Introduction
For many years, GDPR shaped how organisations across Europe thought about data protection and cybersecurity. Security leaders became familiar with concepts such as risk-based controls, breach notification timelines, and accountability for protecting personal data. However, the arrival of the NIS2 Directive marks a significant evolution in the European regulatory landscape. NIS2 does not replace GDPR, but it changes the conversation for security leaders in important ways.
Where GDPR focuses primarily on protecting personal data and individual rights, NIS2 expands the lens to include operational resilience, systemic risk, and national economic stability. It reflects a recognition by European regulators that cyber incidents are no longer just privacy events. They can disrupt essential services, supply chains, financial markets, and public trust.
For security leaders, this shift brings new expectations. Cyber Security Compliance is no longer only about protecting data. It is about ensuring the organisation can withstand, respond to, and recover from cyber threats. This article explains what has changed with NIS2, how it differs from GDPR, and what these changes mean in practice for security leadership, governance, and execution.
Why NIS2 Exists Alongside GDPR
GDPR was designed to protect individuals and their personal data. Over time, regulators observed that even organisations compliant with GDPR could still suffer major cyber incidents that disrupted operations or impacted wider ecosystems. Ransomware attacks on hospitals, utilities, logistics providers, and digital service platforms demonstrated that cyber risk extends beyond privacy.
NIS2 was introduced to address this gap. Its objective is to raise the baseline level of cybersecurity and resilience across critical and important sectors in the EU. Unlike GDPR, which applies broadly to any organisation processing personal data, NIS2 targets entities whose disruption could have cascading societal or economic impact.
For security leaders, this means cybersecurity is now framed as a strategic operational risk, not just a compliance or privacy function.
Scope: From Data Controllers to Essential and Important Entities
One of the most visible changes for security leaders is scope expansion.
GDPR cybersecurity applies to organisations processing personal data, regardless of industry, if EU residents are affected. NIS2, on the other hand, applies based on sector and criticality, not just data processing.
NIS2 introduces two categories:
- Essential entities (e.g., energy, transport, health, financial market infrastructure)
- Important entities (e.g., digital providers, managed service providers, certain manufacturing and service sectors)
Many organisations that were previously outside the scope of NIS are now included under NIS2. This has brought cybersecurity obligations to organisations that historically treated security as an IT concern rather than a board-level issue.
For security leaders, this means engaging with business leadership earlier and more directly.
From Privacy Risk to Operational and Systemic Risk
GDPR risk assessments focus on the rights and freedoms of individuals. Under GDPR, security leaders often frame risk in terms of potential data exposure, identity theft, or misuse of personal information.
NIS2 broadens the risk lens significantly. It requires organisations to consider:
- Service availability
- Business continuity
- Supply chain dependency
- Cross-border and sector-wide impact
This shift changes how security leaders must think about threat scenarios. A cyber incident is no longer assessed only by the data lost, but by how operations are disrupted and how quickly services can be restored.
Governance Expectations: Leadership Accountability Intensifies
GDPR introduced accountability, but in practice many organisations delegated cybersecurity responsibility to IT or compliance teams. NIS2 changes this dynamic by explicitly emphasising management body responsibility.
Under NIS2:
- Senior management is responsible for approving cybersecurity risk measures
- Management can be held accountable for non-compliance
- Oversight and governance are expected, not implied
For security leaders, this means cybersecurity discussions must move into boardrooms and executive committees. Technical reports alone are insufficient. Leaders must translate cyber risk into business and operational language.
Incident Reporting: Broader, Faster, More Structured
Security leaders are already familiar with GDPR’s 72-hour breach notification rule. NIS2 introduces additional incident reporting obligations, often with tighter timelines and broader scope.
Under NIS2, organisations must:
- Report significant incidents early (initial notification)
- Provide follow-up reports as facts evolve
- Consider service disruption and operational impact, not only data breaches
This means incident response plans must be expanded. Security leaders need processes that support rapid triage, decision-making, and communication, even when information is incomplete.
Risk Management Measures: More Explicit Than GDPR
GDPR requires “appropriate technical and organisational measures” but leaves interpretation largely to the organisation. NIS2 is more explicit about the types of measures expected, including:
- Incident handling
- Business continuity and disaster recovery
- Supply chain security
- Vulnerability handling and disclosure
- Security testing and audits
While still risk-based, NIS2 narrows the room for ambiguity. Cloud computing and cybersecurity leaders must ensure these areas are not only planned but operationally implemented and reviewed.
Supply Chain and Third-Party Risk: Elevated Importance
GDPR already places responsibility on controllers for their processors. NIS2 elevates supply chain risk further by recognising that vendor weaknesses can create systemic failures.
Security leaders must now consider:
- MSPs and IT service providers as part of the risk perimeter
- Dependency concentration on single vendors
- Contractual and operational assurance, not just paperwork
This pushes security teams to work more closely with procurement, legal, and operations to maintain ongoing third-party oversight.
Supervision and Enforcement: From Complaint-Driven to Proactive
GDPR enforcement is often triggered by complaints, breaches, or investigations. NIS2 introduces a more proactive supervisory model, particularly for essential entities.
