NIS2 compliance: What the Cisco VPN and email attack campaigns mean for your 2025 EU risk posture

Two coordinated threat campaigns targeting Cisco VPN endpoints and enterprise email services this week are an uncomfortable reminder: NIS2 compliance is not a paperwork exercise, it’s an operational baseline. In yesterday’s Brussels briefing, regulators stressed that edge devices and business email remain the EU’s most common breach vectors in 2025. A CISO I interviewed after the disclosure put it bluntly: “VPNs and mail gateways are the front door—and the door is often left on the latch.” If you operate in the EU, the new rules, from incident reporting to supply chain due diligence, now bite.

Why the latest VPN and email campaigns matter for NIS2 compliance

Here’s what practitioners are seeing across EU Security Operations Centers (SOCs) as the Cisco VPN and email service campaigns unfold—and how that maps to NIS2 obligations:

• Attack pattern: password spraying and MFA fatigue against VPN portals. NIS2 mandate: strong authentication and access control, monitoring of authentication events, risk-based MFA.
• Attack pattern: session hijacking via outdated client configurations, weak device posture checks. NIS2 mandate: asset management and vulnerability handling; documented patching SLAs for edge devices.
• Attack pattern: business email compromise (BEC) through OAuth token abuse and consent phishing. NIS2 mandate: security of network and information systems, including email hardening and continuous monitoring.
• Attack pattern: supply chain pivoting via managed email providers and third-party VPN concentrators. NIS2 mandate: supplier risk management and contractual security assurances.

In several EU incidents I reviewed this quarter, attackers never “exploited a zero-day.” They chained trivial gaps: shared admin accounts on VPN gateways, stale TLS configurations, and weak DMARC on email domains. Under NIS2, those are not just hygiene issues—they’re compliance findings that competent authorities can sanction.

What EU regulators and CISOs are signaling

• Regulators: Expect early-warning notices within 24 hours for significant service interruptions or integrity impacts, followed by a 72-hour incident notification and a final report within one month.
• CISOs: Prepare to show audit trails—centralized logs for VPN auth attempts, email forwarding rule changes, consent grants, and admin role assignments—retained per your sector’s guidance.
• Boards: Demonstrate budgeted resilience measures: enforced MFA, automated patching for edge gear, and email authentication (SPF, DKIM, DMARC) with DMARC set to quarantine or reject.

NIS2 compliance timelines and what to do during a live incident

With most Member States enforcing national NIS2 transpositions throughout 2025, incident playbooks must reflect the directive’s notification staircase:

1. Within 24 hours: Early warning to your national CSIRT/competent authority for significant incidents—flag cross-border effects and suspected criminal activity.
2. Within 72 hours: Incident notification with impact, root-cause hypotheses, and mitigation steps taken.
3. Within 1 month: Final report with full root-cause analysis, indicators of compromise, lessons learned, and planned long-term fixes.

For VPN/email attacks, that means you should have, ready-to-run:

• Pre-approved takedown steps: disable legacy VPN protocols, rotate admin credentials, revoke OAuth tokens, and enforce conditional access.
• Automated forensics: export of VPN auth logs, SAML events, mailbox rule changes, and third-party app consents.
• Supplier notification templates: quickly escalate to your managed email or network provider and document their response times for regulator reviews.

GDPR vs NIS2: how obligations differ when VPN and email are hit

Many EU organizations ask whether a VPN or email compromise is “GDPR” or “NIS2.” Often, it’s both. Here’s the snapshot:

Topic	GDPR	NIS2
Primary focus	Protection of personal data and data subject rights	Security and resilience of network and information systems
Who is in scope	Controllers and processors handling personal data	Essential and important entities across sectors (e.g., energy, finance, health, digital infrastructure, managed services)
Incident trigger	Personal data breach likely to risk individuals’ rights and freedoms	Significant incident impacting service availability, authenticity, integrity, or confidentiality
Deadlines	Notify DPA within 72 hours; inform data subjects without undue delay if high risk	Early warning within 24 hours; incident notification within 72 hours; final report within one month
Example controls	Data minimization, encryption, DPIAs, access controls	Risk management policies, incident handling, business continuity, supply chain security, vulnerability handling, testing
Penalties	Up to €20M or 4% of global annual turnover	Essential entities: up to €10M or 2%; important entities: up to €7M or 1.4%
Audits	DPA investigations, records of processing, DPIA reviews	Security audits and inspections by competent authorities and CSIRTs

Practical controls checklist for EU operators

Use this condensed checklist to reduce exposure from VPN and email threats and to evidence program maturity during audits:

