NIS2 compliance checklist: 2025–2026 guide for EU CISOs and DPOs

In today’s Brussels briefing ahead of Data Protection Day 2026, regulators signalled that the next 12 months are a “prove it” phase for NIS2. Against that backdrop—and after headlines about OAuth abuse in major SaaS ecosystems and the U.S. SEC stepping back from a high‑profile cybersecurity case—security leaders asked me for one thing: a practical NIS2 compliance checklist they can execute now. This report delivers that, tying NIS2 to GDPR, EU regulations, and real-world security audits while showing how to reduce breach risk with privacy-first AI workflows.

Why the NIS2 compliance checklist matters right now

• Regulatory timing: Member States have transposed NIS2 (Directive (EU) 2022/2555) and supervision is ramping through 2025–2026. Expect more inspections and formal security audits.
• Enforcement tone: In my conversations with EU authorities, the message is steady: demonstrate risk management, incident reporting discipline, and supply‑chain controls—or prepare for findings.
• Cross-Atlantic contrasts: The recent U.S. debate over cybersecurity liability (including the SEC’s SolarWinds case reversal) doesn’t change EU expectations. In the EU, regulators continue to press for evidence of governance and technical measures under NIS2 and GDPR.
• Live attack patterns: This week’s OAuth-token misuse reports in CRM stacks underline NIS2’s emphasis on identity, access, logging, and third‑party risk. If you can’t trace tokens, scopes, and app approvals, auditors will notice.

GDPR vs NIS2: what changes for your security team

GDPR and NIS2 overlap but are not interchangeable. GDPR protects personal data; NIS2 secures essential and important entities’ networks and information systems across sectors (energy, transport, health, digital infrastructure, managed services, and more). Most mature organizations must comply with both.

Area	GDPR	NIS2
Objective	Data protection, lawful processing, and individuals’ rights	Cyber resilience of network and information systems for essential/important entities
Scope	Controllers/processors of personal data	Sector- and size-based threshold for entities; includes key suppliers (e.g., MSPs)
Incident reporting	Personal data breach to authority within 72 hours; notify individuals if high risk	Early warning within 24 hours; incident notification within 72 hours; final report within 1 month
Fines	Up to €20M or 4% of global turnover (whichever is higher)	Member States must set maxima at least €10M or 2% (essential) and €7M or 1.4% (important)
Governance	DPO where required; DPIAs; data protection by design/default	Management accountability; risk management measures; supply‑chain security; secure development
Vendors	Processor contracts, SCCs, transfer impact assessments	Supply‑chain cyber risk management; procurement security clauses; continuous oversight

Your NIS2 compliance checklist: 12 controls auditors will test first

• Governance and accountability
  • Board-approved cyber risk policy with clear risk appetite and measurable KPIs.
  • Documented roles: CISO (or equivalent), incident manager, supplier owner; defined reporting to the executive team.
• Risk management program
  • Enterprise risk assessment covering operational technology (OT) and IT; update at least annually or after major changes.
  • Threat-led testing (e.g., red/purple team) aligned to sector risks.
• Incident reporting readiness
  • Runbooks for the 24-hour early warning, 72-hour incident notification, and 1‑month final report.
  • Pre-drafted regulator templates; mapped evidence sources (SIEM, EDR, SaaS logs).
• Identity, access, and OAuth control
  • MFA for admins and high-risk users; phishing-resistant where feasible.
  • OAuth inventory: approved apps, scopes, tokens; automated revocation on anomalies.
• Secure development and change
  • SBOMs, vulnerability management SLAs, code scanning, and secure pipeline gates.
  • Third-party component risk reviews before production use.
• Logging, monitoring, and detection
  • Centralized logs for cloud, SaaS, and on‑prem; retention aligned to regulatory and forensic needs.
  • 24/7 alerting on identity abuse, data exfiltration, and privileged actions.
• Business continuity and resilience
  • Backup immutability and offline copies; tested restores; RPO/RTO match business impact analysis.
• Supply‑chain security
  • Risk-based vendor tiering; security clauses in contracts; continuous monitoring of critical suppliers.
  • Verification of MSP/MSaaS security and their sub‑processors.
• Awareness and training
  • Role-based drills for incident coordinators, PR/legal, and executive briefings.
• Data protection by design
  • Data minimization and pseudonymization/anonymization for personal data; DPIAs for high‑risk processing.
• Shadow AI and secure document workflows
  • Policy for AI use; redaction before model inputs; segregated environments for sensitive files.
  • Use an enterprise-grade anonymizer to strip personal data before analysis or sharing.
• Metrics and board reporting
  • Monthly dashboards on incidents, patch SLAs, supplier findings, and training completion.

