A system administrator with root access is a high-value target and needs different simulations than the finance team handling invoices. C-suite and their Executive Assistants are a high-risk group of their own.
2. Risk Exposure: How often is the employee targeted? Public-facing teams like Sales and Customer Support are bombarded daily and require different conditioning than internal-only teams like R&D.
3. Performance History: Create a dynamic group of "repeat offenders" or users who consistently fail simulations. This segment needs more frequent, targeted micro-learning, not just another failed test.
4. Departmental Context: Grouping by department (Finance, HR, Legal, IT) allows you to use phishing templates that are contextually relevant to their daily workflow.

Let's consider a practical use case:

• Target: The Finance Department. The lure must be contextual. A phishing template mimicking an "Urgent Unpaid Invoice" from a major vendor, or a "Q4 Budget Variance" spreadsheet, is far more realistic and effective.
• Target: The Development Team. An "unpaid invoice" template will be immediately ignored. A more effective lure would be a "Critical Security Alert from GitHub," a "CI/CD Pipeline Failure Notification," or a "New Project Invite on Jira."

The goal isn't just to trick employees; it's to test their response to a plausible threat in their specific environment.

Common Questions on Workforce Segmentation

What is the first step in phishing segmentation?

Start by identifying your high-value targets (HVTs) and high-risk groups. This typically includes the C-suite, system administrators (high privilege), and finance/HR (high-sensitivity data access). Begin with these 4-5 key groups.

How granular should workforce segmentation be? 

It should be as granular as your data allows, but don't overcomplicate it at the start. Begin with role and department. You can then refine your segments over time by integrating performance history ("repeat clickers") and risk exposure.

Does NIS2 specifically require segmentation? 

NIS2 requires "risk management measures" that are effective and proportionate to the identified risks. Phishing segmentation is the primary method to prove your program is proportionate to the specific risks faced by different parts of your organization, making it a cornerstone of NIS2 due diligence.

Campaign and Template Design: From Generic to Hyper-Personalized

The success of your segmented program depends on using the right lure. Hyper-personalized phishing templates that mimic specific, real-world threats are essential for accurately measuring vulnerability and training employees to spot the attacks they will actually face. Generic, easy-to-spot emails only teach them to spot your simulations, not a real attacker's.

Crafting realistic and relevant lures for each segment

Once you have your segments, you must arm your attack simulation program with phishing templates that are contextually believable for each group. An attacker targeting your CFO isn't using the same lure as one targeting your helpdesk. Your phishing simulation program must reflect this reality.

This relevance is the key to gathering meaningful data. Here are practical examples of relevant lures by department:

• For the Finance Department: A lure themed around an "Urgent Unpaid Invoice," an "Urgent Wire Transfer Request," or a "Q4 Budget Variance" spreadsheet.
• For HR: A "Confidential Employee Complaint," a "Payroll System Update," or a "New Candidate Application" with a malicious attachment.
• For the C-Suite: A "Competitor M&A Intel" document, an "Urgent Legal Subpoena," or a spoofed email from their Executive Assistant.
• For IT/DevOps: A "VPN Security Alert," a "Source Code Repository Access Warning," or a "New Project Management Ticket" notification.

Integrating advanced attack vectors into your plan

Attackers are moving beyond email. A mature phishing simulation program must simulate the full spectrum of social engineering tactics. The MITRE ATT&CK framework for Phishing (T1566) details these varied sub-techniques, including attachments, links, and internal spearphishing.

To truly test resilience and meet NIS2 expectations, you must integrate these advanced attack vectors into your plan:

• QRishing (QR Phishing): Sending emails with malicious QR codes that lead to credential harvesting sites. This bypasses many email security filters and exploits mobile-first habits.
• Smishing (SMS Phishing): Using text messages for lures, often impersonating delivery services, internal IT alerts, or multi-factor authentication (MFA) resets.
• Vishing (Voice Phishing): Running vishing simulations to see if employees will give up credentials over the phone, especially with the rise of AI-driven deepfake voice scams.

Furthermore, the rise of AI-phishing means that attackers can now craft perfectly written, highly convincing lures at scale. Your phishing templates must evolve in sophistication to match this emerging threat.

Campaign Design & Cadence: Your Questions

What is the biggest mistake in phishing template design? 

The most common mistake we see is using the same easy, generic template for the whole company. It inflates your success metrics (low failure rate) but provides zero real-world risk data, giving a false sense of security that will not hold up under regulatory scrutiny.

What is AI-phishing? 

It is the use of Generative AI to create highly personalized and grammatically perfect phishing emails. It can mimic a specific person's writing style and context, making traditional red flags like "bad grammar" completely obsolete.

Should I warn employees before a Quishing or Vishing simulation? 

You should inform them that simulations of all types will happen as part of the overall program (this is key for HR/legal). However, do not warn them immediately before a specific test, as this defeats the purpose of measuring their genuine, in-the-moment response.

KPIs and ROSI: How to Measure and Demonstrate Your Program's Value 

You demonstrate the value of your phishing program by translating operational metrics into tangible business impact and calculating a clear phishing simulation ROI. This involves connecting resilience KPIs, like a high employee report rate, to measurable savings like reduced incident detection time (MTTD). This shift from viewing security as an operating expense to a business enabler is essential for executive support and NIS2 compliance.

