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Privacy Daily Brief

NIS2 Compliance Checklist 2025: Redis CVSS 10, Ransomware Lessons

Siena Novak
Siena NovakVerified Privacy Expert
Privacy & Compliance Analyst
8 min read

Key Takeaways

8 min read
  • Regulatory Update: Latest EU privacy, GDPR, and cybersecurity policy changes affecting organizations.
  • Compliance Requirements: Actionable steps for legal, IT, and security teams to maintain regulatory compliance.
  • Risk Mitigation: Key threats, enforcement actions, and best practices to protect sensitive data.
  • Practical Tools: Secure document anonymization and processing solutions at www.cyrolo.eu.
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NIS2 compliance checklist for 2025: lessons from the Redis CVSS 10 flaw and new ransomware campaigns

In today’s Brussels briefing, regulators reiterated that NIS2 is no longer a future concern—it’s the baseline for resilience across essential and important entities. With a 13-year-old Redis flaw now rated CVSS 10 enabling remote code execution, and fresh campaigns from Storm-1175 and Cl0p abusing third-party software, teams are asking for a practical NIS2 compliance checklist they can execute immediately. Below I break down what to do this quarter, how it ties to GDPR, and how to reduce exposure when you must share or analyze sensitive documents.

Why NIS2 matters now

NIS2 has been transposed across EU Member States, with supervision intensifying through 2025. The directive sets tougher cybersecurity compliance duties, broader sector coverage (from energy and finance to healthcare, digital infrastructure, and managed services), and real consequences:

  • Fines up to €10 million or 2% of global annual turnover for essential/important entities, depending on the infringement.
  • Mandatory incident reporting: early warning within 24 hours, incident notification within 72 hours, and a final report within one month.
  • Board-level accountability: management can be held liable for ignoring risk management measures.

As one CISO put it to me last week: “The days of treating vulnerability management as a best-effort task are over.” In parallel, the cost of a privacy breach remains sobering—industry studies peg the global average at roughly €4.5–€5 million in 2024, before counting regulatory actions or lost customers.

NIS2 compliance checklist (actionable in 30–90 days)

  • Governance and scope
    • Confirm whether you’re classified as an essential or important entity; document your regulators and legal obligations per Member State.
    • Appoint accountable owners; brief the board on NIS2 and GDPR intersections.
  • Asset inventory and exposure
    • Maintain a living inventory of internet-facing services, third-party platforms, and business-critical systems (e.g., Redis, Oracle EBS, file transfer gateways).
    • Map data flows and personal data locations to support GDPR-compliant processing and security audits.
  • Vulnerability management
    • Adopt risk-based patching SLAs: e.g., CVSS 9.0–10.0 within 72 hours, critical internet-facing within 24–48 hours.
    • Continuously monitor for exploited-in-the-wild flaws (e.g., legacy Redis CVSS 10, Oracle EBS CVE-2025-61882).
  • Incident detection and reporting
    • Instrument detection for ransomware tradecraft (e.g., Storm-1175 using third-party file transfer exploits to drop Medusa ransomware).
    • Prepare NIS2 reporting templates aligned to 24h/72h/1-month milestones; run tabletop exercises.
  • Third-party and supply chain risk
    • Require suppliers to meet baseline controls (MFA, logging, encryption, patch SLAs); validate with evidence.
    • Track vendor advisories for actively exploited issues; verify compensating controls where patching lags.
  • Data protection by design (GDPR + NIS2)
    • Minimize personal data in operational workflows; anonymize where feasible before sharing with vendors or AI tools.
    • Use an AI anonymizer to remove names, IDs, addresses, and sensitive attributes from tickets, logs, and case files.
  • Secure document handling
    • Shift to secure document uploads for internal review and AI-assisted analysis; restrict who can download originals.
    • Log every access for auditability; enforce retention and deletion policies.
  • Logging, monitoring, and response
    • Centralize telemetry (EDR, NDR, IAM, application logs); keep evidence for regulator requests.
    • Automate containment for known ransomware TTPs; test recovery with immutable backups.
  • Training and drills
    • Run phishing and credential theft simulations; brief engineers on secure configuration of Redis, Oracle EBS, and file transfer software.
    • Rehearse NIS2 reporting with legal and communications teams to avoid missteps during live incidents.

What the latest attacks teach NIS2 programs

Three developments this morning underline why operational discipline matters:

  • Redis CVSS 10 flaw: A 13-year-old bug now weaponized for remote code execution. Takeaway: if a service is business-critical and internet-exposed, prioritize compensating controls (network segmentation, auth hardening, allowlists) even before patches land.
  • Storm-1175 + Medusa: Microsoft-linked reporting ties the actor to a GoAnywhere-style exploit chain delivering ransomware. Takeaway: file transfer and middleware systems are high-value and often overprivileged; reduce blast radius and monitor for data staging.
  • Cl0p targeting Oracle EBS (CVE-2025-61882): Real-world exploitation against ERP suites. Takeaway: ERP change windows must accommodate emergency patching; if you cannot patch, disable vulnerable modules and increase detective controls.

Map each risk to a control owner and deadline. Under NIS2, regulators expect evidence of risk treatment decisions—not just intentions.

