Transition from NIS1 to NIS2 and New Cyber Risk
The NIS2 Directive, which the European Union has enacted as of 2024, is a next-generation cybersecurity regulation that directly affects not only EU member states but also all suppliers and service providers working with the EU. Compared to NIS1, it is more comprehensive, tougher, faster and brings a supply chain security-centered approach.
NIS2 radically changes the culture of cyber risk management in Europe, forcing companies to move to a more proactive, more transparent and more accountable model. Especially considering ransomware attacks, supply chain vulnerabilities, and threats targeting critical infrastructure, NIS2 is not just a compliance mandate; It becomes a strategic security framework for companies to maintain business continuity.
For Turkish companies, the situation becomes even more critical: Companies operating in the EU now have to contractually request NIS2 compliance from all their suppliers. Therefore, whether you are exporting software or serving the EU in finance, energy, logistics or manufacturing, NIS2 compliance becomes a commercial imperative, not a competitive advantage.
The dizzying speed of digital transformation necessitates the evolution of legal regulations with the same dynamism. Entered our lives in 2016 Personal Data Protection Law (KVKK)is on the verge of a radical transformation with its 2026 vision. European Union GDPR, NIS2 and DORA The harmonization process with strict regulations such as these expands the scope of the expected new regulations. This process requires companies not only to update their legal texts; It will require a complete restructuring of its cyber security architecture, technical measures, data governance strategies and business continuity plans.
It is no longer enough to just act “reactively” against data breaches (trying to put out a fire after an incident); it is even a sign of negligence that can legally constitute a crime. KVKK 2026 process, companies “Proactive”forces us to establish a measurable, auditable and sustainable data protection ecosystem. Businesses that see data security as a “cost item” will have to face both heavy administrative fines and irreparable reputational damage in the near future. In this comprehensive guide, we discuss 7 critical steps to strengthen your company’s immune system against upcoming changes, with their technical depth and strategic dimensions.
Scope Expansion and Classification
NIS2 defines two main categories, greatly expanding the sectoral scope. This means that Turkish companies doing business with the EU will potentially face compliance demands in many more sectors.
1. Essential Entities
These entities represent the backbone of critical infrastructure, subject to the highest scrutiny for both operational risk and national security:
- Energy: Electricity, gas, oil and the newly added hydrogen sector.
- Transportation: Air, rail, sea and road transport.
- Finance and Banking: Banking transactions and market infrastructures.
- Health: Hospitals, laboratories, pharmaceutical manufacturing and R centers.
- Digital Infrastructure: Cloud services, data centers, DNS providers, and content delivery networks (CDN).
- Public Administrations, Water and Waste Management, Secure Communication Services.
2. Important Entities
This category, which encompasses a broader ecosystem, includes companies that play a critical role in the EU value chain. The most critical expansion for the Turkish technology and manufacturing sector is here:
- Software Developers Digital Service Providers.
- Production: Automotive, electronics, chemical, food and medical devices.
- Postal, Cargo and Logistics Companies.
- Data Centers Research Organizations.
- Managed Security Providers (MSPs).
What Does It Mean for Turkish Companies? Every Turkish company working with an Essential or Important Entity in the EU is an “indirectly obliged supplier” under NIS2. This means incorporating NIS2 annexes into contracts, regular technical audits, and providing proof of security beyond GDPR.
The 3 Most Critical New Obligations
The following obligations are becoming a new standard for EU companies as well as for Turkish companies serving them.
1. Strengthened Risk Management and Cyber Hygiene
NIS2 mandates that companies embody cyber risk management processes at the technical, operational, and managerial levels. It is no longer enough to say “we did our best”; The following controls are considered standard:
- MFA (Multi-Factor Authentication): It is mandatory to access all critical systems.
- Mandatory Encryption: Encryption of data both at rest and in transit (in transit).
- Privileged Access Management (PAM): Continuous monitoring of highly authorized users.
- Zero Trust: Continuous user and device verification (never trust, always verify).
- XDR/SIEM Usage: Threat detection, incident correlation and rapid response capability.
