NIS2 compliance: what EU security leaders must do now to avoid fines in 2025

Live exploitation of perimeter devices across Europe is accelerating, and boards are asking whether they meet NIS2 compliance. In today’s Brussels briefing, one regulator told me that “known‑vuln incidents are no longer excusable” after fresh waves of VPN and NVR exploits. This week alone, security teams are tracking an actively abused FortiOS SSL VPN two‑factor bypass and a remotely exploitable flaw in certain network video recorders—exactly the kind of events that trigger NIS2 reporting, GDPR exposure, and security audits. Below is a concise plan to meet EU regulations, harden operations, and prevent privacy breaches—plus practical steps to share evidence safely using anonymization and secure document uploads.

Why NIS2 matters after the latest VPN and NVR exploits

Two headlines cut through European SOCs today: attackers are bypassing multi‑factor authentication on certain VPN gateways, and a critical remote code execution bug in an IoT video recorder platform is being exploited in the wild. A CISO I interviewed at a Nordic utility put it bluntly: “It’s the perfect storm—perimeter tech, weekend patch windows, and immediate exploit code.” Under NIS2, that “storm” has legal consequences:

• Essential and important entities must implement risk‑management measures covering patching, access control, logging, supply chain, and incident response.
• Material incidents trigger strict 24h early warning, 72h incident notification, and a final report within one month to national CSIRTs/competent authorities.
• Management accountability and fines apply if governance and controls are lacking.

For operators of essential services (energy, transport, health) and digital infrastructure (DNS, IXPs, cloud), the bar is higher and the scrutiny faster. EU regulators are increasingly aligning expectations: if a vulnerability is widely exploited and you’re unpatched, expect hard questions after the notification lands.

Who is in scope—and what changed in 2025

• Scope expanded: NIS2 covers more sectors (energy, transport, banking, health, water, digital infrastructure, ICT providers, public administration, space, postal/courier, waste, chemicals, food, manufacturing).
• Entity tiers: “Essential” versus “Important” entities, with proportional but enforceable obligations for both.
• National laws now live: Member States transposed NIS2 through 2024 into 2025. Enforcement is active, and audits are ramping up.
• Board duty: Senior management must approve, oversee, and can be held liable for risk‑management measures.

Incident reporting timelines you should operationalize

• Early warning within 24 hours: if the incident is significant, notify the national CSIRT/authority with limited but timely facts and suspected cross‑border impact.
• Incident notification within 72 hours: update scope, root cause hypotheses, and mitigation steps.
• Final report within 1 month: include detailed root cause, indicators of compromise, and lessons learned.

Remember the GDPR overlay: personal data breaches must be reported to the supervisory authority within 72 hours if there’s risk to individuals, and sometimes to the data subjects themselves. In the U.S., public companies face SEC disclosure within four business days for material incidents; critical infrastructure will soon report to CISA under 72‑hour rules. EU entities with global footprints should reconcile these clocks in playbooks.

NIS2 compliance requirements you can execute this quarter

I’ve reviewed multiple national guidance notes this year; the practical expectations are converging. Build the following into your next audit cycle:

• Asset and vulnerability management: real‑time inventory; risk‑based patching SLAs; emergency procedures for exploited vulnerabilities (like VPN appliances and edge IoT).
• Identity and access: phishing‑resistant MFA, least privilege, privileged access management, segmentation around OT/IoT, hardening of remote access and SSL VPNs.
• Secure configuration and monitoring: baseline configurations, SIEM/SOAR with retention that meets national requirements, EDR on servers and endpoints, log integrity.
• Backup and recovery: immutable backups, offline copies, regular restore tests, ransomware playbooks.
• Supplier risk: contractual security clauses, SBOMs where relevant, vendor incident notification lines, validated support channels (no ad‑hoc email attachments).
• Business continuity and crisis comms: incident bridges, regulator contact lists, pre‑approved press and customer notices.
• Training and exercises: board‑level briefings, purple‑team drills, cross‑border reporting rehearsals.
• Data protection alignment: integrate GDPR breach assessment with NIS2 severity scoring so you don’t run two conflicting processes at 2am.

Practical data handling: anonymization and secure evidence exchange

Regulators now expect you to share logs, tickets, and IoCs without leaking personal data or trade secrets. That’s where disciplined redaction and secure transfer matter.

• Before sending log bundles to a CSIRT or vendor, scrub names, emails, IP‑to‑person mappings, and contract identifiers where not strictly necessary.
• For legal, DSAR, and discovery use cases, anonymize case files and attachments to prevent secondary privacy breaches.

Professionals avoid risk by using anonymization that preserves investigative value while stripping personal data. Try our secure document upload—no sensitive data leaks, no guesswork about where your files end up.

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.