From operational metrics to business impact indicators

Your board and executive leadership don't speak in "failure rates". They speak in risk reduction, cost savings, and compliance. The advanced cybersecurity KPIs we've discussed (like Report Rate and MTTR) are your raw data. Your job is to translate them into business impact indicators.

• Reduced Incident Detection Time (MTTD): A high report rate from trained employees turns your entire workforce into a 24/7 human sensor network. This drastically cuts your Mean Time to Detect, as your SOC gets real-time threat intelligence in minutes, not hours or days.
• Increased SOC Efficiency: A well-trained, high-reporting workforce sends fewer false positives to the SOC. They become better at identifying real threats, freeing up valuable analyst time to focus on actual incidents instead of noise.
• Demonstrable Due Diligence: A dashboard showing a rising report rate and a decreasing repeat-offender rate isn't just an internal metric; it's auditable proof of compliance. This is precisely the kind of measurable, continuous improvement that regulators and auditors want to see under NIS2.

A simple model for calculating phishing simulation ROSI

You don't need a complex financial model to prove your program's worth. You can calculate a credible phishing simulation ROSI (​​Return Of Security Investment) by focusing on cost avoidance.

This simple, defensible formula provides a powerful business case:

ROSI = (Avoided Annual Cost of Phishing - Total Program Cost) / Total Program Cost

• Total Program Cost: This is straightforward—your platform subscription, administrative overhead, and any internal resources used.
• Avoided Annual Cost: This is the critical variable. You estimate this using authoritative, third-party benchmarks. For example, the official IBM Cost of a Data Breach Report states that the global average cost of a data breach in 2025 is in the millions.

By demonstrating that your program measurably reduces your failure rate and improves your report rate—and thus the likelihood of a catastrophic breach—you can justify the "Avoided Cost". Even preventing a single major phishing-induced incident can deliver a program ROSI of over 1000%.

FAQs on Phishing ROSI & Business Value

What's more important for NIS2: a low failure rate or a high report rate?

A high report rate, without question. You can easily "game" a low failure rate with easy tests. A high, fast report rate is auditable proof of a resilient, engaged workforce, which is exactly what NIS2's due diligence articles require.

How does measuring human risk help the SOC?

It transforms employees from the biggest liability into the organization's largest sensor network. A high employee report rate (with a low MTTR) is the fastest and most cost-effective way to detect an active attack, feeding real-time threat intel directly to your SOC.

Conclusion: Simulation as a Pillar of Due Diligence Under NIS2

A modern phishing simulation program is no longer a simple compliance task; it is an essential diagnostic tool for proactive human risk management. Under NIS2, it serves as the most effective, data-driven way to demonstrate executive due diligence and protect the organization from its most significant attack vector.

As we've detailed, moving beyond the simple failure rate to embrace advanced metrics (like Report Rate), hyper-segmentation, and a clear ROSI calculation transforms your program from a "pass/fail" test into a sophisticated risk management component.

This is the tangible proof that leadership needs. A well-structured program provides the auditable evidence critical for demonstrating the due diligence required of the Board and C-Suite, shifting the conversation from "did they click?" to "how resilient is our business?"

It’s time to rethink your strategy and adopt a masterplan that provides the maturity, metrics, and risk visibility that NIS2 demands.

Final Takeaways: Your Key Questions Answered

What is the main impact of NIS2 on phishing simulations? 

NIS2 elevates them from a "nice-to-have" training tool to a mandatory component of due diligence. It requires measurable, continuous proof that you are effectively managing your human risk, making a mature simulation program essential for C-suite reporting.

How do phishing simulations help with NIS2 Directive compliance?

NIS2 requires organizations to implement risk management policies and train their employees. Simulations provide measurable, auditable proof that this training is effective and that the organization is proactively managing its top cyber risk vector.

How does a good phishing simulation program demonstrate NIS2 due diligence?

It provides measurable, auditable proof of continuous improvement. By showing rising report rates, faster MTTR, and targeted risk reduction in high-risk segments, you provide tangible evidence that management is proactively addressing human risk.

Is phishing simulation the same as human risk management?

No. Phishing simulation is a critical diagnostic tool within a broader human risk management strategy. It helps you find, measure, and quantify the risk, allowing you to apply the right, targeted interventions to fix it.

Why isn't failure rate the most important metric anymore?

It only measures a negative outcome (a click). It fails to measure positive, resilient behaviors, such as an employee reporting the phish. A low failure rate might just mean your simulations are too easy, not that your employees are secure.

What is a good failure rate for a phishing campaign?

There is no single target number. A "good" failure rate depends on the simulation's difficulty and the program's maturity. The goal isn't to reach zero, but to see a downward trend in clicks and a steady increase in the reporting rate.

How often should you run phishing simulations?

We recommend a quarterly cadence. Consistency is key to building muscle memory and maintaining awareness, avoiding predictable campaigns that lose effectiveness. This regular testing is a key requirement for demonstrating NIS2 compliance.

How do I present phishing simulation ROSI to the board?

Focus on risk reduction and cost avoidance. Present it as a strategic, mandatory investment, not an optional IT cost. Use the "Avoided Annual Cost" calculation based on trusted sources like the IBM report to frame the discussion.

What is the main takeaway for a CISO to report to the board?

The key takeaway is ROSI and quantifiable risk reduction. A mature program's value is not just "awareness" but cost avoidance (preventing a breach) and faster incident response, turning employees into a core part of the defense.

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