NIS2 Compliance Checklist: Surviving AI-Era Threats and EU Enforcement in 2025

In today’s Brussels briefing, regulators reiterated that enforcement is entering a new phase: sectoral supervisors will expect concrete proof of NIS2 maturity, not slideware. If you’re mapping controls right now, this NIS2 compliance checklist is designed for the realities of 2025—AI-powered phishing kits, browser-based GenAI, and supply chain risks. It connects the dots between EU regulations like GDPR and NIS2, cybersecurity compliance obligations, and practical controls such as using an AI anonymizer and secure document uploads to reduce data exposure.

Why NIS2 is a different kind of EU regulation

While GDPR transformed how we treat personal data, NIS2 elevates operational resilience and incident response across essential and important entities—from finance and health to digital infrastructure and managed services. Member states transposed NIS2 in late 2024; in 2025, regulators are moving from guidance to inspections, security audits, and penalties. A CISO I interviewed last month put it bluntly: “We handled privacy notices for GDPR. For NIS2, I need provable cyber risk management, 24/7 incident reporting muscle, and executive accountability.”

• Scope expands to more sectors and “important entities,” including many SaaS, MSPs, and B2B platforms.
• Governance is front and center: boards must oversee risk, training, and investments; negligence can trigger sanctions.
• Incident reporting is faster and deeper: early warning within 24 hours, incident notification within 72 hours, and a final report within one month.
• Penalties climb: fines up to €10 million or 2% of global turnover for essential entities in many transpositions.

GDPR vs NIS2: obligations compared

Topic	GDPR	NIS2
Primary focus	Personal data protection and privacy rights	Network and information security, service continuity, and resilience
Who’s in scope	Any controller/processor handling EU personal data	Essential and important entities in specified sectors (e.g., energy, finance, health, digital providers, MSPs)
Incident reporting	Notify DPA within 72 hours if breach risks rights/freedoms	Early warning within 24h, notification within 72h, final report within 1 month to competent authority/CSIRT
Governance	DPO for certain orgs; privacy by design	Executive accountability; board oversight; risk management and supply chain security
Fines	Up to €20M or 4% global turnover	Up to €10M or 2% global turnover (country-specific ceilings may vary)
Proof of compliance	Records of processing, DPIAs, processor contracts	Policies, technical measures, incident logs, supplier controls, training, and periodic testing

NIS2 compliance checklist

Use this prioritized, audit-friendly list to prepare for inspections and security audits. It reflects themes raised by EU regulators and the patterns I’m hearing in CISO roundtables.

• Scope and classification
  • Confirm whether you are an essential or important entity under national NIS2 law.
  • Map critical services, systems, and dependencies (clouds, MSPs, identity providers).
• Risk management program
  • Document a risk management methodology aligned with ISO 27001/2, NIST CSF, or equivalent.
  • Include specific treatments for phishing-resilient MFA, browser isolation, and GenAI data controls.
• Technical and organizational measures
  • Harden identity: phishing-resistant MFA, conditional access, and admin tiering.
  • Network segmentation, EDR/XDR, vulnerability/risk-based patching cadence.
  • Backups with immutability and tested restoration objectives (RPO/RTO).
  • Data protection: minimize personal data; adopt anonymization workflows before sharing.
• Incident reporting readiness
  • Automate time-stamping and evidence capture for the 24h/72h/1-month reporting windows.
  • Run tabletop exercises that include cross-border notifications and sectoral regulators.
• Supply chain security
  • Risk-rate vendors; require security attestations (e.g., ISO 27001, SOC 2) and incident SLAs.
  • Contractual clauses for rapid notification, forensics cooperation, and regulator access.
• Governance and training
  • Board-approved NIS2 policy; named accountable executive.
  • Annual training with phishing simulations and GenAI data-handling modules.
• Documentation and evidence
  • Maintain an auditable trail: risk registers, asset lists, change logs, incident postmortems.
  • Secure document handling for uploads and reviews; avoid mixing confidential data in LLM chats.

Professionals avoid risk by using Cyrolo’s anonymizer and secure document upload — no sensitive data leaks.

AI-driven threats: what changes in 2025

Two trends stood out in recent EU and industry briefings: AI-enhanced phishing kits that bypass weak MFA flows, and the rapid adoption of GenAI in the browser—often outside corporate guardrails. Banks and fintechs report credential theft campaigns that mirror internal SSO prompts; hospitals see targeted lures using patient-facing terminology; law firms face exfiltration through browser extensions. In each case, attackers leverage speed, personalization, and session token theft.