• Identity and access
  • MFA enforced for all remote access; ban SMS where feasible; use phishing-resistant factors for admins.
  • Just-in-time privileged access; no shared admin accounts on VPN gateways.
• Edge device hardening
  • Maintain an SBOM and firmware currency register for VPN/concentrators; apply critical patches within defined SLAs.
  • Disable legacy protocols (e.g., TLS 1.0/1.1), enforce strong ciphers, and geo-fence where appropriate.
• Email security
  • SPF, DKIM, and DMARC at p=quarantine or reject; MTA-STS and TLS-RPT enabled.
  • Monitor mailbox rule creation, OAuth consent grants, and impossible-travel alerts.
• Monitoring and logging
  • Centralize VPN, IdP, and mail logs; retain per regulator guidance; map to MITRE ATT&CK use cases.
  • Automated anomaly detection on VPN auth spikes and consent phishing patterns.
• Supply chain and vendors
  • Security clauses in MSP/ISP/email provider contracts: patching cadence, incident cooperation, and log access.
  • Annual third-party risk reviews aligned to NIS2 supplier requirements.
• Data protection
  • Encrypt mail archives and VPN session caches where feasible; minimize personal data in support logs.
  • Use an AI anonymizer before sharing artefacts with external tools or LLMs.
• Exercises and training
  • Run phishing and consent-grant drills; test VPN failover and break-glass accounts quarterly.
  • Tabletop the 24h/72h/1-month notification sequence with legal and PR.

AI, document handling, and anonymization: stop leaks before they start

Investigations into VPN and email incidents routinely involve sharing logs, screenshots, and contracts with external tools. That’s where many privacy breaches begin. Professionals avoid risk by using Cyrolo’s anonymizer to redact names, emails, IDs, and other personal data before analysis. And when you must share case files, try our secure document upload at www.cyrolo.eu — no sensitive data leaks.

Compliance note: When uploading documents to LLMs like ChatGPT or others, never include confidential or sensitive data. The best practice is to use www.cyrolo.eu — a secure platform where PDF, DOC, JPG, and other files can be safely uploaded.

NIS2 compliance and the vendor angle: VPNs and email services are “in scope”

NIS2 elevates supplier due diligence from optional to essential. If your VPN concentrator or email is managed by a third party, you remain accountable. A telecom operator in Central Europe told me last month they were asked by their competent authority to produce: the MSP’s patch timeline for edge devices, evidence of DMARC enforcement, and a log-sharing agreement for rapid incident response. If you can’t produce those within days, you’ll struggle in a post-incident audit.

Sector snapshots: what “good” looks like in 2025

• Banks/fintechs: enforce phishing-resistant MFA (FIDO2) for all VPN admins, DMARC at reject, consent governance for third-party mail apps, and 24/7 SOC correlation of identity and mail telemetry.
• Hospitals: segment remote access by clinical role, disable legacy IMAP/POP, pre-authorize emergency break-glass, and encrypt mail backups to prevent ransomware double-extortion.
• Law firms: default-deny external mail forwarding, watermark sensitive attachments, and anonymize case files before sharing with AI workflows using www.cyrolo.eu.

EU vs US: different playbooks, overlapping lessons

While the US lacks a NIS2-style cross-sector directive, regulators are tightening disclosure (e.g., 4-business-day incident reporting for public companies) and critical infrastructure rules via sector bodies. The EU’s approach is more prescriptive on controls and supply chain oversight, with formal security audits by competent authorities. If you operate transatlantically, align on the strictest common denominator: identity-first edge security, rapid notification, and vendor accountability.

Budgeting and board reporting: make it measurable

Boards in 2025 want numbers that map to risk and compliance:

• Time-to-patch for VPN firmware (critical: under 7 days)
• DMARC enforcement rate across domains (target: 100%)
• MFA coverage for remote access (target: 100%; phishing-resistant for admins)
• Mean time to revoke malicious OAuth consents (target: under 1 hour)
• Incident notification rehearsal frequency (quarterly)

Pair these with heatmaps of supplier risk and evidence packs for audits. And don’t overlook data handling: anonymize investigation artefacts with www.cyrolo.eu before any external review.

FAQ: real questions EU teams are asking

Does a VPN brute-force attempt trigger NIS2 reporting?

Not usually. Unsuccessful attacks are typically logged and monitored. Reporting is triggered by a significant incident—e.g., credential stuffing leading to service disruption or data integrity compromise. Keep evidence if volume or origin indicates a broader campaign.

Our email tenant saw suspicious OAuth consents. Is that GDPR or NIS2?

Potentially both. If personal data was accessed, GDPR breach rules apply. If the event affected service integrity or availability, NIS2 applies. Conduct a joint assessment with legal and report per both frameworks as needed.

What penalties can we face for poor edge security under NIS2?

Essential entities face up to €10M or 2% of global turnover; important entities up to €7M or 1.4%. Penalties scale with negligence, impact, and cooperation quality during audits.

How do we safely share logs with external analysts or AI tools?

Never include raw personal data or secrets. Redact with an AI anonymizer and use a secure document workflow. Try www.cyrolo.eu for safe uploads and anonymization.

What evidence will auditors want after a VPN/email incident?

Timeline of events, central logs, configurations, patch status, supplier communications, and proof of 24h/72h/1-month notifications. Include lessons learned and remediation roadmaps.

Conclusion: NIS2 compliance is your blueprint for resilient VPN and email operations

The week’s Cisco VPN and email attacks are a stress test many EU organizations failed before 2025. With NIS2 compliance now fully in play, focus on identity-first controls, hardened edge devices, email authentication, and supplier accountability. Build notification muscle memory, anonymize sensitive artefacts, and use trusted platforms for sharing. When in doubt, protect before you process: handle incident documents via www.cyrolo.eu and strip personal data with an anonymizer so investigations don’t create new risks.