NIS2 Compliance Guide for CISOs: What You Need to Know

NIS 2 demands a strategic upgrade in data protection and cybersecurity practices. Vaultless tokenization, built directly into the data layer, helps CISOs simplify compliance while improving security.  

Protecting sensitive data has become a global challenge, and Europe is no exception. Over the past few years, cyberattacks across the EU have surged, targeting infrastructure, healthcare, and supply chains. More than 50 million personal records have been exposed in major breaches across the EU, from Bulgaria tax agencies to UK telecoms provider.¹

To respond, the EU reinstated NIS2—a sweeping update to its cybersecurity laws. With tighter expectations around risk management, executive accountability, and breach reporting, NIS2 signals a clear shift: data protection is no longer yesterday’s issue, it’s today’s crisis, and leadership is on the hook.

This NIS2 compliance guide explores what’s changing under NIS2, what CISOs need to prioritize, and how modern, data-first strategies are helping organizations adapt while maintaining operational agility.

A Brief Look at NIS2 Directive

Europe’s original Network and Information Security Directive (NIS) was implemented in 2016 to drive baseline cybersecurity practices across member states. It made progress, but enforcement was inconsistent, and many organizations were left to interpret the rules on their own.

Meanwhile, attacks became more frequent and more sophisticated. In 2021, ENISA reported a 150% increase in ransomware activity. Critical services were disrupted. Sensitive data was exposed. It became clear that voluntary standards were no longer enough.

NIS2 responds with a more prescriptive, enforceable framework that applies to a broader set of industries and supply chains. It introduces ten minimum requirements for cybersecurity readiness, including:

• Formal risk assessments and documented security policies for IT systems

• Continuous evaluation of existing security measures and their policies and procedures.

• Clear policies and procedures for the use of cryptography and, when relevant, encryption.

• A security incident response plan covering detection, mitigation and recovery steps.

• Security protocols built into system procurements, development and operations, including policies and procedures for identifying and reporting vulnerabilities.

• Company-wide cybersecurity training in basic digital hygiene.

• Defined security/access control policies for employees handling sensitive or PII data, along with a clear inventory of critical assets and how they are managed.

• A business continuity plan that ensures up-to-date backups and maintains access to IT systems and functions during and/or after a security incident.

• The use of multi-factor authentication, continuous verification methods, and secure communication (voice, video, and messaging), especially for emergency use, when appropriate.

• Supply chain security measures tailored to each vendor’s risk level, along with regular assessments of overall supplier security posture.

Perhaps most importantly, NIS2 puts leadership in the spotlight. CISOs and executives are now directly accountable for cybersecurity failures, signalling a cultural shift in how data security is governed.

What High-Performing CISOs Are Doing Differently at Cloudera

Across industries, organizations subject to NIS2 are rethinking how they manage digital risk. But the most effective CISOs are doing more than adapting. They’re using the urgency of compliance to drive long-term architectural change.

These leaders are building security into the foundation of their data strategy, using tools like Cloudera and SecureToken to modernize how data is protected, governed, and used. Here’s what they’re doing differently.

1. Architecting for Protection, Not Just Detection

While many organizations respond to NIS2 by adding more detection tools and breach-response workflows, high-performing CISOs are shifting left by removing risk before data enters the system. Vaultless tokenization is central to this approach.

By tokenizing sensitive data at the point of ingestion, in transit or on the fly, organisations drastically shrink their compliance footprint and make privacy the default without compromising usability. SecureToken enables this by generating format-preserving tokens that maintain structure while eliminating the need to store or process raw PII.

This architectural choice is increasingly common among regulated leaders who want to enforce NIS2’s encryption, access control, and data minimization requirements through default data design, not added overhead.

2. Automating Policy Across the Data Lifecycle

Consistency is critical under NIS2. High performing organisations are replacing manual controls with automated policy enforcement, integrated directly into their data infrastructure.

With Cloudera’s native governance tools like Ranger and KMS, these data teams are able to enforce access policies, automate encryption and tokenization as part of data pipelines, and maintain audit trails and retention policies across distributed architectures.  

This consistency isn’t just about compliance, but allowing these organizations to scale securely, move faster, and reduce manual governance workloads. Where others see fragmentation, high-performing CISOs are standardizing automated governance control at the infrastructure level.

3. Turning Self-Service into a Secure Default, Not a Risk

One of the most telling signs of maturity in regulated enterprises is their stance on data democratization.

While many organizations still respond to NIS2 by locking sensitive data down, leading CISOs are doing the opposite. They’re enabling more access but doing it safely.

Using tokenization, fine-grained access controls and secure detokenization workflows to enable, these teams are unlocking secure self-service access to sensitive data for analysts, developers, and data scientists. Teams can experiment, build, and analyze without ever touching raw identifiers.

This aligns directly with NIS2’s principles around access control, security training, and incident prevention. By investing in privacy-preserving architectures, regulated organizations are proving that safe access can be a business multiplier—not a liability.

Ready to learn more?

Many people often mistakenly assume that CISO are at a disadvantage when facing regulatory pressures. Yet, as we’ve seen, CISOs leading organizations under an array of complex compliance requirements are, in fact, often better positioned to leverage their data and drive stronger business outcomes.

To learn more, check out the Bluemetrix and Cloudera Whitepaper, which explore common use cases in highly regulated industries and how these organisations are thriving with Vaultless Tokenization technology, and if you want to see how you can grow your business while securing your modern AI data stack, request a demo today.