NIS2 compliance: A 2026 reality check after new spear‑phishing waves

In today’s Brussels briefing, regulators repeated a blunt message: most major incidents still start with a malicious email. The timing is uncanny. This week’s spear‑phishing campaigns in the Middle East, including a new remote access trojan reportedly deployed via weaponized attachments, mirror the techniques EU incident responders keep seeing at home. If your organization operates essential or important services, your NIS2 compliance posture in 2026 will be judged on how well you prevent, detect, and report exactly these email‑borne intrusions—without creating new risks through careless data handling or AI tool misuse.

I’m Siena Novak, and over the past quarter I’ve sat with CISOs from banks, hospitals, and public administrations who are tightening controls ahead of national supervisory audits. Their bottom line: phishing defense, secure document workflows, and provable governance now determine whether you pass an inspection—or face fines and remediation orders.

What NIS2 compliance means in 2026

NIS2 (Directive (EU) 2022/2555) has been transposed across Member States, expanding security and incident reporting duties for “essential” and “important” entities across sectors like energy, banking, healthcare, transport, digital infrastructure, ICT service management, public administration, and more. Supervisors have authority to demand evidence, conduct audits, and sanction non‑compliance.

• Risk management and governance: Board‑level accountability, policies, asset inventory, vulnerability handling, supply‑chain security, and business continuity planning.
• Incident reporting: Early warning within 24 hours of becoming aware of a significant incident; follow‑up report within 72 hours; final report within one month (check national transposition specifics).
• Technical controls: Multi‑factor authentication, network segmentation, logging and monitoring, cryptography, and secure development practices where applicable.
• Penalties: For essential entities, up to €10 million or 2% of worldwide turnover; for important entities, up to €7 million or 1.4%—plus potential management liability and supervision measures.

GDPR still applies in parallel when personal data is involved—typically the case in phishing, identity takeover, and exfiltration scenarios. Expect dual scrutiny: data protection regulators and NIS2 competent authorities may both call.

The phishing problem regulators keep stressing

In back‑to‑back meetings I’ve attended in Brussels and with national CSIRTs, officials emphasized that the “first click” is still the most cost‑effective point of failure for attackers—and the cheapest point of control for defenders. A CISO I interviewed at a Central European bank described a recent dry‑run: a convincingly spoofed procurement thread with a compressed “invoice” led to endpoint execution in under four minutes. Only strict attachment sandboxing and identity‑aware email policies stopped lateral movement.

Three lessons keep repeating across cases:

• Weaponized attachments are back: compressed or “scanned” PDFs and office docs that drop loaders or call out to malicious CDNs.
• Thread hijacking works: attackers reply inside existing supplier chains; users trust the context and bypass scrutiny.
• Post‑compromise speed matters: containment within the first 30 minutes dramatically lowers breach cost and reporting scope.

The link to NIS2 is direct: your controls around email, document handling, and supplier communications form part of your “state of the art” security measures. Failure to deploy reasonable safeguards can translate into supervisory findings—and where personal data is implicated, GDPR breach notifications and potential fines up to €20 million or 4% of global turnover.

GDPR vs NIS2: obligations at a glance

Topic	GDPR	NIS2
Scope	Personal data processing by controllers/processors in the EU (and extraterritorially in some cases)	Security of network and information systems for essential/important entities in specified sectors
Primary Goal	Protect rights and freedoms of individuals (privacy)	Ensure resilience and continuity of critical services (security)
Incident Reporting	Notify DPA within 72 hours if personal data breach likely impacts rights/freedoms; notify individuals when high risk	Early warning within 24 hours; update within 72 hours; final report within one month for significant incidents
Governance	Data protection officer (when required), DPIAs, records of processing	Board accountability, security policies, risk management, supply‑chain oversight, audits
Sanctions	Up to €20m or 4% global turnover	Up to €10m or 2% (essential) and €7m or 1.4% (important), plus corrective measures

NIS2 compliance in practice: controls that pass audits

• Email and identity security: DMARC/DKIM/SPF enforcement, phishing‑resistant MFA, conditional access, role‑based privileges.
• Attachment handling: Content disarm and reconstruction (CDR), sandboxing, and strict policies for macros and compressed files.
• Logging and response: Centralized logs, 30‑day hot retention minimum for email and endpoint events, playbooks and tabletop exercises.
• Supplier channel protection: Vendor domain verification, secure portals, and contractual security clauses with evidence of adherence.
• Document workflows: Anonymize or redact personal and confidential data before sharing outside your core systems.

Professionals avoid risk by using Cyrolo’s anonymizer at www.cyrolo.eu to strip names, IDs, and other personal identifiers before analysis, testing, or external collaboration. Try our secure document upload at www.cyrolo.eu — no sensitive data leaks.

