NIS2 vs DORA: Your Complete EU Cybersecurity Compliance Guide

Last Updated on February 16, 2026 by Narendra Sahoo

By January 2025, over 160,000 EU organizations became subject to new cybersecurity regulations—NIS2, DORA, or both. If you operate in the EU or serve EU clients, you’re likely affected.

This guide clarifies which regulations apply to you and what you must do to comply.

Quick Facts
NIS2:	Broad cybersecurity directive covering 18 critical sectors
DORA:	Financial sector operational resilience regulation
Timeline:	DORA active since January 17, 2025 | NIS2 by October 2026
Penalties:	Up to €10M or 2% of global revenue
Overlap:	Financial entities often need both

At-a-Glance Comparison

Aspect	NIS2	DORA
Applies To	18 sectors, 160,000+ entities	Financial sector, 22,000+ entities
Main Goal	Prevent cyber incidents	Ensure business continuity
Focus	Cybersecurity	Operational resilience
Testing	Risk-based assessments	Mandatory TLPT every 3 years
Penalties	Up to €10M or 2% revenue	Fines + operational restrictions
Active Since	October 2024 (varies by country)	January 17, 2025

Is Your Organization Affected?

Question 1: Where Do You Operate?

✓ In the EU
✓ Serve EU customers
✓ Part of EU supply chains

Question 2: What Sector Are You In?

• Financial services → DORA applies
• Critical infrastructure (energy, healthcare, transport) → NIS2 applies
• ICT services (cloud, hosting, software) → Likely both
• Manufacturing, logistics, postal → NIS2 applies

Question 3: What’s Your Company Size?

• 50+ employees OR €10M+ revenue → In scope
• Small but critical services → May be in scope
• Enterprise financial/infrastructure → Definitely both

Result: If you answered yes to Q1 and any part of Q2-Q3, keep reading.

What is NIS2?

NIS2 (Network and Information Systems Directive 2) is the EU’s updated cybersecurity law covering critical sectors. Member states transposed it by October 2024, with organizations required to comply by October 2026.

Who Must Comply: 160,000+ Entities

Essential Entities (Higher Tier):
• Energy, transport, banking, healthcare
• Water, digital infrastructure, space
• Public administration, critical manufacturing

Important Entities (Standard Tier):

• Postal services, waste management
• Food production, manufacturing
• Digital service providers

Size Threshold: 50+ employees OR €10M+ annual revenue

Key NIS2 Requirements

Governance:
• Board-level cybersecurity oversight
• Designated responsible person
• Regular management reporting

Risk Management:

• Risk-based cybersecurity measures
• Security controls proportional to risk
• Business continuity plans

Supply Chain Security:

• Vendor security assessments
• Contracts with security requirements
• Third-party risk monitoring

Incident Response:

• 24-hour early warning
• Significant incidents to CSIRT
• Final report within one month

Reporting:

• Notify national authorities
• Public disclosure if needed
• Cooperation with regulators

What is DORA?

DORA (Digital Operational Resilience Act) is EU regulation focusing on financial sector operational resilience. Active since January 17, 2025, it harmonizes cybersecurity and ICT risk management across all EU financial entities.

Who Must Comply: 22,000+ Financial Entities

• Banks and credit institutions
• Investment firms and trading platforms
• Insurance and reinsurance companies
• Payment institutions and e-money providers
• Crypto-asset service providers
• Critical ICT third-party providers

DORA’s Five Pillars

Pillar 1: ICT Risk Management

• Comprehensive ICT risk framework
• Governance, policies, procedures
• Continuous monitoring and improvement

Pillar 2: Incident Management

• Classification and reporting systems
• Major incidents to regulators within 4 hours
• Root cause analysis and lessons learned

Pillar 3: Testing

• Annual security testing
• Threat-led penetration testing (TLPT) every 3 years for large entities
• Scenario-based testing

Pillar 4: Third-Party Risk

• Due diligence on ICT providers
• Contractual requirements
• Exit strategies and continuity plans

Pillar 5: Information Sharing

• Share threat intelligence
• Participate in industry forums
• Cyber threat information exchange

Key Differences: NIS2 vs DORA

Aspect	NIS2	DORA
Scope	18 sectors, 160,000+ entities	Financial sector only
Legal Nature	Directive (member states implement)	Regulation (directly applicable)
Governance	Board oversight required	Extensive governance framework
Testing	Risk-based assessments	Mandatory TLPT every 3 years
Third Parties	Vendor assessments	Stringent contracts + oversight
Reporting	National CSIRT	Financial supervisors

Overlap: When You Need Both

Approximately 40% of DORA entities also fall under NIS2:

• Large banks (essential entities under NIS2)
• Payment processors
• Financial market infrastructures
• Insurance giants
• Critical ICT providers serving both sectors

Which Takes Priority?

