NIS2 compliance 2025: What EU regulators expect now (and how to pass audits without a privacy breach)

From Brussels to Berlin, the message is consistent: NIS2 compliance is no longer a distant deadline but an operational requirement under active supervision. In today’s Brussels briefing, officials recapped the September joint session of LIBE and FEMM and stressed that 2025 is about execution—proof of risk management, supply-chain controls, incident reporting, and evidence that staff aren’t leaking personal data through shadow AI tools. Below I unpack what regulators are asking for, how this intersects with GDPR, and how security and legal teams can reduce audit exposure with practical steps—especially around anonymization and secure document uploads.

What NIS2 compliance requires in 2025

In the September committee minutes and subsequent regulator roundtables, supervisors emphasized tangible security measures and governance. Here’s what they’re checking on-site and in desk audits:

• Risk management and governance: documented policies approved by the board; named accountable executives; regular reviews.
• Technical controls: multi-factor authentication, network segmentation, encryption, secure logging, and monitored remote access.
• Supply-chain security: due diligence on vendors; contractual security clauses; continuous monitoring of third-party risk.
• Incident reporting: early warning within 24 hours to CSIRTs/competent authorities, with final reports and lessons learned.
• Business continuity: tested backup/restore, ransomware playbooks, and alternative communications.
• Training and awareness: anti-phishing drills, AI usage rules, and role-based privacy/security training.
• Data protection alignment: mapping of personal data flows to meet GDPR while meeting NIS2’s system resilience duties.

Fines are real: essential entities face up to at least €10 million or 2% of global turnover; important entities up to at least €7 million or 1.4%. A CISO I interviewed warned: “The fastest way to fail a NIS2 audit is to have great policies but no evidence of daily enforcement—especially around uncontrolled document uploads to AI tools.”

GDPR vs NIS2: what overlaps and what’s different

Many teams ask if NIS2 replaces GDPR. It doesn’t. GDPR protects personal data; NIS2 secures network and information systems. You need both.

Topic	GDPR	NIS2
Primary focus	Personal data and privacy rights	Cybersecurity resilience of essential/important entities
Scope trigger	Processing personal data	Operating in covered sectors with material impact on society/economy
Key obligations	Lawful basis, DPIAs, data minimization, breach notifications to DPAs	Risk management, incident reporting to CSIRTs, supply-chain security, governance
Fines (max)	Up to 4% global turnover	Essential: ≥ €10m or 2%; Important: ≥ €7m or 1.4%
Audit evidence	Records of processing, DPIAs, processor contracts, data subject response logs	Security policies, technical controls, vendor assessments, incident & continuity tests
AI/tool usage	Minimize personal data, ensure lawful processing, anonymize where possible	Prevent system/data compromise; control shadow IT and unsafe uploads

The operational risk: AI, shadow uploads, and supply-chain exposure

Regulators told me they increasingly see privacy breaches beginning as “productivity hacks.” A lawyer uploads a client memo to an online LLM for summarization; a clinician pastes a discharge note into a free OCR site; a project manager drags a vendor contract into a consumer-grade translation app. The intent is efficiency. The outcome is uncontrolled personal data sharing and a loss of chain-of-custody—risk under both GDPR and NIS2.

Mandatory safety reminder: 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.

In audits this year, supervisors asked specifically for: AI usage policies, logs of document uploads, and evidence of anonymization for training/evaluation data. That means you must be able to show where files went, who accessed them, and whether personal data was removed or masked.

NIS2 compliance: a practical blueprint you can implement this quarter

• Map critical systems and data: identify essential services, dependencies, and personal data flows.
• Harden access: enforce MFA everywhere; restrict admin privileges; segment high-risk systems.
• Instrument logging and detection: centralized logs, alerts on exfiltration and unusual uploads.
• Vendor controls: tier suppliers; require security addenda; collect SOC2/ISO/pen-test evidence.
• Incident readiness: define 24-hour notification steps; rehearse with tabletop exercises.
• Train for AI safety: set rules for generative AI; require anonymization before any external processing.
• Prove it: maintain dated screenshots, tickets, and exports to show control effectiveness to auditors.

