NIS2, DORA, CRA: Three Regulations, One Common Challenge

Why companies need integrated GRC processes instead of parallel compliance projects

NIS2, DORA and the Cyber Resilience Act are among the most important European regulations for cybersecurity, digital resilience and risk management. At first glance, they address different target groups: NIS2 applies to many essential and important entities, DORA focuses on the financial sector and its ICT service providers, while the Cyber Resilience Act places stronger obligations on manufacturers and providers of digital products.

In practice, however, it quickly becomes clear that these three regulations have more in common than many companies initially assume. They require structured risk management, clear responsibilities, documented measures, functioning reporting processes, controlled supply chains and reliable evidence.

The real problem arises when companies treat each regulation as a separate project. One project is created for NIS2, another for DORA, another for the CRA, alongside existing ISO 27001, data protection or audit initiatives. Each team works with its own lists, controls, evidence and responsibilities. This leads to duplicated work, inconsistent information and unnecessary complexity.

This is exactly why companies do not need another compliance silo. They need integrated GRC processes. By connecting risks, controls, suppliers, incidents, assets, measures and evidence in one central system, companies can meet regulatory requirements more efficiently while strengthening their cyber resilience.

Key Takeaways

NIS2, DORA and the CRA differ in terms of target groups, scope and specific obligations. What they have in common, however, is that they require companies to strengthen cyber resilience, improve risk management and maintain reliable documentation.

Companies that implement each regulation separately quickly create parallel processes. Risks are recorded multiple times, controls are documented twice, suppliers are assessed differently and evidence is distributed across different systems. This increases effort without necessarily improving security or governance.

An integrated GRC approach solves this problem. Requirements, risks, controls, measures, suppliers, incidents and evidence are managed in one shared system and linked with each other. This makes it much easier to manage NIS2, DORA, CRA and other standards such as ISO 27001, GDPR or BSI IT-Grundschutz efficiently.

Three regulations with different priorities

NIS2: Cybersecurity becomes a leadership responsibility

The NIS2 Directive significantly expands the number of regulated companies. It affects many organisations in essential and important sectors, including energy, transport, healthcare, digital infrastructure, public administration, manufacturing, food, chemicals and digital services.

At its core, NIS2 focuses on risk management, technical and organisational security measures, reporting obligations and the responsibility of senior management. It makes one thing clear: cybersecurity is not just an IT department issue. It is a management responsibility with direct governance relevance.

Companies must not only implement security measures. They must also be able to demonstrate that these measures are appropriate, documented and effective. This is where GRC becomes essential.

DORA: Digital resilience in the financial sector

DORA, the Digital Operational Resilience Act, applies to financial entities and certain ICT third-party service providers. The regulation is designed to ensure that financial organisations remain operational even in the event of cyberattacks, IT outages or problems with service providers.

The focus is on ICT risk management, incident reporting, digital resilience testing, information sharing and third-party risk management. The handling of external ICT service providers is particularly important. Financial companies must know which providers are critical, what risks exist, which contractual requirements apply and which exit strategies are available.

DORA therefore makes it clear that digital resilience does not end at the company’s own boundaries. It also depends on how well suppliers, service providers and cloud providers are managed.

CRA: Cybersecurity for digital products

The Cyber Resilience Act takes a different approach. It focuses on products with digital elements, such as software, hardware, connected devices and digital components.

Manufacturers and providers must ensure that their products are securely developed, maintained and updated throughout their entire lifecycle. This includes secure development processes, vulnerability management, security updates, technical documentation and reporting obligations for actively exploited vulnerabilities.

As a result, cybersecurity moves deeper into product development, the software lifecycle, supply chains and product responsibility. Here, too, it is not enough to describe individual security measures. Companies need established processes, clear responsibilities and reliable documentation.

The common challenge: too many parallel compliance structures

Many companies respond to new regulation by launching new projects. This is understandable, but in the long term it creates a structural problem.

A separate risk register is created for NIS2. A separate service provider register is built for DORA. For the CRA, product development maintains its own lists of products, vulnerabilities and security updates. Data protection, information security, internal audit and business continuity teams also work with their own documentation.

On paper, this may initially look like progress. In reality, it creates a patchwork of disconnected structures.

