Executive Summary
As cybersecurity threats continue to evolve, regulatory frameworks are becoming more stringent worldwide. The NIS2 Directive represents the European Union’s latest effort to enhance cybersecurity resilience, but how does it compare to other major regulations such as GDPR, DORA, NIST CSF, and ISO 27001? Understanding these regulations’ overlaps, differences, and compliance challenges is essential for businesses operating in multiple jurisdictions.
This white paper provides a detailed comparative analysis of NIS2 against other key cybersecurity regulations. It also outlines best practices for harmonising multiple frameworks and the critical steps non-EU businesses must take when engaging with the European market.
1. Introduction
1.1 The Increasing Regulatory Landscape in Cybersecurity
Cybersecurity regulations have become central to risk management and operational resilience. Governments worldwide are implementing stricter policies to combat cyber threats, making compliance a priority for businesses.
1.2 Why NIS2 Matters
The NIS2 Directive expands the scope of the original NIS Directive (2016), strengthening cybersecurity requirements for essential and important entities across EU member states. Unlike GDPR, which focuses on data protection, NIS2 enforces resilience, incident reporting, and governance for businesses operating in critical sectors.
2. Comparative Analysis: NIS2 vs. Other Cybersecurity Regulations
| Regulation | Scope & Focus | Key Requirements | Penalties for Non-Compliance |
|---|---|---|---|
| NIS2 (EU) | Cyber resilience for essential & important entities | Risk management, incident reporting, supply chain security | Fines up to €10M or 2% of global turnover |
| GDPR (EU) | Data privacy & protection | Consent management, data encryption, DPO appointment | Fines up to €20M or 4% of global turnover |
| DORA (EU) | Financial sector resilience | ICT risk management, third-party oversight, operational resilience testing | Fines vary by member state |
| ISO 27001 (Global) | Cybersecurity management framework | Information security governance, risk assessment, continual improvement | No fines, but required for certifications |
| NIST CSF (US) | Voluntary cybersecurity framework | Identify, Protect, Detect, Respond, Recover model | No fines, but widely adopted in regulated sectors |
3. Legal and Compliance Overlaps & Differences
3.1 NIS2 vs. GDPR
Key Differences:
- NIS2 focuses on cyber resilience, while GDPR is dedicated to personal data protection.
- GDPR applies to all organisations processing EU citizens’ data, whereas NIS2 applies only to critical and important entities.
- Incident reporting deadlines differ: NIS2 mandates reporting within 24 to 72 hours, while GDPR requires notification of breaches within 72 hours.
3.2 NIS2 vs. DORA
Key Differences:
- DORA is sector-specific (applies to financial institutions), while NIS2 applies to multiple industries.
- DORA mandates operational resilience testing, which is not explicitly required under NIS2.
3.3 NIS2 vs. ISO 27001
Key Differences:
- ISO 27001 is voluntary but provides a framework for cybersecurity governance, whereas NIS2 is legally binding.
- Organisations certified under ISO 27001 can leverage existing controls to meet NIS2 requirements.
3.4 NIS2 vs. NIST CSF
Key Differences:
- NIST CSF is voluntary, while NIS2 has legal consequences.
- NIST CSF’s "Identify, Protect, Detect, Respond, Recover" model can help businesses structure their NIS2 compliance strategy.
4. Best Practices for Harmonising Multiple Cybersecurity Frameworks
4.1 Adopt a Risk-Based Approach
- Map common compliance requirements across regulations.
- Prioritise cybersecurity investments based on risk exposure.
4.2 Implement Unified Cybersecurity Policies
- Develop integrated governance frameworks covering NIS2, GDPR, DORA, and ISO 27001.
- Ensure consistent security controls to meet multiple regulatory standards.
4.3 Leverage International Security Standards
- Use ISO 27001 and NIST CSF to streamline NIS2 compliance.
- Adopt CIS Controls for improved security posture.
4.4 Automate Compliance Monitoring
- Deploy Security Information and Event Management (SIEM) systems.
- Use automated risk assessment and compliance reporting tools.
5. What Non-EU Businesses Need to Know About NIS2
5.1 Does NIS2 Apply to Non-EU Companies?
Yes, if a non-EU company operates within the EU or provides services to EU-based customers, it may be subject to NIS2 requirements. This includes cloud service providers, digital infrastructure providers, and multinational organisations.
5.2 Key Compliance Steps for Non-EU Businesses
✔️ Assess exposure to NIS2 obligations (identify operations within the EU). ✔️ Develop cybersecurity governance policies aligned with NIS2. ✔️ Establish incident response plans that meet EU reporting requirements. ✔️ Ensure third-party vendors also comply with NIS2 regulations. ✔️ Monitor evolving national implementations of NIS2 across EU member states.
6. Conclusion: The Path Forward for Businesses
As regulatory landscapes evolve, businesses must be strategic in compliance efforts. The NIS2 Directive, GDPR, DORA, ISO 27001, and NIST CSF all play a role in shaping cybersecurity resilience.
By aligning cybersecurity frameworks, harmonising policies, and automating compliance, organisations can achieve robust security postures while reducing regulatory complexity.