DORA is “lex specialis” (specific law) for financial entities:

• DORA supersedes NIS2 on ICT risk management, testing, third-party risk, incident reporting
• NIS2 still applies for broader cybersecurity coordination and CSIRT reporting

Practical result: Build ICT program to DORA standards, add NIS2 CSIRT reporting.

5-Phase Implementation Roadmap

Phase 1: Assessment (Weeks 1-4)

• Confirm your scope
• Appoint compliance owner
• Inventory critical systems
• Gap analysis vs requirements

Phase 2: Governance (Weeks 5-8)

• Establish board oversight
• Create incident response procedures
• Document current controls
• Review vendor contracts

Phase 3: Technical Controls (Weeks 9-16)

• Implement security measures
• Deploy monitoring tools
• Establish backup/recovery
• Configure logging and alerts

Phase 4: Testing & Validation (Weeks 17-20)

• Conduct risk assessments
• Run tabletop exercises
• Perform vendor reviews
• Test incident procedures

Phase 5: Continuous Compliance (Ongoing)

• Monitor security controls
• Review incidents
• Update risk register
• Quarterly board reporting
• Annual full risk assessment

Common Mistakes to Avoid

Mistake 1: Treating It as One-Time Project

❌ Wrong: “Let’s get compliant and we’re done”
✅ Right: Continuous compliance with ongoing monitoring

Mistake 2: Separate NIS2 and DORA Programs

❌ Wrong: Two teams, duplicate effort
✅ Right: Unified framework saves 50% cost

Mistake 3: Ignoring Supply Chain

❌ Wrong: “Vendors handle their own security”
✅ Right: You’re responsible for third-party risks

Mistake 4: Weak Governance

❌ Wrong: Delegating to IT only
✅ Right: Board-level ownership mandatory

Mistake 5: No Testing

❌ Wrong: Plan exists but never tested
✅ Right: Regular drills and simulations

Mistake 6: Missing Deadlines

❌ Wrong: “We’ll figure out reporting when incident happens”
✅ Right: Pre-built templates, tested workflows

Mistake 7: Poor Documentation

❌ Wrong: “We do security but don’t document well”
✅ Right: If not documented, it doesn’t exist for auditors

Penalties & Enforcement

NIS2 Penalties

Financial:

• Essential: €10M or 2% revenue (whichever higher)
• Important: €7M or 1.4% revenue (whichever higher)

Other Consequences:

• Public warnings
• Business suspension orders
• Personal liability for executives

Enforcement Trends:

• Focus on governance failures
• Late incident reporting
• Poor supply chain oversight
• Average penalties: €500K-€5M

DORA Sanctions

Financial:
• Not fixed—based on severity and systemic risk

Operational Restrictions:

• Temporary ban on activities
• Withdrawal of authorization
• Restrictions on new products
• Public statements of non-compliance

What Triggers Penalties:

• Failure to conduct TLPT
• Inadequate third-party oversight
• Missing incident reports
• Insufficient business continuity

Quick Wins: Start Now

Week 1:

1. Confirm your scope
2. Appoint compliance owner
3. Inventory critical systems
4. List all ICT providers

Weeks 2-4:

5. Create basic incident response procedure
6. Establish reporting workflows
7. Document current controls
8. Review vendor contracts

Month 2:

9. Lightweight risk assessment
10. Formalize governance structure
11. Start security training
12. Implement basic monitoring

Month 3:

13. Detailed gap analysis
14. Engage consultants (if needed)
15. Create compliance roadmap
16. Secure budget approval

Conclusion

NIS2 and DORA represent the EU’s most significant cybersecurity shift in decades. Over 180,000 organizations now face strict requirements, mandatory reporting, and severe penalties for non-compliance.

Key Takeaways:

✓ Both regulations are active—compliance isn’t optional
✓ Financial entities often need both (DORA takes priority)
✓ Penalties reach €10M or 2% revenue
✓ Full compliance takes 6-12 months

The question isn’t whether to comply, but how quickly and effectively you can build a program that satisfies regulators while improving your actual cyber resilience.

Organizations that succeed:

• Start early
• Invest appropriately
• Build unified frameworks
• Test relentlessly
• Document everything
• Improve continuously

Need Expert Help?

VistaInfosec specializes in EU cybersecurity compliance for critical infrastructure, financial entities, and ICT providers.

Our Services:

✓ NIS2 & DORA Gap Assessments
✓ Unified Governance Framework Design
✓ Third-Party Risk Management Programs
✓ Incident Response Playbook Development
✓ TLPT Preparation and Testing
✓ Independent Compliance Audits
✓ Ongoing Compliance Support

Why VistaInfosec:

• CREST certified, vendor-neutral
• Deep EU regulatory expertise
• Proven track record with financial and infrastructure clients
• Unified compliance approach (no duplication)
• Support from scoping to ongoing monitoring

Get Started:

Schedule Consultation: https://vistainfosec.com/contact-us/

Email: info@vistainfosec.com