How EU Regulations Interconnect: An Integrated Compliance Approach

TL;DR

• The European regulatory landscape is intentionally interconnected: The GDPR forms the foundation, upon which NIS-2, DORA, Cyber Resilience Act, and Data Act build—supplemented by the Cloud Sovereignty Framework as a procurement guideline.
• An integrated approach significantly reduces effort: A solid ISMS based on ISO 27001, active GDPR compliance, and cloud-native principles cover large parts of the requirements of all mentioned regulations simultaneously.
• NIS-2 (from October 2024) and DORA (from January 2025) focus on cyber resilience and operational risk management; CRA (from 2027) and Data Act (from September 2025) shift the focus to secure products, interoperability, and vendor neutrality.
• The Cloud Sovereignty Framework makes these requirements measurable for procurement and architecture, linking data protection, security, exit capability, and sovereignty to concrete selection criteria for Cloud and SaaS services.
• ayedo pursues an integrated compliance approach: We combine ISO-27001-oriented processes, cloud-native architecture patterns, and EU regulatory knowledge to guide organizations structurally towards a sustainable, auditable compliance strategy.

GDPR as a Foundation: Privacy by Design as a Common Thread

The GDPR has been directly applicable law in the EU since May 25, 2018—and it is more than “just” data protection. It defines principles that run through the entire regulatory landscape:

• Data minimization, purpose limitation, transparency
• Privacy by Design and by Default
• Security of processing (Art. 32)
• Accountability obligations

These principles are compatible with all other regulations:

• NIS-2 and DORA concretize “security of processing” towards organizational and technical resilience.
• The Cyber Resilience Act transfers Privacy/Security by Design to the level of products and software supply chains.
• The Data Act connects data protection with interoperability, data access, and portability.

Organizations that take GDPR seriously not just formally but architecturally create a sustainable basis:

• Clearly defined data flows and data classes
• Role and permission concepts reflected in identity and access management systems
• Processes for data breaches that can be harmonized with incident response processes according to NIS-2/DORA
• Documentation serving as a basis for audits according to ISO 27001 and sectoral examinations

Practically, this means: A functioning data protection management system (DSMS) closely linked with the information security management system (ISMS) is not an “add-on” but the basis for an integrated compliance approach.

NIS-2 and DORA: Cyber Resilience Across the Board and in the Financial Sector

With NIS-2, the EU addresses a wide range of operators of critical and important facilities in 18 sectors—from energy and health to digital infrastructures—from October 18, 2024. DORA comes into force on January 17, 2025, acting as a lex specialis for the financial sector.

NIS-2: Horizontal Across 18 Sectors

The NIS-2 directive particularly demands:

• Systematic risk management for network and information systems
• Technical and organizational measures for cyber resilience
• Reporting obligations for security incidents
• Management responsibility and personal liability
• Consideration of supply chain security

Many of these requirements overlap with Art. 32 GDPR (security of processing) and ISO 27001:

• Risk management: Threat and vulnerability analysis, assessment of likelihood and impact
• Catalogs of measures: Access controls, network security, logging, hardening, backup & recovery
• Incident response: Detection, assessment, handling, communication
• Governance: Responsibilities, training, management reporting

DORA: Deepening for the Financial Sector

DORA addresses these points but goes deeper:

• ICT risk management with clear control objectives
• Continuous testing, including Threat-Led Penetration Testing (TLPT)
• Strict third-party risk management: Contract requirements, exit strategies, concentration risks
• Unified reporting and notification obligations for ICT incidents

For technology and platform managers, this means: Those who have cleanly implemented an ISMS according to ISO 27001, established risk-based security processes, and think cloud-natively are in a much better position for both NIS-2 and DORA. The regulatory “extra work” is less if the basic structures are already in place.

CRA and Data Act: Security by Design and Interoperability at the Product Level

While NIS-2 and DORA address the operational resilience of organizations, the Cyber Resilience Act and the Data Act focus on products, software, and data ecosystems.

Cyber Resilience Act: Products Must Be Securely Designed

The CRA is expected to be fully applicable from 2027. It obliges manufacturers of products with digital elements—essentially large parts of the software and IoT industry—to:

• Security by Design throughout the entire product lifecycle
• Clear definition and documentation of security functions
• Creation and maintenance of a Software Bill of Materials (SBOM)
• Vulnerability management and coordinated vulnerability disclosure
• Update obligations, especially for security updates
• Technical documentation as a basis for CE marking

On the architecture side, the CRA promotes clear module boundaries, reproducible builds, standardized deployment processes, and transparency in the software supply chain—all principles that are already best practice in modern cloud-native stacks.