The same risk appears multiple times but is assessed differently. A control is documented for several standards but is not maintained consistently. A measure is tracked in several lists without it being clear which status is actually up to date. A supplier is assessed from a data protection perspective but classified differently under DORA. A security incident is handled technically but not properly linked to regulatory reporting obligations.

The result is not more control. It is more complexity. And complexity is one of the biggest enemies of effective compliance.

The shared requirements of NIS2, DORA and CRA

Although the three regulations pursue different objectives, they overlap in several key areas. Companies should make use of these overlaps.

Risk management

All three regulations require companies to systematically identify, assess, treat and monitor risks. NIS2 mainly focuses on risks to network and information systems. DORA focuses on ICT risks and digital operational resilience. The CRA focuses on security risks related to digital products and their lifecycle.

The common denominator is clear: risks must not be viewed in isolation. A risk is almost always connected to systems, processes, suppliers, products, controls and measures. An integrated GRC approach makes these relationships visible.

Controls and measures

Regulatory requirements remain theoretical if they are not translated into concrete measures. Companies must be able to show which security measures have been implemented, who is responsible for them, when they were reviewed and whether they are effective.

Examples include access controls, backup concepts, incident processes, vulnerability management, supplier assessments, business continuity measures, security updates and awareness measures.

The decisive factor is not only that these measures exist. What matters is that they are up to date, traceable, assigned and auditable.

Incident management and reporting obligations

NIS2, DORA and the CRA all contain obligations for handling security incidents. Deadlines, formats and competent authorities may differ depending on the regulation. However, the operational need is very similar: companies must detect, assess, escalate, document and, where necessary, report incidents.

An isolated incident process is not enough. An incident must be linkable to affected systems, products, processes, customers, suppliers, risks and regulatory obligations. Only then can a company quickly decide whether reporting is required, which deadline applies and what information is needed.

Supplier and third-party risks

DORA places particular emphasis on third-party risks. But NIS2 and the CRA also increase pressure on supply chains, service providers and external technology partners.

Companies must know which suppliers are critical, what services they provide, which data or systems are affected, which security requirements apply and which contractual arrangements are in place. Without this transparency, blind spots quickly emerge, especially in relation to cloud services, software providers, managed services and critical ICT service providers.

Integrated vendor risk management is therefore becoming a key function of modern GRC programmes.

Evidence and audit readiness

Regulatory requirements are only truly fulfilled if companies can prove it. This is exactly where many compliance programmes struggle.

The individual policy is not the real problem. The challenge is proving that it has been implemented. The risk assessment alone is not enough. It must be linked to measures, responsibilities, status, reviews and decisions.

Audit readiness is created through consistent documentation. Companies need a central view of requirements, controls, risks, measures and evidence.

Why Excel and email are no longer enough

Many companies start their compliance work with spreadsheets, SharePoint folders, email coordination and PowerPoint reports. For individual tasks, this may work. But as soon as several regulations need to be managed at the same time, this approach quickly reaches its limits.

Excel can record risks, but it cannot manage reliable workflows. Email can distribute tasks, but it cannot ensure a dependable evidence chain. Folder structures can store documents, but they cannot map regulatory dependencies. PowerPoint can present management reports, but it cannot provide an up-to-date overall view.

The problem is not the individual tool. The problem is the missing connection between information.

A risk sits in one spreadsheet. The related measure sits in another. The evidence is stored in a folder. Responsibility was agreed by email. The supplier is assessed separately. The incident is handled in a ticketing system.

During an audit, an incident or a management discussion, all of this information has to be manually collected. This costs time, creates errors and makes decision-making harder.

What integrated GRC processes can deliver

An integrated GRC approach connects governance, risk management and compliance in one shared system. Instead of managing each regulation separately, requirements, risks, controls, measures and evidence are structured centrally.

The goal is not to artificially make NIS2, DORA and the CRA identical. The legal requirements remain different. The goal is to use shared processes intelligently.

For example, an access control may be relevant for ISO 27001, NIS2, DORA and internal security requirements. It should not be documented four times separately. It is much more effective to maintain this control centrally and map it to several requirements.

The same logic applies to risks, suppliers, incidents, policies, assets and measures. An integrated GRC system ensures that information is recorded properly once and then used multiple times.

The biggest benefit: Build once, use many times

The greatest value of integrated GRC processes lies in reusability. Companies do not need to create new structures for every regulation. Instead, they can assign existing content to multiple requirements in a targeted way.