Tools that cut audit risk: anonymization and secure document uploads

Two controls shrink both GDPR and NIS2 exposure: removing identifiers and controlling where documents go.

• Use an AI anonymizer to strip names, emails, addresses, IDs, and free-text PII before analysis, translation, or LLM prompts. Professionals avoid risk by using Cyrolo's anonymizer at www.cyrolo.eu.
• Route all sensitive document uploads through an enterprise-safe gateway that logs access and enforces deletion. Try our secure document upload at www.cyrolo.eu — no sensitive data leaks.

I’ve seen this work in practice:

• Banks and fintechs: redact client identifiers from transaction narratives before fraud model tuning; restrict staff to a logged, compliant upload path.
• Hospitals: de-identify discharge notes and radiology reports for analytics; ensure clinical staff cannot paste PHI into consumer AI tools.
• Law firms: anonymize case materials prior to cross-border reviews; maintain a defensible chain-of-custody for every file.

These steps translate directly into audit-ready evidence: anonymization logs, access records, and a provable trail that sensitive files were handled in a compliant manner.

What auditors will ask you to show

• Policy to practice: where are AI/document handling rules written, and how are they enforced technically?
• Tickets and timestamps: examples of vendor risk reviews, patch rollouts, and backup restore tests.
• Incident drill artifacts: tabletop agendas, attendees, outcomes, and remediation tickets.
• Evidence of minimization: before/after samples showing anonymized data; logs from your anonymizer.
• Upload governance: proof that staff used a secure channel for document uploads, not ad-hoc tools.

Compliance checklist for NIS2 and GDPR alignment

• Appoint accountable executives and approve a cybersecurity policy at the board level.
• Classify systems and data; complete a risk assessment tied to controls and investments.
• Implement MFA, network segmentation, encryption at rest/in transit, and EDR.
• Establish incident reporting workflows that meet NIS2 timing and GDPR breach notifications.
• Tier suppliers; require security clauses and ongoing assurance from critical vendors.
• Define AI usage rules; require anonymization before any external processing.
• Adopt a secure upload pathway for all sensitive files—centralized logs, retention, and deletion.
• Run quarterly tabletop exercises and at least annual backup/restore tests.
• Maintain audit evidence: change tickets, training records, scan results, anonymization logs.

EU vs US: different philosophies, same direction

EU rules lean toward prescriptive governance and fines via GDPR/NIS2; US rules increasingly come through sectoral regulators and incident disclosure mandates. Yet both expect demonstrable risk management, documented vendor oversight, and provable control efficacy. If you can show a secure pipeline for sensitive documents and automatic anonymization prior to analysis, you will satisfy most supervisory expectations on both sides of the Atlantic.

FAQ

What is the fastest way to show NIS2 compliance progress?

Create an evidence binder: board-approved security policy, risk assessment, MFA rollout proof, vendor tiering, incident reporting workflow, and logs showing secure, controlled document uploads.

Does anonymization satisfy GDPR requirements?

Anonymization that is irreversible and robust falls outside GDPR’s scope. Pseudonymization does not. Use tools designed to remove direct and indirect identifiers. An AI anonymizer can automate this across PDFs, images, and text.

How do NIS2 and GDPR interact during a breach?

Report cybersecurity incidents to the competent authority/CSIRT under NIS2, and personal data breaches to the DPA under GDPR. Your playbook should handle both streams with consistent facts and timelines.

What are typical NIS2 fines?

Essential entities: up to at least €10 million or 2% of global turnover; important entities: up to at least €7 million or 1.4%. Regulators also impose corrective measures and enhanced supervision.

How do we stop staff uploading sensitive files to random AI tools?

Blocklist risky destinations, whitelist a secure gateway, and train staff. Provide a safe alternative: try the secure pathway at www.cyrolo.eu for controlled uploads and built-in anonymization.

Conclusion: make NIS2 compliance routine, not a fire drill

NIS2 compliance in 2025 is about daily discipline you can prove: hardened access, vendor oversight, incident readiness, and safe data handling. Remove identifiers before analysis, channel every sensitive file through a governed upload, and keep audit-grade evidence. To reduce risk today, use an AI anonymizer and secure document uploads at www.cyrolo.eu. It’s the simplest path to resilience without sacrificing productivity.