Authorities may:
- Conduct inspections
- Request evidence of controls
- Require remediation plans
- Impose penalties for governance failures
For security leaders, this means readiness cannot be reactive. Evidence of continuous control execution becomes critical.
Penalties: Financial and Reputational Impact Increases
While GDPR penalties are widely known, NIS2 introduces penalties aligned with organisational size and criticality. More importantly, NIS2 penalties are tied to failure to manage cyber risk, not only breach outcomes.
This reinforces the idea that:
- Poor governance can be penalised even without a major incident
- Repeated weaknesses signal management failure
- Reputation damage extends beyond privacy issues
What Stayed the Same: Risk-Based, Technology-Neutral Approach
Despite these changes, some principles remain consistent:
- Both GDPR and NIS2 are risk-based
- Neither mandates specific tools or vendors
- Proportionality still applies
This consistency allows security leaders to build on existing GDPR programmes, rather than starting from scratch.
What Changed for Security Leaders in Practice
For security leaders, the shift from GDPR to GDPR plus NIS2 means:
- Broader accountability
- Expanded scope of risk
- Greater interaction with senior leadership
- Increased emphasis on resilience and continuity
- Stronger focus on execution over documentation
The role becomes less about technical control ownership and more about orchestrating governance, execution, and assurance across the organisation.
Operationalising GDPR and NIS2 Together
The most effective approach is not to treat GDPR and NIS2 as separate compliance tracks. Instead, organisations should adopt a single cybersecurity governance model that satisfies both.
This includes:
- Unified risk assessments
- Integrated incident response
- Common evidence repositories
- Regular management reporting
Security leaders who align these frameworks reduce duplication and improve clarity.
How Infodot Supports GDPR and NIS2 Alignment
Infodot helps organisations move from regulatory interpretation to operational execution. Rather than offering one-time advisory support, Infodot embeds cybersecurity controls into daily IT operations through a managed execution model.
Infodot supports security leaders by:
- Translating GDPR and NIS2 requirements into practical controls
- Operating continuous patching, access governance, and monitoring
- Maintaining inspection-ready evidence
- Supporting incident response and reporting workflows
- Managing third-party and cloud security execution
- Reducing dependency on internal headcount
- Enabling board-level visibility and assurance
Conclusion
GDPR changed how organisations think about personal data protection. NIS2 changes how they must think about cybersecurity as a business and societal risk. For security leaders, this represents a shift from compliance stewardship to resilience leadership.
Those who adapt will find that GDPR and NIS2 together create a stronger, more defensible cybersecurity posture. Those who continue to treat security as a technical or privacy-only function will face increasing regulatory, operational, and reputational pressure.
The question for security leaders is no longer “Are we GDPR compliant?” It is now “Are we resilient enough for NIS2 expectations?”
GDPR vs NIS2: Cybersecurity Comparison for Security Leaders
| Dimension | GDPR (General Data Protection Regulation) | NIS2 Directive |
| Primary Objective | Protect personal data and individual rights | Protect essential services, operations, and systemic resilience |
| Core Focus | Privacy and data protection | Cybersecurity, operational resilience, and service continuity |
| Who It Applies To | Any organisation processing EU personal data | Essential and important entities in defined sectors |
| Trigger for Applicability | Processing of personal data | Sector criticality and organisational role |
| Risk Perspective | Risk to rights and freedoms of individuals | Risk to operations, services, economy, and society |
| Accountability Model | Accountability principle, often delegated | Explicit senior management and board accountability |
| Management Responsibility | Implied governance responsibility | Direct responsibility of management bodies |
| Cybersecurity Scope | Security of personal data | Security of networks, systems, and services |
| Incident Definition | Personal data breach | Cyber incident impacting availability, integrity, or confidentiality |
| Incident Reporting Timeline | 72 hours after becoming aware | Early warning, incident notification, and follow-up reporting |
| Incident Impact Assessment | Impact on individuals | Impact on operations, services, and supply chains |
| Operational Resilience Requirement | Implicit | Explicit (BCP, DR, service continuity required) |
| Patch and Vulnerability Management | Expected but broadly defined | Explicitly expected as part of risk management measures |
| Supply Chain and Vendor Risk | Controller responsible for processors | Strong emphasis on supply chain and MSP risk |
| Third-Party Accountability | Contractual and oversight responsibility | Ongoing operational oversight expected |
| Security Measures | “Appropriate technical and organisational measures” | Defined categories of required risk management measures |
| Technology Prescription | Technology-neutral | Technology-neutral but more explicit expectations |
| Supervisory Approach | Often complaint or incident driven | Proactive supervision and inspections |
| Audit and Evidence Expectations | Accountability documentation | Continuous evidence of execution and governance |
| Penalties | Fines based on turnover and severity | Penalties tied to criticality, governance failure, and resilience gaps |
| Board and Executive Involvement | Recommended | Mandatory and enforceable |
| Cyber Governance Maturity | Often compliance-centric | Governance- and execution-centric |
| Focus on Availability | Secondary | Primary (service disruption is a key risk) |
| Ransomware Perspective | Data breach if data affected | Incident even if availability is disrupted |
| Cross-Border Considerations | Data transfer focus | Sector-wide and cross-border resilience focus |
| Regulatory Narrative | Privacy protection | National and EU-wide cyber resilience |
| Expectation of Continuous Compliance | Yes, but often interpreted loosely | Explicit expectation of continuous governance |
| Role of MSPs | Execution support | Recognised as part of risk perimeter |
| Inspection Readiness | Policy and documentation heavy | Evidence- and execution-heavy |
| Key Question Regulators Ask | “Was personal data protected?” | “Can the organisation withstand and recover from cyber threats?” |
Frequently Asked Questions (FAQs): GDPR vs NIS2 for Security Leaders
Is NIS2 replacing GDPR?