Controls that actually work

• Harden MFA: favor FIDO2/passkeys or platform-bound authenticators over OTP/SMS; block push fatigue with number matching and geo-velocity checks.
• Browser policy and isolation: disable unvetted extensions, sandbox GenAI sessions, and prevent token reuse across tabs and profiles.
• Data minimization: scrub personal data before testing prompts, sharing logs, or filing tickets.
• Segment admin planes: separate admin browsers and identities; enforce step-up authentication for privileged actions.

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.

Practical workflows: privacy plus resilience

GDPR and NIS2 are converging in daily operations. Here’s how teams reduce both privacy breach and resilience risk:

• Pre-share redaction: run contracts, logs, and tickets through an AI anonymizer to remove personal data and secrets before collaboration. Try www.cyrolo.eu to operationalize anonymization at upload time.
• Secure evidence handling: keep incident artifacts in a centralized, access-controlled vault; use secure document uploads for regulator-ready packets.
• Vendor due diligence: require suppliers handling personal data or operational telemetry to demonstrate both GDPR and NIS2 controls; test their incident reporting clocks.

Regulatory realism: what EU authorities will ask for

From discussions with national authorities and CSIRTs, expect these requests during inspections or after significant incidents:

• Show me the board minutes approving your NIS2 plan and budget.
• Prove your 24h/72h reporting runbooks—who decides severity, who contacts whom, and where evidence is stored.
• Demonstrate phishing-resistant MFA adoption rates, not just policy intent.
• Walk through a recent tabletop: actions taken, gaps found, and the patch to fix them.
• Supply chain map: critical vendors, inherited risks, and contingency plans if a provider is down for 48 hours.

EU vs US: different paths, same risks

The EU’s approach hardwires security-by-governance, with prescriptive reporting and penalties across sectors. The U.S. continues to regulate via sectoral levers—transport, finance, markets disclosure—while federal privacy remains fragmented. One unexpected consequence EU CISOs note: NIS2 pushes earlier executive engagement on cyber budgets, while U.S. peers often cite board attention primarily around disclosure liability. For multinationals, harmonize on the stricter common denominator to avoid divergent control sets.

Sector snapshots I’m hearing from the field

• Banks and fintechs: Running blue-team drills on SSO token theft; mandating passkeys for staff and high-risk partners; accelerating supplier questionnaires aligned with NIS2.
• Hospitals: Segmenting clinical networks, rolling out EDR to legacy endpoints, and anonymizing patient identifiers when triaging incidents and sharing case notes.
• Law firms and professional services: Browser policy lockdowns; client data rooms only; default redaction for exhibits before review in AI tools.

All three sectors emphasize the same theme: data minimization and clean evidence pipelines. That’s why many teams standardize on anonymization and secure document uploads before anything leaves the tenant.

Executive actions for Q1

• Confirm NIS2 classification and notify authorities where required.
• Approve a risk treatment plan with explicit funding for MFA, browser security, and backup modernization.
• Schedule a regulator-style incident exercise, including a 24-hour early warning dry run.
• Mandate redaction/anonymization for all external shares and AI workflows; standardize on www.cyrolo.eu.

FAQs

Who needs to comply with NIS2?

Essential and important entities in sectors like energy, finance, health, transport, water, public administration, and key digital providers (including some MSPs and cloud services). Scope and thresholds are set in each member state’s transposition.

How is NIS2 different from GDPR?

GDPR targets personal data protection; NIS2 targets the resilience and security of services. You may need to comply with both—one handles privacy rights and breach notices; the other demands robust security controls, incident reporting within 24/72 hours, and board-level oversight.

What are the NIS2 incident reporting timelines?

Typically: early warning within 24 hours of awareness, a more detailed notification within 72 hours, and a final report within one month. Check your national implementation for exact requirements.

How should we handle GenAI and document uploads under NIS2?

Apply strict data minimization. Remove personal data and secrets before sharing or testing prompts. Use secure upload and review channels with audit trails. 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.

What penalties can regulators impose under NIS2?

Many transpositions set fines up to €10 million or 2% of global turnover for essential entities, with lower—but still material—caps for important entities. Authorities can also mandate remediation and, in some cases, impose management accountability measures.

Bottom line: your path to credible NIS2 compliance

NIS2 forces a step-change in operational resilience: provable governance, faster reporting, hardened identity, and secure data handling. Use this NIS2 compliance checklist to focus investments where regulators and attackers both look first. Reduce risk exposure by anonymizing data and centralizing evidence—start with anonymization and secure document uploads at the source. The organizations that practice now will find 2025 inspections routine—and keep AI-era attackers at bay.