Data Act: Interoperability and Exit Capability

The Data Act will be applicable from September 12, 2025. For cloud providers, SaaS providers, and operators of data platforms, the following points are particularly relevant:

• Data portability and interoperability—for both users and between cloud services
• Obligation to open, documented interfaces
• Avoidance of technical and contractual vendor lock-in
• Mandatory exit plans and runbooks for data and service migrations
• Transparent cost models for migration and data access

For cloud-native architectures, this is good news: Those who already rely on containerized workloads, standardized orchestration (e.g., Kubernetes), and open protocols meet many technical prerequisites for Data Act compliance. The real work lies in:

• Documentation of portability
• Standardization of export formats
• Establishment of formal exit processes
• Contract design with customers and subcontractors

Cloud Sovereignty Framework: Procurement as a Lever for Compliance

The Cloud Sovereignty Framework of the EU Commission is not a law but a procurement framework. It particularly helps public clients evaluate cloud and platform services along eight sovereignty goals (SOV-1 to SOV-8).

Key connections:

• SOV-3 (Data Sovereignty) essentially demands GDPR compliance and clarity about data access by third countries.
• SOV-4 (Operational Sovereignty) requires exit capability, interoperability, and thus direct linkage to the Data Act.
• SOV-7 (Security/Compliance) is oriented towards fulfilling NIS-2 and DORA requirements for operation and organization.

For architecture and platform managers, this results in a clear guideline: If you design infrastructures and services to perform well in the SOV logic, you not only increase your chances in tenders but also meet central requirements from the underlying regulations.

Practically, this means:

• Clear separation of data levels (e.g., personal, business-critical, public)
• Transparent data location (regions, legal areas), ideally with an EU focus
• Portability of workloads between providers and/or sovereign platform offerings
• Verifiable security and compliance processes, ideally through ISO certifications

Leveraging Synergies: An ISMS, GDPR, and Cloud-Native as a Common Denominator

The real opportunity of an integrated compliance approach lies in the synergies. Many regulatory requirements are structurally identical when elevated to an abstract level.

ISO 27001 as a Backbone

An information security management system according to ISO 27001 provides an excellent framework to integrate requirements from GDPR, NIS-2, DORA, and CRA:

• Risk-based approach: Risk analyses and treatment are core to ISO 27001, NIS-2, DORA, and CRA.
• Organization & Governance: Roles, responsibilities, policies, training.
• Technical measures: Access control, cryptography, logging, network and system hardening.
• Continuous improvement: Plan-Do-Check-Act, internal audits, management reviews.

Instead of building separate “silos” for each regulation, you can map the requirements into a single control framework and consciously leverage overlaps.

Integrating GDPR and Security Management

The connection between data protection and security is central:

• Data Protection Impact Assessments (DPIAs) can serve as input for risk analyses in the ISMS.
• Incident response plans simultaneously consider data breach notification obligations and NIS-2/DORA reporting.
• Roles like DPO (Data Protection Officer) and CISO work on a common risk basis rather than in separate tracks.

Cloud-Native Development as an Enabler

Cloud-native principles—especially automation, immutability, declarative infrastructure, and observable systems—support compliance in many areas:

• Reproducible deployments help meet CRA requirements for product consistency and updateability.
• Standardized APIs and loose coupling promote interoperability in the sense of the Data Act.
• Centralized logging, metrics, and tracing are the basis for incident detection according to NIS-2/DORA.
• Externalized configuration and secrets management support GDPR-compliant separation and protection of personal data.

Those who consciously align these three levels—ISMS, data protection, and cloud-native architecture—reduce redundant effort and shorten time-to-compliance.

Organizational Steps to an Integrated Compliance Approach

An integrated approach does not arise automatically; it is the result of deliberate design. The following steps have proven effective in practice:

1. Create a Common Map of Requirements

• Identify all relevant regulations (GDPR, NIS-2, DORA, CRA, Data Act, possibly industry-specific standards).
• Map requirements in a common control structure—ideally along ISO 27001.
• Mark overlaps: Where does one control cover multiple regulatory requirements?

2. Clarify Roles and Governance

• Clear responsibilities: Who is responsible for data protection, information security, cloud architecture, product development, procurement?
• Establish committees (e.g., Security & Compliance Board) where technical and legal perspectives come together.
• Define decision-making processes, e.g., for selecting new cloud services or for architectural decisions with compliance impact.

3. Set Technical Guardrails

• Define architectural principles that support both sovereignty and compliance (e.g., “EU-first” regions, portable workloads, open standards).