NIS2 Compliance in 2025: Brussels Briefing, DSA Enforcement, and a Practical Checklist You Can Use Today

In today’s Brussels briefing, one message echoed from regulators and CISOs alike: 2025 is the first real year of NIS2 compliance. With the European Commission levying a €120 million fine against a major platform under the Digital Services Act, LIBE preparing another packed agenda on platform accountability, and fresh zero‑click and supply chain exploits hitting European networks, the era of “paper compliance” is over. If you handle critical services or essential data flows, NIS2 compliance is now a board-level imperative—on par with GDPR and, for financial services, DORA. This piece distills what changed, how audits will bite, and how to operationalize secure document handling and AI workflows without risking privacy breaches.

What NIS2 Really Requires in 2025

Member States transposed NIS2 in late 2024. Throughout 2025, regulators and CSIRTs will test whether “essential” and “important” entities have moved from policy to practice. Based on conversations with national authorities and a CISO I interviewed in Frankfurt, here’s what’s drawing scrutiny:

• Governance and accountability: Boards must oversee cybersecurity risk. Expect requests for minutes showing risk briefings, budget decisions, and security KPIs.
• Risk management measures: Demonstrable controls for asset inventory, patching, monitoring, secure development, incident response, business continuity, and supply chain security.
• Incident reporting: Early warning to the competent authority/CSIRT within 24 hours of becoming aware of a significant incident, a more complete incident notification within 72 hours, and a final report within one month.
• Supply chain due diligence: Third-party risk reviews tied to criticality, contractual security requirements, and rapid takedown/containment plans.
• Technical hygiene that withstands audits: verifiable logging, vulnerability management, MFA, segmentation, and encryption—particularly around personal data and critical operational technology.

As one CISO told me this week: “We thought NIS2 was about IT. It’s actually about how the board steers existential risk.”

GDPR vs NIS2: The obligations you must reconcile

Compliance teams often underestimate the overlaps. GDPR governs personal data protection; NIS2 targets network and service resilience. You need both. Here’s a practical side-by-side view:

GDPR vs NIS2 obligations (what auditors ask first)

Dimension	GDPR	NIS2
Primary focus	Data protection and privacy of personal data	Cybersecurity risk management and service resilience
Scope	Controllers and processors handling personal data	Essential and important entities in defined sectors (energy, health, digital infrastructure, manufacturing, finance, etc.)
Incident reporting timeline	Notify data protection authority within 72 hours of becoming aware of a personal data breach	Early warning to CSIRT/authority within 24 hours; more complete notice within 72 hours; final report within 1 month
Fines	Up to €20 million or 4% of global annual turnover	Essential entities: up to €10 million or 2% of global turnover; Important entities: up to €7 million or 1.4%
Security measures	Appropriate technical/organizational measures; privacy by design and by default	Risk management measures across prevention, detection, response, and supply chain security
Board liability	Leadership accountability implied but sectoral	Explicit management oversight and potential personal consequences in some national regimes

NIS2 Compliance Checklist for CISOs and DPOs

Use this pragmatic list to structure your security audits and board updates:

• Map scope and criticality:
  • Identify essential/important entities across your group and subsidiaries.
  • List critical services, supporting assets, data flows, and dependencies.
• Governance and roles:
  • Board briefings on NIS2 risk quarterly; record decisions and budgets.
  • Appoint a NIS2 liaison and define RACI with SOC, privacy, legal, and procurement.
• Vulnerability and patch management:
  • Prioritize internet-facing and third-party components.
  • Patch high/critical vulns within defined SLAs. This week’s headlines—an XXE in Apache Tika (CVSS 10) and active exploitation of “React2Shell”—belong on your emergency patch docket if used in your stack.
• Detection and logging:
  • Centralize logs with retention aligned to incident reconstruction needs.
  • Deploy EDR/NDR for real-time detection and triage playbooks for zero-click phishing/browser attacks.
• Incident reporting workflow:
  • Pre-draft 24h early-warning templates; define thresholds for “significant” incidents.
  • Maintain regulator and CSIRT contact lists; test the process with tabletop exercises.
• Supplier and platform risk:
  • Tier vendors by criticality; require security attestations and rapid remediation clauses.
  • Monitor platforms for DSA-related enforcement signals that may affect your content or ad operations.
• Secure document handling and AI:
  • Prohibit uploading personal or confidential data to public LLMs.
  • Standardize an AI anonymizer workflow for internal AI use cases.
  • Adopt a secure document upload tool that enforces encryption-at-rest and at-transfer, audit trails, and access controls.
• Data minimization and protection:
  • Apply pseudonymization/anonymization to personal data in testing, analytics, and AI prompts.
  • Encrypt sensitive records; enforce strict access reviews.
• Business continuity and crisis communications:
  • Document RTO/RPO for critical services; run failover tests quarterly.
  • Pre-approve plain-language customer notices for downtime and breaches.

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.

Why enforcement momentum matters: DSA today, NIS2 tomorrow

The Commission’s €120 million DSA penalty this week is a wake-up call. It validates what EU regulators stressed to me in recent briefings: once the legal hooks are in place, enforcement follows swiftly. LIBE’s upcoming agenda signals continued pressure on platform risk, transparency, and cross-border issues—signals that ripple into NIS2, where competent authorities will now expect measurable controls, not promises.

