New EU frameworks (NIS2, DORA and the AI Act) turn compliance into a board‑level mandate with ongoing, provable evidence as the norm.
Why ‘Provable Compliance’ Becomes the Norm
“The question is shifting from ‘Are we compliant?’ to ‘Can we prove it, every single day?’”
- NIS2 widens scope (energy, healthcare, critical manufacturing, public sector) and stresses risk management, logging/monitoring and incident reporting — with accountability at the board level. Source: European Commission (NIS2 overview).
- DORA (in force since 17 Jan 2025) harmonises digital operational resilience in finance: ICT risk management, incident classification/reporting, testing and oversight of critical third‑party providers. Source: EUR‑Lex (DORA).
- AI Act phases in through 2026/2027. Organisations developing or deploying high‑risk AI face documentation, human oversight and traceability duties. Source: European Commission (AI Act timeline).
“Regulation now demands not just policies, but proof those policies work in processes and systems.”
From Policy to System: The 3‑Layer Model
1) Governance & Risk (GRC/ISMS)
Unify policies, risks, controls, audits and evidence in one platform. Map to a backbone like NIST CSF 2.0 (incl. the Govern function) or ISO 27001/37301. Result: a single audit trail, board‑ready reporting and clean mapping to requirements.
2) Secure Collaboration & File Transfer
Many incidents stem from everyday actions (wrong recipient, open link, uncontrolled cloud sharing). Secure/managed file transfer enforces encryption, access and complete audit trails when sharing with internal and external parties.
Secure file transfer explained
3) Privacy & Third‑Party Management
GDPR fundamentals (RoPA/Art. 30, security/Art. 32, breach/Art. 33, DPIA/Art. 35) plus robust TPRM for supply‑chain risk. Note: EU hosting is often risk‑reducing but not mandatory; extra‑EEA transfers are possible under conditions (e.g., adequacy decisions or SCCs).
Integration Over Fragmentation
Disconnected tools yield snapshots. Provability emerges when logs (file transfer, IAM, EDR/SIEM), privacy artefacts (RoPA, DPIA, breach register) and access attestations/alerts are streamed into GRC dashboards. That way you can show who‑did‑what‑when — and how deviations were fixed.
“Without integration, compliance remains fragmented; with integration, evidence becomes part of daily work.”
People & Organisation: Design Against Real‑World Errors
Make the secure route the easiest route. Train for common errors (misaddressed email, wrong link permissions) and embed security by default: SSO/MFA, automated retention, and effortless file transfer with logging.
What to Do Now (Practical Steps)
- Pick your backbone: NIST CSF 2.0 or ISO 27001/37301; map existing controls.
- Automate evidence: stream logs/attestations into GRC; record remediation.
- Tame supply‑chain risk: TPRM questionnaires, clauses and periodic reviews.
- Privacy by design: refresh RoPA, DPIA templates and breach procedures.
- AI inventory: list AI uses and start documentation flows towards 2026.
Expert Panel — Msafe (knowledge contribution, non‑advertorial)
Why secure file transfer is often the missing link:
- Encryption & access: end‑to‑end encryption, role‑based permissions, MFA.
- Audit trail as evidence: every action (view, download, share) is traceable and exportable to GRC/SIEM.
- Data residency & agreements: EU data centres can reduce risk; pair with clear processor terms.
- Supply‑chain parity: require the same security/logging levels for external parties.
Practical tip: tag transfer logs with control IDs in your GRC. That lets you prove, per project or process, that policy works in practice.
About Msafe (knowledge & research)
Sources (selection)
- European Commission — NIS2 overview
- EUR‑Lex — DORA (EU) 2022/2554
- European Commission — AI Act (explanation & timeline)
- EUR‑Lex — GDPR (EU) 2016/679
- NIST — Cybersecurity Framework 2.0
- ISO — ISO 37301 (Compliance Management)
By the Msafe Research & Compliance Team