A risk assessment, for example, may be relevant for NIS2, DORA, ISO 27001 and internal security objectives. An access security control may cover several regulatory requirements at the same time. A supplier can be assessed from the perspective of information security, data protection, business continuity and DORA. An incident can be analysed technically, classified from a regulatory perspective and documented organisationally. Evidence can be relevant not just for one audit, but for several reviews.

This is where efficiency is created. Effort decreases because information does not have to be recreated again and again. At the same time, quality improves because everyone works with the same data, assessments and evidence. Companies gain not only compliance, but also better control and governance.

What an integrated GRC system should be able to do

An integrated GRC system should be able to centrally map regulatory requirements from NIS2, DORA, the CRA and other standards. This also includes ISO 27001, GDPR, BSI IT-Grundschutz, ESG requirements and internal policies.

What matters is not just documentation. The decisive factor is connectivity: Which requirement applies to which area? Which control addresses it? Which risks exist? Which measures are in progress? Which evidence is available? Where are the gaps?

A central risk register creates transparency across information security risks, ICT risks, product security risks, supplier risks and operational risks. Risks should not only be described, but also assessed, assigned to responsible owners and linked to concrete measures.

Control management also plays a central role. Controls are the link between requirements and implementation. A good GRC system shows which controls exist, which requirements they are mapped to, when they were last reviewed and whether they are effective.

Structured measure management is equally important. Compliance often fails not because insights are missing, but because implementation is not tracked consistently. Clear tasks, responsibilities, deadlines, status information and escalation mechanisms are therefore essential.

Vendor risk management is particularly important. Suppliers and service providers must be assessed based on criticality, risk, data access, contractual requirements, security evidence and dependencies. Especially under DORA, NIS2 and the CRA, an isolated supplier register is not enough.

An integrated incident process also helps companies assess security incidents not only technically, but also from a regulatory and organisational perspective. Which systems are affected? Which processes are critical? Which customers or suppliers are involved? Are there reporting obligations? Which deadlines apply? Which evidence must be documented?

Finally, management also needs a clear view. NIS2, DORA and the CRA increase pressure on senior leadership. Risks, open measures, critical suppliers, compliance gaps, incident trends and audit status must therefore be presented in a clear and understandable way.

Integrated GRC processes improve more than compliance

Compliance is often seen as a box-ticking exercise. But NIS2, DORA and the CRA are not about paperwork. They are about real resilience.

A company is not more secure simply because it has many documents. It becomes more secure when it understands its risks, implements measures consistently, clarifies responsibilities, manages incidents effectively and learns from problems.

Integrated GRC processes support exactly that. They create transparency around dependencies, weaknesses, open measures and critical areas. They show where regulatory requirements and operational risks intersect.

This is particularly important because modern cyber risks rarely affect only one area. An attack can simultaneously involve IT, data protection, suppliers, business continuity, product responsibility and communication. Companies that manage these areas separately react more slowly. Companies that manage them in an integrated way identify connections earlier and can act more effectively.

Typical implementation mistakes

A common mistake is to view NIS2, DORA and the CRA purely as legal topics. Of course, they are legal requirements. But their implementation is operational. Companies need processes, responsibilities, controls and evidence.

A second mistake is assigning responsibility solely to IT. Cybersecurity is a technical topic, but not only a technical one. Procurement, product development, legal, compliance, data protection, risk management, audit and senior management all need to be involved.

Many companies also create separate control sets for every regulation. This quickly leads to duplication. A central control framework that maps requirements from several regulations is much more effective.

Suppliers are also often involved too late. Yet third-party risks are a central element of modern regulation. Companies that only assess suppliers shortly before an audit risk gaps in contracts, evidence, security requirements and exit strategies.

Another common weakness is evidence management. Audit readiness is not created on the day of the audit. It is created through continuous documentation. Evidence must be up to date, easy to find and linked to requirements.

How companies should approach this now

Companies should not begin by building three separate programmes for NIS2, DORA and the CRA. A shared foundation is the better approach.

The first step is to clarify which regulations are actually relevant. Then companies should review existing processes, controls, risks and evidence. In many organisations, a lot already exists, but it is distributed, inconsistently documented or difficult to find.

The next step is requirement mapping. Which obligations overlap? Which existing controls can be used? Which evidence is already available? Where are processes, responsibilities or documentation missing?