For security leaders, the lesson is straightforward: assume audits in 2025 will request technical evidence (patch timelines, alert volumes, MFA coverage) and governance proof (board minutes, budget approvals, risk heatmaps). If you treat NIS2 like GDPR’s security article rebadged, you will miss supply chain and service resilience requirements that auditors now treat as non-negotiable.

Sector spotlights: manufacturing, healthcare, media

• Manufacturing: The threat landscape has become markedly harsher, with ransomware groups pivoting to OT-adjacent systems and new zero-click paths via corporate SaaS and browser sessions. For NIS2, segment OT/IT, map dependencies to critical lines, and pre-arrange offline restoration for PLC engineering workstations.
• Healthcare: Collective redress actions are gaining traction. Hospitals and digital health platforms face dual exposure: GDPR class actions over personal data misuse and NIS2 scrutiny over service outages. Minimize exposure by anonymizing health data in analytics and AI workflows, and deploy strict access and audit logging for e-health systems.
• Media and platforms: The DSA fine underscores systemic risk around recommender systems, content moderation, and transparency. Media orgs using generative AI for production or research should formalize red-teaming, watermark checks, and safe prompt handling with an anonymization step baked in.

AI, documents, and the new compliance baseline

Three concrete developments are shaping 2025 controls:

1. Zero-click and agentic phishing now exploit browser trust and session tokens—raising the bar for least privilege, device posture checks, and rigorous patching.
2. Widely used content parsers (like Apache Tika) can become a single point of catastrophic failure if unpatched. If your e-discovery, knowledge ingestion, or document readers rely on them, treat this as an emergency change window.
3. Shadow AI and ungoverned uploads to public models create untracked data exposure. Regulators increasingly expect documented AI governance, including data minimization for prompts, human-in-the-loop review for high-risk outputs, and secure tools for uploads.

Professionals avoid risk by using Cyrolo’s anonymizer to strip personal data before analysis, and by relying on a secure document upload workflow—so sensitive material never leaks to unmanaged services.

DORA, AI Act, and the 2025 EU puzzle

For financial entities, DORA applies from January 2025, locking in ICT risk management, incident reporting, testing, and third-party oversight. Many controls overlap with NIS2—logging, detection, red-teaming, and supplier management—but DORA adds operational resilience testing and stricter oversight of critical ICT providers. Meanwhile, the AI Act phases in obligations over 2025–2026, with high-risk AI systems facing conformity assessments and post-market monitoring. Security, privacy, and explainability obligations from AI projects should be wired into your NIS2 control set, not bolted on later.

What this means for your next audit

• Show unified control evidence that satisfies NIS2, GDPR, and DORA where applicable.
• Demonstrate AI governance: inventories of models and use cases, data minimization rules, and sanitization via an AI anonymizer.
• Produce incident runbooks that bifurcate DPA notifications (GDPR) and CSIRT early warnings (NIS2) with clear decision criteria.

From policy to practice: a 30–60–90 day plan

If you need to de-risk fast, sequence work like this:

• Days 1–30: Confirm NIS2 scope, update risk register, patch critical vulns (Tika/React stacks if relevant), and lock down SSO/MFA. Mandate secure document uploads and anonymization for all AI workflows.
• Days 31–60: Finalize incident thresholds, build 24h/72h reporting templates, run a tabletop with Legal/Comms/IT, and roll out supplier security addenda.
• Days 61–90: Implement continuous monitoring KPIs, schedule resilience tests, and brief the board with a funding plan and audit-ready evidence pack.

FAQs

What is NIS2 compliance and who is in scope?

NIS2 applies to “essential” and “important” entities across sectors such as energy, transport, health, digital infrastructure, water, manufacturing, and finance. Compliance means implementing risk management, incident reporting, and supply chain security measures, with documented governance and technical evidence to back it up.

How do NIS2 reporting timelines interact with GDPR breach notifications?

They run in parallel. For a significant incident under NIS2, you must send an early warning within 24 hours and a more complete notice within 72 hours. If personal data is involved, GDPR requires notifying the supervisory authority within 72 hours as well. Your runbook should distinguish when both apply and ensure coordinated messaging.

Does NIS2 require anonymization of personal data?

NIS2 doesn’t mandate anonymization per se, but it expects risk-based controls. Pseudonymization/anonymization reduce impact and reporting scope for incidents and are considered good practice under both NIS2 risk management and GDPR’s data protection by design.

Are uploads to public LLMs allowed under EU regulations?

Regulations don’t ban AI usage, but they expect security, privacy, and governance. Avoid feeding confidential or personal data to public LLMs; implement approved, secure workflows that sanitize data first.

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.

How do DORA and NIS2 overlap for financial institutions?

Both require robust ICT risk management, incident reporting, testing, and third‑party oversight. DORA is sector‑specific and prescriptive on operational resilience testing and critical ICT providers. Align evidence so one control satisfies both where possible.

Conclusion: make NIS2 compliance your competitive advantage

2025 will reward organizations that operationalize NIS2 compliance—governance, patching, logging, reporting, and secure supplier and AI workflows—with fewer outages, lower legal exposure, and faster audits. The enforcement drumbeat is unmistakable: DSA fines this week, NIS2 audits next. Standardize safe data handling now: anonymize personal data with Cyrolo’s anonymizer, and move sensitive files through a secure document upload process. Strong controls don’t just meet EU regulations—they build trust your customers can feel.