CSA 2 Needs an Execution Substrate: SMB-Viable Continuous Governance for Cyber Resilience

SA 2 makes important strides toward harmonization, simplification, and cross-border coherence. However, the proposal still assumes the existence of a continuous governance substrate that most SMBs do not have and cannot practically build. As written, CSA 2 risks reproducing the same structural gap seen in NIS 2, CRA, and the AI Act: policy goals without the operational mechanisms required to generate evidence, maintain compliance, or demonstrate good-faith behavior. Static certification frameworks and outcome-based language fail SMBs in the same way—they describe the destination without providing the execution layer that produces verifiable behavioral signals. A ransomware safe-harbor provision, for example, is only meaningful if an organization can generate a continuous audit trail showing patching behavior, access-control changes, model-update decisions, and incident-response actions. Most SMBs lack the telemetry, automation, and governance primitives needed to produce this evidence. The first recommendation below is foundational to all that follow: without a defined minimal execution substrate, recommendations on certification alignment, safe-harbor eligibility, and open tooling have no operational floor to stand on. Similarly, 'harmonized risk management' cannot be realized if the underlying behavioral signal is absent. CI/CD pipelines, cloud-native architectures, and increasingly agentic AI systems require governance that is embedded at the substrate layer: machine-readable controls, automated attestations, and continuous evidence generation. Without this, harmonization becomes an administrative exercise rather than a resilience-building mechanism.