NIS2 compliance: Lessons from the Infy APT resurgence and what EU firms must do now

As the Iranian “Infy” APT reportedly reappears after years of quiet, boards across Europe are asking what this means for NIS2 compliance. In today’s Brussels briefing, regulators emphasized that state-backed campaigns are precisely the threat model baked into NIS2’s mandatory risk management, incident reporting, and supply chain obligations. For organisations already juggling GDPR duties, the message is blunt: harmonise your security controls, get reporting-ready, and remove personal data from operational workflows—especially when using AI tools or sharing documents externally.

What the Infy APT resurgence means for NIS2 compliance

Infy’s return is an unwelcome but timely reminder that sophisticated intrusion sets target EU essential and important entities—energy operators, hospitals, banks, logistics providers, managed service providers, and SaaS vendors. A CISO I interviewed this week put it plainly: “We don’t get to choose when an APT knocks; we only choose whether the door is reinforced.” Under NIS2, that reinforcement must be demonstrable.

• Risk management expectations: NIS2 requires documented policies for incident handling, vulnerability management, multi-factor authentication, encryption, and backup/BCP testing—validated through audits and board oversight.
• Incident reporting clock: Early warning to the national CSIRT within 24 hours, a more detailed notification at 72 hours, and a final report within one month. Without pre-approved playbooks and clean evidence trails, those deadlines are unforgiving.
• Supply chain due diligence: If your MSP or software vendor gets compromised, regulators will still ask what risk assessments, contractual security clauses, and monitoring you had in place.
• Data protection crossover: Security incidents that implicate personal data can trigger parallel GDPR notifications. That means one event, two regulators, and two timelines.

Professionals avoid risk by using Cyrolo’s anonymizer to strip personal data from threat reports, tickets, and AI prompts—so indicators of compromise can be shared without leaking sensitive information or violating privacy rules.

GDPR vs. NIS2: obligations compared

Many teams still treat GDPR and NIS2 as separate tracks. They aren’t. Think of GDPR as the “what” (protect personal data) and NIS2 as the “how” (establish and prove operational resilience across critical services). Here’s a quick side-by-side:

Dimension	GDPR	NIS2
Scope	Personal data processing by controllers/processors	Cybersecurity risk management for essential and important entities (Annex I & II sectors)
Primary focus	Privacy and data protection rights	Service continuity, resilience, and incident response
Incident reporting	To DPAs when personal data breaches risk individuals’ rights/freedoms	To national CSIRTs/competent authorities within 24h (early warning), 72h (notification), and one month (final report)
Sanctions	Up to €20M or 4% of global annual turnover (whichever higher)	Up to €10M or 2% of global annual turnover (Member State transposition applies)
Security measures	Appropriate technical/organisational measures; pseudonymisation, encryption	Mandatory risk management measures; MFA, patching, logging, supply chain controls, business continuity testing
AI/document handling	Minimise personal data; lawful basis; DPIAs where required	Protect operational data, threat intel, and logs; ensure secure sharing and third‑party risk controls

Practical NIS2 compliance checklist (APT-ready)

• Board accountability: Assign a responsible executive and brief the board on NIS2 duties and penalties.
• Asset and service mapping: Identify “essential” services and dependencies; maintain a living asset inventory.
• Vulnerability and patch cadence: Define SLAs by criticality; document exceptions; verify with scans.
• Identity and access: Enforce MFA for admins and remote access; implement least privilege and periodic access reviews.
• Network security: Segment critical systems; deploy EDR/IDS; block egress by default for high-risk tiers.
• Backups and recovery: Test restores quarterly; maintain offline copies; document RTO/RPO.
• Logging and evidence: Centralise logs; time‑sync; protect integrity; rehearse evidence collection for 24/72‑hour reporting.
• Incident playbooks: Create APT, ransomware, and supplier breach runbooks with comms templates and CSIRT contacts.
• Supplier due diligence: Security clauses, SBOMs, vulnerability disclosure processes, and breach notification obligations.
• Data minimisation: Anonymise personal data in tickets, threat intel, and AI prompts to avoid GDPR spillover.

Try our secure document upload for internal workflows and regulator-ready reporting. Teams use it to centralise PDFs, DOCs, and logs without risking accidental disclosure.