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.

Fast wins: data minimization and safe AI workflows

Two practical steps reduce both privacy breaches and cybersecurity exposure under EU regulations:

• Automate anonymization before sharing or analysis
  • Strip names, IDs, health and financial markers from case files, tickets, and logs before they leave your trust boundary.
  • Professionals avoid risk by using Cyrolo’s anonymizer at www.cyrolo.eu.
• Lock down document handling and uploads
  • Use a dedicated secure environment for document uploads and reviews to prevent mishandling in ad‑hoc SaaS or shadow AI tools.
  • Try secure document upload at www.cyrolo.eu — no sensitive data leaks.

Sector snapshots: what I’m hearing from the field

• Hospitals and clinics: Legacy devices and sprawling vendor lists complicate incident reporting. A CISO told me they now maintain a “72-hour evidence box” with pre‑tagged logs and contact trees.
• Banks and fintechs: With DORA now live, firms are harmonizing controls so one audit trail satisfies DORA, NIS2, and GDPR—particularly for third‑country service providers.
• Law firms: Client confidentiality and cross‑border transfers remain top concerns. Many are deploying on‑prem or EU-hosted tools for secure discovery and redaction before counsel review.
• Managed service providers: Under NIS2, MSPs are themselves “important” or “essential.” Expect auditors to ask how you secure your own access to customer tenants.

Executive briefing: three regulator expectations for 2026

1. Show your work: Policies must connect to controls, logs, and outcomes—not just slideware.
2. Prove incident muscle memory: Simulate the 24/72/30‑day reporting timeline and keep the evidence trail.
3. Tame your SaaS and AI sprawl: Inventory OAuth apps, revoke unused tokens, and gate uploads through a secure platform like www.cyrolo.eu.

FAQ: NIS2 compliance, GDPR, and secure document handling

Who is in scope for NIS2?

Essential and important entities across specified sectors (energy, transport, health, digital infrastructure, public administration, water, financial market infrastructure, managed service providers, and others), typically based on size and criticality. Many SaaS and MSP providers are explicitly in scope.

How does NIS2 interact with GDPR?

GDPR governs personal data processing and breach notification to data protection authorities. NIS2 focuses on cyber risk management and incident reporting to national CSIRTs/competent authorities. If an incident involves personal data, both regimes may apply—triggering parallel notifications.

What are the NIS2 incident reporting timelines?

Submit an early warning within 24 hours of becoming aware of a significant incident, an initial notification with assessment within 72 hours, and a final report within one month, including root cause and mitigation.

Do AI tools and LLMs create NIS2 or GDPR risk?

Yes. Uploading sensitive files to AI tools can trigger GDPR obligations and increase NIS2 exposure if controls, logging, and supplier oversight are weak. Enforce data minimization, anonymization, and approved platforms for 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.

What fines and personal liability are possible?

Under GDPR, fines can reach €20M or 4% of global annual turnover. Under NIS2, Member States must set maximum fines of at least €10M or 2% for essential entities and €7M or 1.4% for important entities. NIS2 also emphasizes management accountability, including possible temporary bans for failing to implement measures.

Conclusion: turn this NIS2 compliance checklist into measurable progress

Europe’s privacy and security posture is moving from policy to provable outcomes. Use this NIS2 compliance checklist to prioritize identity and OAuth controls, incident reporting muscle, and supply‑chain discipline—then harden data workflows with anonymization and secure uploads. To reduce breach risk and accelerate audits, run sensitive documents through an AI‑safe pipeline: anonymize first and channel uploads via www.cyrolo.eu. That’s how EU teams will meet NIS2, align with GDPR, and enter Data Protection Day 2026 with confidence.