Cybersecurity Compliance in Saudi Arabia:

Why SAP Authorization & SAP Security Are Now a Board-Level OblIGATION

Saudi Arabia has established one of the most comprehensive national cybersecurity regulatory frameworks worldwide. With the issuance of the Essential Cybersecurity Controls – ECC-2:2024 by the National Cybersecurity Authority (NCA), cybersecurity is no longer a matter of internal IT best practice. It is now a binding regulatory requirement for organizations operating within the Kingdom.

For CEOs and CIOs running SAP landscapes, this is a fundamental shift: SAP Authorization and SAP Security have become legally enforceable compliance disciplines. The ECC explicitly classifies enterprise systems that support financial operations, HR, logistics, procurement, and executive decision-making as critical information assets, which places typical SAP systems directly under its regulatory scope (ECC 1-2, Asset Classification) .

Failure to implement adequate access governance, monitoring, and incident management is therefore not only a security weakness — it is a regulatory violation with executive accountability.

Identity & Access Management in SAP Is a Legal Control — Not an IT Preference

The ECC requires every organization to implement a formal Identity & Access Management framework that enforces least privilege, role-based access, segregation of duties, and privileged access protection (ECC 2-2-1 to 2-2-3: Identity and Access Management Controls) .

In practical SAP terms, this means that:
Unrestricted use of SAP_ALL, shared administrator accounts, and permanent firefighter access is no longer compliant. The regulation explicitly requires:

• Separation of conflicting duties (ECC 2-2-3-3)
• Protection of privileged users through additional security mechanisms such as MFA and session monitoring (ECC 2-2-3-4)
• Periodic access reviews and revocation of unnecessary privileges (ECC 2-2-3-5)

From a regulatory standpoint, an SAP system in which users can create vendors, post invoices, and execute payments within the same role structure represents a direct breach of mandatory national cybersecurity controls.

Logging, Monitoring and Auditability Are Mandatory for SAP

The ECC places very strong emphasis on continuous monitoring and traceability of security-relevant activities. Organizations must ensure that logs from critical systems are created, protected, retained, and actively monitored (ECC 2-12-1 to 2-12-5: Cybersecurity Logging and Monitoring) .

Applied to SAP, this creates clear regulatory obligations:
Security-relevant events such as user creation, role changes, emergency access usage, remote logons, and critical business transactions must be fully logged, tamper-proof, and centrally monitored. The ECC explicitly requires log integrity and protection against manipulation (ECC 2-12-4), as well as sufficient retention periods for forensic investigations (ECC 2-12-5).

An SAP system without active Security Audit Log, change logging, and SIEM integration is therefore not defensible in a regulatory audit.

Incident Response and Regulatory Reporting Also Apply to SAP Systems

Cyber incidents do not only refer to malware attacks or network intrusions. The ECC clearly defines cybersecurity incidents as any compromise of confidentiality, integrity, or availability of information systems (ECC 2-13: Cybersecurity Incident and Threat Management) .

This includes:

• Compromised SAP user accounts
• Abuse of privileged authorizations
• Unauthorized data extraction
• Manipulation of financial postings or master data

The ECC requires:

• Formal incident response plans
• Defined escalation paths to management
• External reporting of severe incidents to competent national authorities (ECC 2-13-3 and 2-13-4)

If SAP incidents are not detectable due to missing logs or weak monitoring, organizations are structurally unable to fulfil their statutory reporting duties — which in itself constitutes a compliance breach.

Cloud and Outsourced SAP Operations Do Not Remove Regulatory Liability

Many organizations operate SAP on hyperscalers or with managed service providers. However, ECC 4-1 and 4-2 explicitly regulate third-party and cloud cybersecurity responsibilities .

The regulation makes it unambiguous:
The customer remains fully responsible for cybersecurity compliance — even when the system is outsourced.

For SAP, this means that:
Access control, logging, incident response, and data protection requirements must be contractually and technically enforceable against cloud and hosting providers. The ECC explicitly requires third-party risk assessments, security clauses, and continuous oversight (ECC 4-1-2 and 4-2-3).

From a governance perspective, moving SAP to the cloud does not reduce compliance obligations — it increases governance complexity.

Executive Accountability Under Saudi Cybersecurity Law

What makes ECC-2:2024 particularly relevant for executives is its clear governance and accountability framework. Cybersecurity is defined as a board- and executive-level responsibility, not an IT-only function (ECC 1-4: Cybersecurity Governance) .

Senior management is obligated to:

• Ensure implementation of cybersecurity controls
• Allocate sufficient resources
• Oversee risk management
• Enforce internal accountability mechanisms

In regulated sectors such as finance, energy, healthcare, and critical infrastructure, deficiencies in SAP Security can directly translate into licensing risks, regulatory sanctions, and personal liability.

Why This Matters Strategically for CEOs and CIOs

From a business perspective, weak SAP Security in Saudi Arabia today represents more than a technical vulnerability. It creates:

• Direct regulatory non-compliance risk
• Financial fraud exposure
• Operational shutdown risk following cyber incidents
• Personal accountability for executive management
• Loss of trust with regulators, partners, and state entities

ECC-2:2024 positions cybersecurity as an element of national economic resilience. SAP, as the digital backbone of most large enterprises, is therefore one of the primary regulatory focus areas.

What Executives Should Do Now

A compliant organization should immediately ensure:

• A formal SAP Authorization & Segregation of Duties framework aligned with ECC 2-2
• Privileged Access Management and MFA for SAP administrators
• End-to-end SAP logging and SIEM integration according to ECC 2-12
• A documented SAP incident response and regulatory reporting process under ECC 2-13
• A third-party and cloud risk governance model for SAP under ECC 4-1 and 4-2

This is not about technical optimization. It is about maintaining the organization’s legal right to operate securely within the Kingdom.

Final Thought for the Boardroom

Saudi Arabia is not merely encouraging cybersecurity maturity — it is legally enforcing it.
Organizations that proactively align their SAP Security with ECC-2:2024 will benefit from:

• Regulatory trust
• Stronger digital resilience
• Reduced executive liability
• Sustainable growth in a tightly regulated digital economy

Those who delay alignment risk discovering their exposure only during a cyber incident or a formal NCA audit.

🔒 Cybersecurity is no longer an IT topic.

📊 In Saudi Arabia, it is a matter of national compliance and executive responsibility.

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