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.
CSSF — Ivanti EPMM: RCE exploited, mandatory DORA notification
On 10 February 2026, the CSSF warned of two actively exploited Ivanti EPMM RCEs (CVE‑2026‑1281/1340) and reminded firms that this constitutes a major ICT incident to notify (Circulars 25/893 and 24/847).
GDPR: first access request may be refused for abuse (CJEU 19/03/2026)
The CJEU (C‑526/24) holds that a first GDPR access request may be refused for abuse under Article 12(5). Practical key: document abusive intent and a two‑pronged proportionality test.
GDPR: no automatic damage — French Court of Cassation tightens Article 82
On 24 June 2026, the French Court of Cassation held that a GDPR breach does not, by itself, entitle a claimant to compensation: the claimant must prove damage and causation. A strong signal for data litigation across Europe.
BSI v2.0 “Logging and Detection”: What It Changes for Your Logs and SIEM
In April 2026, BSI released v2.0 of its minimum standard “Protokollierung und Detektion.” Here’s how to align logging, detection, and investigation with NIS 2 and DORA, and meet ILR/CSSF expectations.
DORA vs NIS 2 in Luxembourg: which regime prevails in an incident?
On 18/09/2023, the European Commission confirmed that sectoral acts prevail over NIS 2 as lex specialis where requirements are equivalent. DORA is one of them: in Luxembourg, the CSSF oversees incident notifications for financial entities.
Deploying ChatGPT without consulting staff: courts order suspension — and Luxembourg is not immune
On 21 May 2026, the Paris Court of Appeal suspended ChatGPT and an internal AI assistant at a press group, under a EUR 1,000 daily penalty: the works council had not been consulted before deployment. The fourth such ruling in a year. In Luxembourg the logic already exists — staff delegation, co-decision from 150 employees, AI Act in August 2026. What to check before deploying.
CNIL: vehicle location data — new recommendation
On 30 June 2026, the CNIL issued a recommendation on the use of vehicle location data. It clarifies ePrivacy consent, multi-user rights, security, data minimisation and the need for DPIAs.
ENISA publishes its Cybersecurity Exercise Methodology (16 Feb 2026)
ENISA releases a comprehensive methodology and toolkit to design and run cyber exercises. Here is how to align it with DORA (Art. 24) and NIS 2 for robust compliance evidence.
AEPD vs AENA: €10.04M for a deficient DPIA in biometrics
On 20 March 2026, the AEPD published in the BOE a €10,043,002 fine against AENA for a non-compliant DPIA related to biometric boarding. Key signal: a DPIA must now be complete, evidence-based and traceable.
AI Act D-31: transparency on 2 August, machine-readable marking by 2 December
The EU Council confirms AI Act transparency duties from 2 August 2026, with a grace period until 2 December 2026 for machine‑readable marking of AI-generated content.
UniCredit Romania: €12k GDPR fine — preventing misdirected emails
On 29 May 2026, Romania’s ANSPDCP fined UniCredit Bank SA for security shortcomings (Art. 32) and late breach notification (Art. 33) after mailings to wrong recipients. Here is practical DLP that prevents this and evidences compliance.
Legitimate interest vs consent: CNPD/EDPB tighten, ICO remains looser
Luxembourg’s Administrative Court backed the CNPD in the Amazon case: legitimate interest was not justified. While the EDPB tightens Article 6(1)(f), the UK ICO still calls it the most flexible basis.