Based on this, companies can build an integrated GRC structure. This includes a shared risk register, a central control framework, structured measure management, integrated supplier management, a traceable incident process and clean evidence management.

The decisive success factor is consistency. Companies need a shared data basis, clear responsibilities and standardised workflows. Only then can regulatory requirements be fulfilled efficiently and managed sustainably.

The role of Zazoon GRC

Zazoon GRC helps companies manage regulatory requirements in an integrated rather than isolated way. Risks, controls, measures, evidence, audits, policies, suppliers and incidents can be managed centrally and connected with each other.

This allows companies to map requirements from NIS2, DORA, the CRA, ISO 27001, GDPR, BSI IT-Grundschutz and other frameworks in a structured way. Instead of maintaining parallel spreadsheets and manual evidence processes, companies create a transparent GRC foundation for compliance, risk management and cyber resilience.

This integrated approach is especially important for organisations that need to meet several regulatory requirements at the same time. It reduces effort, improves traceability and creates a clear foundation for audits, management decisions and continuous improvement.

Conclusion: The future of compliance is integrated

NIS2, DORA and the CRA show where European regulation is heading: away from isolated individual obligations and towards demonstrable resilience, clear responsibility and continuous risk management.

Companies that treat each regulation separately will struggle with growing complexity, duplicated effort and inconsistent evidence. Companies that build integrated GRC processes create a scalable foundation for current and future requirements.

The key point is this: NIS2, DORA and the CRA are not just compliance tasks. They are a wake-up call for better governance.

Companies that centrally connect risks, controls, measures, suppliers, incidents and evidence meet regulatory requirements more efficiently and make their organisation more resilient at the same time.

FAQ

What do NIS2, DORA and the CRA have in common?

NIS2, DORA and the CRA pursue different objectives, but they share many common requirements. All three regulations require structured risk management, clear responsibilities, security measures, documentation, incident processes and reliable evidence. This makes them well suited to being managed through integrated GRC processes.

Why should companies not implement NIS2, DORA and the CRA separately?

Separate implementation often leads to duplicated controls, parallel risk assessments, inconsistent evidence and high manual effort. An integrated approach reduces duplication and ensures that requirements, risks, controls and measures are centrally connected.

What is the difference between NIS2, DORA and the CRA?

NIS2 focuses on cybersecurity and risk management for many essential and important entities. DORA applies to the financial sector and focuses on digital operational resilience and ICT third-party risks. The CRA applies to products with digital elements and sets requirements for secure development, vulnerability management and product responsibility.

What role does GRC play in NIS2, DORA and the CRA?

GRC connects governance, risk management and compliance. For NIS2, DORA and the CRA, this means that requirements are managed centrally, risks are assessed, controls are mapped, measures are tracked and evidence is documented. This creates transparency around regulatory obligations and their operational implementation.

Which companies are affected by NIS2?

NIS2 applies to many companies in essential and important sectors, including energy, healthcare, transport, digital infrastructure, public administration, manufacturing, food, chemicals and digital services. Whether a company is affected depends, among other things, on its sector, size and national implementation.

Who is affected by DORA?

DORA applies to financial entities such as banks, insurers, payment institutions, investment firms and other financial market participants. It also affects certain ICT third-party service providers if they are critical to the financial sector.

Who is affected by the Cyber Resilience Act?

The Cyber Resilience Act applies to manufacturers, importers and providers of products with digital elements. This includes software, hardware, connected products and digital components. Companies must ensure that these products are securely developed, documented and maintained throughout their lifecycle.

Why is vendor risk management so important?

Many companies depend heavily on external service providers, cloud providers, software suppliers and ICT partners. NIS2, DORA and the CRA increase the pressure to make these dependencies transparent. Companies must know which suppliers are critical, what risks exist and which security requirements apply.

Is ISO 27001 enough to comply with NIS2, DORA or the CRA?

ISO 27001 is a very strong foundation for information security management, but it does not replace a regulation-specific assessment. Many controls and processes from ISO 27001 can be used for NIS2, DORA and the CRA. However, companies still need to assess which specific additional requirements apply.

How does Zazoon GRC support implementation?

Zazoon GRC helps companies centrally manage requirements, risks, controls, measures, evidence, audits, policies, suppliers and incidents. This allows multiple standards and regulations to be mapped in one integrated system. It reduces manual effort and improves transparency, audit readiness and governance.