NIS2 compliance in 2026: a practical playbook for EU security and privacy teams

In today’s Brussels briefing, regulators repeated a simple message: NIS2 compliance is no longer theoretical. With reports of China‑linked actors exploiting ESXi zero‑days to escape virtual machines and APT28 credential‑stealing campaigns targeting energy and policy organizations, the EU’s cybersecurity compliance regime is entering its enforcement phase. If you handle personal data, operate critical services, or rely on cloud and AI tools, your exposure now spans both EU regulations—NIS2 and GDPR—and the messy reality of supply‑chain risk, security audits, and privacy breaches.

I spent the week speaking with CISOs in banks, hospitals, and policy shops across the bloc. Their worries were identical: incident reporting clocks, vendor accountability, and risky document workflows involving LLMs. Below is the field guide they asked for—clear steps, comparisons, and tools to keep services running and regulators satisfied.

What NIS2 compliance really means in 2026

NIS2 expands the original NIS Directive and captures a broader set of “essential” and “important” entities—energy, transport, banking, healthcare, digital infrastructure, managed service providers, and more. Key features you must plan for now:

• Risk management measures: policies for governance, asset management, vulnerability handling, encryption, multi‑factor authentication, secure development, and incident response.
• Management accountability: executive liability for failing to implement cybersecurity measures; mandatory training; potential temporary bans for egregious non‑compliance.
• Incident reporting timelines: early warning within 24 hours of becoming aware, an incident notification within 72 hours, and a final report within one month.
• Supply‑chain and service provider oversight: documented due diligence, contractual security requirements, and visibility into third‑party incidents.
• Enforcement and fines: up to €10 million or 2% of worldwide turnover for essential entities (lower thresholds apply to important entities), plus corrective orders and public notices.

Bottom line: NIS2 is service‑centric. Even if you don’t process personal data at scale, you’ll still need robust controls and rapid reporting—especially where operational continuity is at stake.

How NIS2 compliance intersects with GDPR

GDPR remains the EU’s privacy backbone, focused on personal data protection, while NIS2 targets the resilience and security of network and information systems. In practice, a single incident (say, ransomware with data exfiltration) can trigger both regimes.

Topic	GDPR	NIS2
Primary objective	Data protection and privacy of natural persons (personal data)	Cybersecurity and resilience of essential and important services
Scope	Controllers and processors handling personal data	Entities in specified sectors and size thresholds; service‑centric
Incident reporting	Notify DPA within 72 hours when a personal data breach is likely to risk rights and freedoms	24‑hour early warning; 72‑hour notification; final report in one month for significant incidents
Fines	Up to €20M or 4% of global turnover	Up to €10M or 2% of global turnover (entity type dependent)
Management liability	Indirect via governance failures and accountability	Explicit duties for management bodies; potential temporary bans
Third‑party risk	Processor due diligence, SCCs, DPIAs	Contractual security controls, continuous oversight of supply chain and managed services

Pragmatically, treat them as a single operating model: one incident response plan with dual pathways—privacy and operational resilience—so you can meet both sets of regulators without duplicating effort.

Recent attacks: what they teach us about audits and board accountability

This morning’s disclosures about ESXi VM‑escape zero‑days and the new APT28 credential theft wave are more than headlines; they’re audit questions waiting to happen. A national regulator told me bluntly, “We will ask for your vulnerability exposure timeline, your identity hardening records, and who had access to what documents during triage.” Expect these focal points:

• Virtualization and hypervisor hygiene: asset inventory of hypervisor versions, patch lag metrics, and isolation controls. VM‑escape class flaws are now Board‑level risks.
• Identity resilience: phishing‑resistant MFA, conditional access, service account vaulting, and continuous monitoring for anomalous sign‑ins—especially for energy and policy organizations in the crosshairs.
• Supplier paths: managed service providers and remote admin channels remain the soft underbelly. Keep contract clauses and evidence of their security measures ready.
• Evidence retention: logs, ticket histories, and secure case files demonstrating “who knew what and when.” Weak documentation is a fast path to corrective orders.

As one CISO at a European utility told me, “The technology was the easy part; proving we did the right thing, fast, with clean documentation—that’s where we almost stumbled.”

Document handling: your hidden NIS2 and GDPR risk

Most enforcement pain I see is not zero‑day exploitation—it’s messy document workflows. Teams paste sensitive material into chatbots, email incident reports to vendors, and upload customer files to unvetted SaaS. That’s a privacy breach under GDPR and a supply‑chain weakness under NIS2.