Build safer AI‑assisted workflows without risking fines

• Use an AI anonymizer to remove personal data before sending files to third‑party tools or partners.
• Keep a chain of custody: who uploaded what, when, with which policy applied, and where outputs were stored.
• Segregate workloads: different data classifications, different tools and networks.

Mandatory 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.

Compliance checklist for Q1 2026

• Map NIS2 applicability: confirm entity classification (essential or important) and in‑scope services.
• Approve Board‑level security policy including phishing defense, supplier risk, and incident reporting procedures.
• Run a phishing tabletop: simulate thread‑hijack plus weaponized attachment; record MTTD/MTTR and actions taken.
• Deploy phishing‑resistant MFA for admins and high‑risk roles; enforce least privilege across mail and file systems.
• Implement attachment CDR/sandboxing; block password‑protected archives unless explicitly approved.
• Establish a documented anonymization workflow for personal/confidential data. Use www.cyrolo.eu to automate redaction before sharing.
• Prepare incident templates: 24‑hour early warning, 72‑hour update, and one‑month final report; align with GDPR breach notices when needed.
• Evidence everything: logs, training records, vendor assurances, and outcomes of security audits.

Lessons from the latest spear‑phishing waves

Campaigns I reviewed this week used multilingual lures and “regional” supplier impersonation. The attachments were tuned to local software defaults, ensuring execution paths on EU systems. Notably, several victims only discovered lateral movement when finance systems flagged anomalous session tokens—well after endpoint alerts. Two takeaways for EU teams:

• Identity telemetry is your early warning: impossible travel, unusual consent grants, and mailbox rule changes catch what AV misses.
• Data‑minimizing workflows blunt impact: the less personal data stored in mailboxes and shared drives, the smaller your GDPR and NIS2 blast radius.

How Cyrolo supports secure document uploads and anonymization

Your incident playbooks depend on predictable, safe handling of files. That’s where operational tooling matters:

• AI anonymizer: Automatically remove personal identifiers, client names, case numbers, and other sensitive fields before files leave your secure boundary. Point counsel, auditors, or vendors to sanitized versions only.
• Secure document uploads: Centralize where staff send PDFs, DOCs, images, and logs, with guardrails that prevent data spill and create an audit trail that satisfies both NIS2 and GDPR expectations. Start at www.cyrolo.eu.
• Prove compliance: Export evidence of anonymization and access controls during supervisory reviews.

Whether you’re a hospital sharing a discharge summary for model testing, a fintech submitting logs to a supplier, or a law firm briefing external counsel, minimizing personal data is the fastest way to reduce regulatory risk. Use www.cyrolo.eu to make that default behavior.

EU vs US: different regulatory rhythms, same phishing reality

The US still leans sectoral (health, finance, critical infrastructure) and breach‑notification‑oriented, while the EU layers systemic resilience (NIS2) atop comprehensive privacy (GDPR). But adversaries don’t care about jurisdictional nuance—they weaponize trust and documents. European organizations that operationalize anonymization and strong email defenses are faring better in audits and real‑world incidents alike.

FAQ

What is the NIS2 compliance deadline and is it already enforceable?

Member States had to transpose NIS2 by October 2024. In 2026, national rules apply and supervisors are actively auditing essential and important entities. Check your national authority for sector‑specific guidance and timelines.

Does NIS2 apply to SMEs?

Yes, if an SME provides services listed in NIS2 as essential or important (e.g., certain digital infrastructure or managed service providers) or is designated by a Member State due to risk profile. Size alone doesn’t always exempt you.

How does NIS2 treat phishing and email‑borne malware?

NIS2 is technology‑neutral but expects risk‑appropriate controls. For email, that typically includes MFA, secure email gateways, attachment sandboxing/CDR, user training, and rapid incident reporting when a significant incident occurs.

How should we handle AI tools under GDPR and NIS2?

Apply data minimization and anonymization before uploading files to any third‑party AI. Keep audit trails, restrict access, and validate vendors. For safety, route sensitive files through a secure anonymizer and upload platform such as www.cyrolo.eu.

What evidence do auditors expect for NIS2?

Policies approved at the right governance level, proof of control operation (logs, configurations), results of exercises, supplier assurance artifacts, and incident report templates. Demonstrating anonymization and safe document workflows is increasingly common.

Conclusion: make NIS2 compliance your phishing antidote

The latest spear‑phishing waves are a reminder that resilient services and privacy go hand‑in‑hand. Treat documents as potential attack vectors and potential liabilities under GDPR, and bake anonymization plus secure uploads into daily practice. If you need a fast, defensible way to reduce exposure, use the AI anonymizer and secure document uploads at www.cyrolo.eu. In 2026, NIS2 compliance is not just a regulatory checkbox—it’s your best defense against the next email that lands in your users’ inboxes.