No. NIS2 complements GDPR by focusing on cybersecurity resilience and operational continuity, while GDPR continues to govern personal data protection.
Do organisations need to comply with both GDPR and NIS2?
Yes, if they process personal data and fall within NIS2 sector scope, both regulations apply simultaneously.
What is the biggest change NIS2 introduces?
NIS2 shifts focus from privacy-only compliance to operational resilience, service continuity, and systemic cyber risk management.
Who is accountable under NIS2?
Senior management and boards are explicitly accountable for cybersecurity risk management and compliance under NIS2.
Does NIS2 mandate specific security tools?
No. Like GDPR, NIS2 is technology-neutral and requires risk-based, proportionate security measures.
How does incident reporting differ between GDPR and NIS2?
GDPR focuses on data breaches, while NIS2 requires broader reporting of incidents affecting operations and service availability.
Are reporting timelines stricter under NIS2?
Yes. NIS2 introduces early warning and phased reporting obligations beyond GDPR’s 72-hour breach notification.
Does NIS2 apply to small organisations?
Yes, if they operate in defined essential or important sectors, regardless of organisation size.
What role do MSPs play under NIS2?
MSPs are considered part of the risk perimeter and require active oversight, not just contractual controls.
Is ransomware always a reportable incident under NIS2?
Yes, if it disrupts availability or operations, even without personal data exposure.
Does GDPR require business continuity planning?
Implicitly yes, but NIS2 makes operational resilience and continuity an explicit requirement.
What changes for CISOs under NIS2?
CISOs must engage more with boards, focus on resilience, and demonstrate continuous execution rather than periodic compliance.
Are access controls more important under NIS2?
Yes, as access failures can directly impact service availability and operational integrity.
Does NIS2 increase audit expectations?
Yes. Regulators expect ongoing evidence of execution, not just audit reports or policies.
How does supply chain risk differ under NIS2?
NIS2 places stronger emphasis on continuous vendor oversight and dependency risk management.
Can GDPR-compliant organisations assume NIS2 readiness?
No. GDPR compliance alone does not address operational resilience and systemic risk requirements under NIS2.
What penalties exist under NIS2?
Penalties are tied to organisational size, criticality, and governance failures, not only incident outcomes.
Does NIS2 require board training?
While not explicitly mandated, informed board oversight is strongly expected and often scrutinised.
Is vulnerability management explicitly required under NIS2?
Yes. Vulnerability handling and timely remediation are core NIS2 risk management measures.
How should organisations approach GDPR and NIS2 together?
By adopting a unified cybersecurity governance model that satisfies privacy protection and operational resilience requirements.
Does NIS2 require regular security testing?
Yes. Testing and audits are expected to validate control effectiveness and resilience readiness.
Are cloud services covered under NIS2?
Yes. Cloud platforms are within scope if they support essential or important services.
What evidence do regulators expect under NIS2?
Continuous records of execution, monitoring, incident handling, and management oversight.
Does NIS2 change breach notification to individuals?
No. Individual notification remains governed by GDPR when personal data rights are affected.
How does NIS2 affect incident response planning?
Incident response must be operational, tested, and capable of supporting rapid regulatory communication.
Is availability more important than confidentiality under NIS2?
Availability and resilience receive significantly higher emphasis under NIS2 compared to GDPR.
Can cyber insurance replace NIS2 controls?
No. Insurance does not remove the obligation to implement appropriate cybersecurity measures.
Does NIS2 apply outside the EU?
Yes, if organisations provide covered services within the EU or support EU critical infrastructure.
What happens if management ignores NIS2 obligations?
Regulators may impose penalties and hold management accountable for governance failures.
Is continuous compliance mandatory under NIS2?
Yes. NIS2 explicitly expects ongoing governance and execution, not point-in-time compliance.
How does NIS2 impact compliance budgets?
Budgets must support continuous execution and resilience, not just audits and documentation.
What is the role of metrics under NIS2?
Metrics demonstrate control effectiveness, resilience trends, and informed management oversight.
Does NIS2 require formal risk assessments?
Yes. Risk assessments must inform cybersecurity measures and be updated periodically.
How should security leaders prepare for NIS2 inspections?
By ensuring controls operate continuously and evidence is readily available across systems and processes.
How can Infodot support GDPR and NIS2 compliance together?
Infodot embeds continuous cybersecurity execution, evidence generation, and governance oversight into daily IT operations.