GDPR vs NIS2: how obligations differ (and overlap)

Area GDPR NIS2
Scope Processing of personal data by controllers/processors Cybersecurity risk management for essential/important entities across critical sectors
Primary objective Data protection and privacy rights Network and information systems security and resilience
Incident reporting 72-hour breach notification to data protection authority if personal data affected Early warning in 24h, incident notification in 72h, final report within one month
Fines Up to €20M or 4% of global turnover Up to €10M or 2% of global turnover (Member State specifics may vary)
Technical measures Data minimization, encryption, pseudonymization Vulnerability management, supply chain risk, business continuity, logging, security audits

EU vs US: different enforcement cultures

EU regulators under NIS2 will increasingly ask for documented risk management, tested incident processes, and supply chain evidence. In the US, sectoral rules (e.g., GLBA, HIPAA) and rapid SEC disclosure expectations shape behavior, but fewer prescriptive cross-sector risk measures exist. If you operate transatlantically, harmonize your control set to the stricter regime and localize only where necessary.

Secure-by-design document workflows (without data leaks)

NIS2 and GDPR converge on one practical rule: do not expose personal data or sensitive operational details when you don’t have to. That’s especially true when security teams share logs, screenshots, and case notes with vendors or feed documents into AI assistants.

  • Automatically strip personal identifiers and business secrets using Cyrolo’s anonymizer. Professionals avoid risk by using Cyrolo’s anonymizer instead of manual redaction.
  • Move off email attachments. Use Cyrolo’s secure document reader for controlled, audited, and expiring access to PDF, DOC, and images—no sensitive data leaks.

Compliance 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 my interviews with banks, hospitals, and law firms this summer, the highest-risk moments weren’t zero-days—they were rushed uploads to external tools under incident pressure. Simple guardrails around anonymization and controlled viewing dramatically reduce breach fallout and regulator scrutiny.

Quick start plan: 30/60/90 days

Day 0–30

  • Confirm NIS2 classification and regulators; assign executive sponsor.
  • Freeze internet exposure: inventory Redis, ERP, file transfer, and IAM services; enforce strong auth and network allowlisting.
  • Implement critical patch SLAs for CVSS ≥9.0; deploy emergency mitigations where patching is not yet possible.

Day 31–60

  • Stand up incident reporting runbooks for 24h/72h/1-month; run one tabletop.
  • Contractualize supplier requirements; collect evidence of patching and logging.
  • Roll out Cyrolo for anonymization and secure document uploads in SOC and legal workflows.

Day 61–90

  • Integrate telemetry into SIEM/EDR; enable immutable backups and recovery tests.
  • Schedule a security audit mapped to NIS2 Articles 21–23 risk measures.
  • Train staff on secure handling of personal data and privacy breach prevention.

Practical scenarios: mapping news to controls

  • Fintech using Redis for session storage: Restrict Redis to internal networks, require authentication, rotate keys, and monitor anomalous client commands. If internet-exposed, isolate immediately and review for RCE indicators. Document actions for NIS2 evidence.
  • Healthcare provider with legacy Oracle EBS: Apply vendor mitigations for CVE-2025-61882, disable vulnerable modules, and put a 7-day change window for patching. Maintain an audit trail and notify the regulator if availability or confidentiality was materially impacted.
  • Law firm relying on a managed file transfer platform: Validate MFA, IP allowlists, and latest hotfixes. If compromise suspected, use anonymized case files via Cyrolo’s secure document reader to coordinate with incident responders without exposing client identities.

FAQ: NIS2 compliance in plain language

What is the fastest way to meet NIS2 incident reporting timelines?

Pre-build a 24h/72h/1-month reporting pack: executive summary, impact assessment, indicators of compromise, and mitigations. Assign an on-call legal contact. Run a monthly tabletop so your team can produce regulator-ready updates in hours, not days.

Does NIS2 replace GDPR for security incidents?

No. NIS2 and GDPR run in parallel. If personal data is affected, you may need to notify the data protection authority under GDPR within 72 hours, in addition to NIS2’s staged notifications to your CSIRT/competent authority.

Are anonymization tools acceptable to regulators?

Yes, if they are effective and consistently applied. Regulators favor data minimization. Use an AI anonymizer to remove personal data before sharing logs or documents externally, and keep audit evidence.

How do fines actually get decided?

Authorities consider the severity, duration, negligence, and cooperation level, plus prior violations. Strong documentation of risk treatment and timely reporting substantially mitigates outcomes.

What about US operations?

Align with the stricter regime (EU). Map NIS2 controls to US sectoral rules and SEC disclosure norms. One control framework, multiple mappings, fewer gaps.

Conclusion: your NIS2 compliance checklist is your resilience plan

The threat headlines will keep coming—today it’s a Redis CVSS 10 flaw, tomorrow a new supply-chain exploit. A living NIS2 compliance checklist keeps your organization defensible with regulators and safer for customers. Start with risk-based patching, disciplined reporting, and secure document handling. Professionals avoid risk by using Cyrolo’s anonymizer and secure document reader—try them today and cut both breach and compliance risk.