GDPR vs NIS2: what’s different, what overlaps

Area	GDPR	NIS2
Primary aim	Protect personal data and privacy rights	Ensure network and information systems security and resilience
Who is in scope	Controllers and processors of personal data	Essential and important entities across specified sectors
Incident reporting	72h to data protection authority for personal data breaches	24h early warning, 72h notification, final within 1 month for significant incidents
Fines (upper bound)	Up to €20M or 4% of global annual turnover	At least up to €10M or 2% (essential); €7M or 1.4% (important), per national law
Governance	DPO for certain organizations	Management accountability; security risk‑management measures mandated
Security measures	“Appropriate” technical and organizational measures; data minimization	Explicit controls: risk management, incident handling, supply‑chain, encryption, access control, monitoring
Reporting authority	National data protection authority (DPA)	National CSIRT/competent authority for NIS

NIS2 quick‑start compliance checklist

• Map essential/important entity status and register with your national authority if required.
• Adopt a risk‑based patching policy with emergency windows for exploited edge devices (VPN, gateways, NVRs).
• Harden remote access: enforce phishing‑resistant MFA, restrict admin interfaces, validate device firmware provenance.
• Implement SIEM with alerting for anomalous VPN logins and device reboots/config changes.
• Prepare incident reporting templates aligned to 24h/72h/1‑month milestones.
• Integrate GDPR breach assessment with NIS2 severity classification.
• Contractually require suppliers to notify you within 24 hours of material incidents.
• Standardize evidence packages with anonymization and secure document uploads.
• Schedule a board briefing on NIS2 duties and personal accountability.
• Run a cross‑functional incident simulation that includes regulator notifications.

Governance, audits, and penalties: how authorities are enforcing

Across the bloc, competent authorities are signaling a pragmatic but firm approach: show your program is real, not just paper. Expect requests for:

• Documented risk assessments and board approvals for security strategy.
• Evidence of vulnerability management cadence, especially for exploited CVEs.
• Logging and monitoring architecture diagrams and retention policies.
• Supplier risk procedures and escalation paths.
• Post‑incident remediation plans and lessons learned.

Penalty frameworks are now embedded in national law. For essential entities, expect maximum fines at least €10M or 2% of global turnover; for important entities, at least €7M or 1.4%. Repeated failure to report or to remediate can escalate sanctions, including binding instructions or temporary suspension of certain activities. A senior auditor I spoke with in Paris noted: “If your VPN remained unpatched weeks after a public exploit, we’ll look at governance, not just the SOC.”

Three scenarios from the field—and how teams responded

• Bank/fintech: After anomalous VPN access, the SOC contained sessions, rotated credentials, and pushed an emergency firmware update. Within 24 hours they issued an early warning, then used anonymization to remove PII from authentication logs before sharing with the national CSIRT and a third‑party IR firm.
• Hospital: A vulnerable network video recorder exposed to the internet was compromised. OT/clinical systems were segmented; backups restored imaging archives. The team filed a 72‑hour NIS2 notification and a GDPR breach report for affected patient data. Medical records shared with external responders were sanitized via secure document upload.
• Law firm: A supplier credential was phished for remote access. The firm activated the incident bridge, notified clients under contractual SLAs, and prepared the one‑month final report with redacted case files to avoid privacy breaches.

FAQ: real questions teams ask about NIS2

What is NIS2 compliance and who must meet it?

NIS2 compliance means implementing mandated security risk‑management measures and incident reporting across EU‑designated sectors. Both essential and important entities—public and private—must comply once in scope under national transposition laws.

How fast must we report incidents under NIS2?

Submit an early warning within 24 hours, a fuller notification within 72 hours, and a final report within one month. If personal data is involved, assess GDPR reporting in parallel.

Does NIS2 apply to SMEs?

Yes, if they are in specified sectors or meet criteria (e.g., criticality) under national rules. Size alone is not a blanket exemption in high‑impact sectors.

How do GDPR and NIS2 interact during a breach?

They run in parallel: GDPR protects personal data, while NIS2 ensures system resilience. You may need to notify both the data protection authority and the NIS authority with different content and timelines, coordinated by your incident commander.

What’s the safest way to share logs and documents with regulators and vendors?

Redact and anonymize first, then use a secure channel. To avoid accidental exposure, use www.cyrolo.eu for anonymization and secure document uploads. 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.

Conclusion: make NIS2 compliance your 2025 advantage

The past week’s exploits on VPNs and IoT recorders confirm what Brussels has been saying all year: operational resilience and disciplined reporting are now baseline expectations. Treat NIS2 compliance as a competitive edge—prove you can detect fast, notify accurately, and share evidence without leaking personal data. Professionals avoid risk by using anonymization and secure document upload at www.cyrolo.eu. Your next audit—and your next incident—will go better for it.