- Patch Management Business Continuity: Temporary closure of vulnerabilities and testing of disaster recovery plans.
2. Expedited Incident Notification: First Report in 24 Hours
One of the harshest clauses of NIS2 is the cyber incident notification periods:
- 24 Hours: “Early Warning” – Reports whether the incident has a cross-border impact.
- 72 Hours: Detailed Incident Notification – Technical details and impact analysis are provided.
- 1 Month: Final Report – Root cause analysis and actions taken.
Critical Note for Turkish Suppliers: If your partner in the EU experiences a security incident, they can request logs, forensics outputs, and technical details from your own systems within 24 hours to understand the source or impact of the incident. This makes it mandatory for Turkish companies to establish continuous monitoring (24/7 SOC) and incident response procedures.
3. Supply Chain Security
NIS2 puts supply chain risks at the center of regulation. EU companies are now obliged to require their suppliers to:
- Safety certifications (ISO 27001, SOC 2).
- Regular penetration tests and code analysis reports.
- Proof of secure software development processes (SDLC).
- Supplier risk assessment forms and vulnerability management reports.
EU companies have the legal right to remove suppliers from the system or terminate the contract if they deem risky.
Legal and Financial Consequences: Does a Turkish Company Pay a Penalty?
This section contains the answer to the most frequently asked question by Turkish administrators.
- Indirect Punishment, Not Direct: EU authorities cannot directly impose administrative fines (2% of turnover or 10M Euros) on Turkish companies.
- Contractual Recourse (Indemnity): However, if the European parent company experiences a violation and receives a penalty because of its supplier (you), it will reflect this penalty to you in accordance with the compensation clauses of the contract between you. In other words, you pay the fine to your business partner, not the state.
- Executive Responsibility: Since managers in the EU are held personally responsible, they will be extremely intolerant in auditing Turkish suppliers.
Impact on the Turkish Market – Crisis and Opportunity
For thousands of Turkish companies doing business with the EU, NIS2 becomes not just a regulation, but a commercial barrier or bridge.
Balance of Crisis and Opportunity
- Crisis: Companies that fail to prove their level of safety may be eliminated from tenders, existing contracts may be cancelled, or blacklisted as “risky suppliers”.
- Opportunity: Turkish companies that certify NIS2 compliance are positioned as “safe ports” in the EU market. This provides a great competitive advantage over competitors in long-term contracts.
NIS2 – KVKK – GDPR Triangle
The biggest advantage of Turkish companies is that NIS2 is compliant with KVKK and GDPR at many points (Data security, incident notification, risk assessment). Companies with existing KVKK/GDPR infrastructure can accelerate the process by building the business continuity and operational security layers brought by NIS2 on this foundation.
- KVKK/GDPR: It protects the Privacy of Data.
- NIS2: It maintains the Availability of Service.
5-Step Action Plan for Turkish Companies
Where should you start the adaptation process? Here is the roadmap recommended by Infosec experts:
- Scoping and Inventory: Identify which of your services are critical to EU customers and take a full asset inventory of these systems.
- Technical Gap Analysis: Differentiate between your current security posture and NIS2 requirements with a technical audit. Audit not only on paper but also on technical configurations.
- Contract Review: Review the cybersecurity and indemnification clauses in your existing client contracts with your legal team; Be prepared for possible new demands.
- Incident Response Drill: Conduct “Tabletop” drills to test your ability to report within 24 hours.
- Supplier Management: Start auditing your own subcontractors as well; Don’t be the weakest link in the chain.
Starting NIS2 Compliance Today Boosts Your Competitiveness
NIS2 sets a new standard for all Turkish companies working with Europe. Companies that do not adapt risk market loss, while those that adapt will be indispensable partners in Europe’s digital ecosystem. Now, cybersecurity is the document at the top of your tender file.
As Infosec, we are with you in your NIS2 compliance process. We analyze your current situation in technical, administrative and operational terms (Gap Analysis), provide a complete roadmap and bring your systems to EU standards.
