Unpacking compliance, security and AI.
Our DPOs and CISOs regularly share their take on regulatory and technical news here: new CNPD guidelines, notable sanctions, incident lessons learned, evolutions on the AI Act, NIS 2 and DORA. To go beyond the press release.
39 articles found · #dora
VG Düsseldorf (02/04/2026): Transport Encryption Can Suffice
On April 2, 2026, the VG Düsseldorf held that well‑governed email transport encryption can satisfy GDPR Article 32 without mandating end‑to‑end in all cases—provided effectiveness is evidenced by measures and logs.
ENISA Cybersecurity Exercise Methodology and DORA Article 24 Compliance
ENISA released a cybersecurity exercise methodology and toolkit that directly meet DORA Article 24 scenario-based testing requirements, with concrete artifacts to evidence compliance.
CSSF 25/892: quantifying ICT incident costs — adopt 3‑2‑1‑1‑0 immutable backups
Since 28/05/2025, the CSSF requires annual aggregated estimation of costs/losses from major ICT incidents (JC 2024 34). Immutable, isolated 3‑2‑1‑1‑0 backups cut financial impact and provide the required evidence.
DORA Art. 28: Register of Information — CSSF expectations for 2026
The CSSF opened eDesk and set a DORA Register of Information submission window from 11 February to 31 March 2026. Content is standardized by ITS (EU) 2024/2956 and subject to strict validation rules.
LastPass (ICO, 20/11/2025): £1.23M for an exfiltrated backup
The UK ICO fined LastPass UK Ltd £1,228,283 after a backup repository was exfiltrated. Why to move to immutable, isolated backups (DORA Art. 12) and how to evidence compliance.
ANSSI ReCyF: immutable, isolated backups to meet DORA Art. 12
ANSSI’s ReCyF (17/03/2026) calls for immutable, isolated backups to counter ransomware. Here’s how to deploy them and evidence compliance with DORA Art. 12 and NIS 2.
NIS 2 vs DORA in Luxembourg: notify in 24 h or 4 h?
Verifiable fact: CSSF Circular 25/893 (27/05/2025) aligns DORA reporting with a first notification “within 4 hours” after classification. NIS 2 requires a preliminary alert “within 24 hours.” Key issue: who to notify, when, and against which clock in Luxembourg.
South Staffordshire Water: £963k fine for detection failures
The ICO fined South Staffordshire Water £963,900 for ~5% monitoring coverage and near-absent detection. Here’s why a 24/7 operated EDR/XDR stack is now essential.
DORA TLPT vs TIBER‑EU/LU: the key gap on internal testers
Delegated Regulation (EU) 2025/1190 allows, under strict conditions, internal testers for DORA TLPT. TIBER‑EU/TIBER‑LU require external providers for recognition.
CSSF 25/893: reporting a major incident in 4h with EDR/XDR
CSSF Circular 25/893 formalizes DORA reporting for major ICT incidents and significant cyber threats. A well‑tuned EDR/XDR stack speeds up detection, classification, and 4h/72h/1‑month notifications.
France Travail: €5M fine for inadequate security (GDPR Art. 32)
On 22 January 2026, the CNIL fined France Travail €5M for breaches of GDPR Article 32. Key takeaway: prove the proportionality and effectiveness of security measures, with clear documentation, including in Luxembourg.
CSSF — DORA: ICT register due March 31, 2026; inventory is critical
The CSSF opened the DORA ICT register collection with stricter validations. Without an automated, reliable inventory/CMDB, submissions risk rejection and supply chain blind spots remain.