Phishing simulation — regular simulated phishing tests conducted; failure rates tracked and reducing

Trigger

When this rule fires

No phishing simulation programme; simulations conducted less than quarterly; failure rates not tracked or not declining over time

Applicability gate

Confirm the entity's role before treating this as a duty

This is a readiness rule mapped to JS2 themes. Its presence in the library does not establish that JS2 applies directly to the firm.

• Insurance Broker: Most independent non-life Category I brokers are not directly in JS2's defined scope. A broker may be directly in scope if it separately meets a listed category, and may face contract or oversight requirements from an in-scope institution. Third-party provisions impose duties on the in-scope financial institution. They do not themselves make every supplier or intermediary directly subject to JS2.
• Uma Binder Holder: UMA or binder-holder status is not itself listed in JS2's definition. Direct scope depends on another listed capacity; insurer contracts and oversight may create evidence requirements. JS2 paragraph 3.3 concerns juristic persons structured under an insurer or designated insurance group; it is not a blanket rule for every independent UMA or intermediary.
• Insurer: An insurer as defined in the Insurance Act is directly in scope of JS2 from 1 June 2025. Apply proportionality and distinguish the insurer's own duty from requirements it places on third parties.

Citation

Mapped source

This control maps to the public instruments below. The mapping does not establish entity applicability.

Section

Joint Standard 2 of 2024 — paragraph 7.2.7 (awareness and training) / NIST SP800-50

Legislation

• Joint Standard 2 of 2024

Remediation

How to close the gap

Implement a phishing simulation platform. Run monthly or quarterly simulations varying attack type (credential harvest, malware, BEC). Track click-through and report rates. Auto-enrol failures in targeted training.

Evidence required

Evidence to prepare if this control applies

• Phishing simulation platform configuration
• Simulation results (last 4 campaigns) with click rates
• Failure rate trend showing improvement
• Targeted training completion for failures