AI workflows, anonymization, and secure document uploads

In 2025, many SOCs summarise incidents with LLMs, draft customer notices, and translate regulator templates. That speed is useful—but it’s also a liability if raw logs include names, emails, IPs, or medical identifiers. A hospital DPO told me their biggest surprise audit finding wasn’t endpoint gaps; it was analysts pasting personal data into AI tools.

• Strip identifiers before analysis: Use an AI anonymizer to automatically remove names, emails, phone numbers, addresses, and IDs from tickets, chat transcripts, and timeline notes.
• Secure evidence handling: Centralise breach artifacts via secure document uploads, so only the minimum necessary data is exposed to tools and partners.
• Reversible anonymisation: Maintain a key vault so legal teams can de-anonymise when strictly necessary and authorised.
• Audit trail: Log who uploaded, viewed, and exported documents for audit defence.

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.

Regulatory timelines and how to avoid last‑minute scramble

NIS2 had to be transposed by Member States in October 2024, with enforcement and sectoral rules rolling out through 2024–2025. Today, most competent authorities expect:

• Registration of in-scope entities and nominated contacts.
• Evidence of risk management policies, supplier assessments, and incident playbooks.
• Proven ability to submit 24/72-hour notifications with substantiated facts (indicators, impact, mitigation).

In my conversations with national CSIRTs, the single biggest bottleneck is evidence quality: incomplete logs, personal data mixed into technical notes, and inconsistent time-stamps that complicate forensics. Addressing this now pays dividends during an audit—or when an APT forces real-time reporting.

What EU regulators are signaling—and how it differs from the US

Brussels is leaning into outcome-based controls: not prescriptive checklists, but demonstrable resilience and timely reporting. The US often relies on sectoral rules (HIPAA, GLBA) and disclosure obligations (e.g., material cyber incidents). The EU’s approach adds executive liability and supply chain scrutiny across a broader set of sectors. For multinationals, that means harmonising to the highest common denominator: NIS2 technical measures, GDPR minimisation, and provable incident readiness.

Real-world scenarios

• Bank and fintech: If a supplier’s API is hijacked, you’ll need to alert the CSIRT within 24 hours and your DPA if personal data is affected. Be prepared with anonymised customer references and exact time windows.
• Hospital: Ransomware that disrupts medical devices is a NIS2 incident even without exfiltration; if patient data is exposed, GDPR applies too. Keep medical record identifiers out of any AI summarisation.
• Law firm: Managed email compromise of a partner account can cascade across clients. Ensure pre-signed incident notification templates and anonymised client identifiers.

To reduce both breach and compliance risk, professionals avoid risk by using Cyrolo’s anonymizer at www.cyrolo.eu. Try our secure document upload at www.cyrolo.eu — no sensitive data leaks.

FAQ: your top NIS2 compliance questions

What is NIS2 compliance and who is in scope?

NIS2 applies to “essential” and “important” entities across sectors like energy, transport, health, banking, digital infrastructure, and key ICT services. Compliance means implementing risk management measures, incident reporting within 24/72 hours, supply chain controls, and governance oversight.

How does NIS2 differ from GDPR in practice?

GDPR protects personal data and individuals’ rights; NIS2 ensures service resilience and security across critical operations. Many incidents trigger both regimes: NIS2 for operational impact and GDPR if personal data is compromised.

What are the penalties under NIS2?

Member States can impose administrative fines up to €10 million or 2% of global turnover, plus supervisory actions such as audits and mandatory remediation. Executive accountability is explicit.

Do AI tools and LLMs create compliance risk?

Yes—if you paste logs or tickets containing personal data into AI tools, you risk GDPR violations and uncontrolled disclosure. Use an AI anonymizer and secure document uploads to minimise exposure.

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.

What should we prepare before an audit or incident?

Have asset inventories, evidence-quality logging, tested backups, supplier risk files, and pre-approved incident templates. Ensure personal data is minimised or anonymised in all operational documentation.

Conclusion: make NIS2 compliance your 2025 advantage

Infy’s resurgence underscores that NIS2 compliance isn’t paperwork—it’s operating at a higher security tempo. If you can evidence risk management, notify within 24/72 hours, and share clean, anonymised evidence, you’ll navigate both regulators and attackers with confidence. Start by separating personal data from operational workflows and centralising evidence handling. Then pressure-test your playbooks. And when in doubt, route sensitive content through www.cyrolo.eu—for anonymisation and secure uploads that reinforce both GDPR and NIS2 controls.