Professionals avoid risk by using Cyrolo’s anonymizer to redact names, IDs, and locations before sharing. And when collaboration is necessary, try our secure document upload at www.cyrolo.eu—no sensitive data leaks, with a workflow you can defend to auditors.

Mandatory 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.

A practical workflow you can show to regulators

1. Anonymize first: remove personal data and client identifiers from incident notes, legal memos, and vendor tickets using an AI anonymizer that logs what was redacted.
2. Upload securely: centralize files with access controls and audit trails. Use a secure document upload process your DPO and CISO can approve.
3. Share least‑privilege links: time‑bound, role‑based access; revoke on incident closure.
4. Preserve evidence: store hash‑sealed versions of key reports and timelines for NIS2/GDPR reporting.

NIS2 compliance checklist for your next audit

• Governance
  • Board‑approved cybersecurity policy mapped to NIS2 risk areas.
  • Executive and technical training records within the last 12 months.
• Asset and vulnerability management
  • Live inventory covering endpoints, servers, hypervisors, and SaaS.
  • Patch SLAs by criticality; evidence of timely remediation for internet‑facing and hypervisor CVEs.
• Identity and access
  • Phishing‑resistant MFA for admins; privileged access management; service account rotation.
  • Conditional access for vendors; logs of who accessed what during incidents.
• Secure development and operations
  • SBOMs for critical applications; code signing and build pipeline protections.
  • Backups tested for rapid restore; immutable storage for critical data.
• Incident response and reporting
  • Runbook covering 24h/72h/1‑month NIS2 milestones plus GDPR breach triggers.
  • Playbooks for ransomware, hypervisor exploits, and identity compromise.
• Third‑party risk
  • Security clauses in contracts (MFA, logging, incident notice, evidence sharing).
  • Annual assurance artifacts (SOC 2/ISO 27001 equivalents, pentest summaries).
• Data protection
  • DPIAs for new processing; records of processing activities up to date.
  • Approved process for anonymization and secure document uploads when using AI or external experts.

Budget and staffing: what regulators told me this week

Two supervisors I spoke with were sympathetic about hiring gaps but clear about expectations. They look for proportionality—controls that match your risk profile—not perfection. Show them:

• Awarded budgets tied to specific NIS2 controls with delivery dates.
• Interim risk reductions (e.g., MFA rollout to all admins within 30 days; temporary network segmentation around hypervisors).
• Evidence of disciplined document hygiene: anonymization in place, centralized secure storage, and audited sharing.

Compared with the US, where the SEC’s disclosure rule focuses on timely investor information (four business days after determining materiality), EU regulators will scrutinize both your incident speed and your systemic controls. In short: narrative plus proof.

FAQ: real‑world questions teams are asking

What is NIS2 compliance and who does it apply to?

NIS2 compliance means implementing governance, technical, and operational measures to secure the network and information systems that underpin essential and important services in the EU. It applies to entities across sectors like energy, healthcare, banking, transport, digital infrastructure, managed services, and more—generally above certain size thresholds, with some sector‑specific nuances.

What are the NIS2 incident reporting timelines?

Submit an early warning within 24 hours of becoming aware of a significant incident, a more detailed notification within 72 hours, and a final report within one month. Align your internal SLAs so legal, security, and communications are synchronized.

How does NIS2 interact with GDPR after a breach?

If personal data is at risk, GDPR’s 72‑hour clock to the data protection authority is in play alongside NIS2’s timelines. Build one incident process that triggers both pathways, with clear criteria for when to inform data subjects and sector regulators.

Can we use AI tools during incident response?

Yes—but only with strict guardrails. Anonymize case notes and logs first, then use a secure platform for sharing. Professionals avoid risk by using Cyrolo’s anonymizer and secure document upload to prevent leaks and preserve evidence integrity. Remember: 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 are the fines under NIS2 vs GDPR?

NIS2: up to €10 million or 2% of global turnover (entity category dependent), plus corrective measures and potential management consequences. GDPR: up to €20 million or 4% of global turnover. Regulators increasingly expect demonstrable controls and documented decisions to mitigate penalties.

Conclusion: make NIS2 compliance measurable in the next 90 days

NIS2 compliance in 2026 is about verifiable discipline—tight identity controls, rapid patching of exposed systems (including hypervisors), credible supply‑chain oversight, and clean documentation you can hand to an auditor. Start with the workflows that leak the most: documents and data sharing. Redact with an AI anonymizer and centralize collaboration via secure document uploads at www.cyrolo.eu to cut breach risk and prove control. When the next ESXi‑class exploit or credential campaign hits—and it will—you’ll have both resilience and receipts.