The regulatory landscape in Europe is shifting rapidly, particularly as it relates to the security of critical infrastructure. I have observed a marked evolution from prescriptive compliance towards risk-based frameworks, with the introduction of NIS2 and DORA setting new expectations for technology leaders and CISOs. Freddy Dezeure’s recent analysis highlights the strategic challenges facing organisations as these regulations come into force. The key question is no longer whether compliance is possible, but how businesses can leverage regulatory pressure to truly strengthen their operational resilience.
Understanding the Global Landscape
Europe’s approach to securing critical infrastructure is not happening in isolation. The increasing sophistication of cyber threats, combined with geopolitical instability, has driven governments worldwide to reconsider their models for regulation. However, what sets Europe apart is the emphasis on risk-based requirements rather than exhaustive checklists. This represents a fundamental shift in how organisations must think about protection.
Key points shaping the global context:
- Regulatory fragmentation remains an issue, with varying standards and enforcement across regions
- Attackers are targeting supply chains and critical service providers more aggressively
- The convergence of IT and OT environments increases complexity and expands attack surfaces
From my perspective, European regulation has become a benchmark for others seeking to balance innovation with robust security.
The Landscape Facing CISOs and Technology Leaders
I believe the most pressing challenge for CISOs today lies in navigating regulatory expectations while enabling business agility. NIS2 (the updated Network and Information Security Directive) and DORA (Digital Operational Resilience Act) are not simply incremental updates; they redefine what “good” looks like in operational risk management.
Key features of this landscape include:
- Expanded scope: NIS2 now covers a broader set of entities deemed essential or important, including digital infrastructure providers
- Accountability: Senior leadership must demonstrate clear oversight of cyber risk management practices
- Continuous improvement: Organisations are expected to adopt adaptive controls based on evolving threat intelligence
These changes demand a level of strategic foresight that goes beyond mere compliance reporting. In my experience, successful CISOs are those who treat regulations as catalysts for meaningful transformation rather than obstacles.
How NIS2 and DORA Are Transforming the CISO Role
The introduction of NIS2 and DORA marks a pivotal moment for those responsible for securing critical infrastructure. Freddy Dezeure emphasises that these frameworks require CISOs to move away from static control lists towards dynamic risk assessment.
What does this mean in practice?
- Risk Ownership: CISOs now play a central role in shaping business strategy by aligning risk appetite with board priorities.
- Operational Resilience: There is increased focus on continuity planning, incident response, and real-time monitoring.
- Integrated Reporting: Regulatory requirements necessitate transparent reporting mechanisms that bridge technical data with executive decision-making.
- Vendor Oversight: Third-party risk management becomes non-negotiable as supply chain attacks proliferate.
For technology leaders, this means investing in capabilities that allow rapid detection, containment, and recovery without disrupting core operations.
Less Is More: Prioritising Effective Controls
One insight I found particularly compelling is the assertion that “not all controls are created equal.” European regulators encourage organisations to prioritise controls based on actual risk exposure rather than blanket implementation. This calls for careful evaluation of both technical and procedural safeguards.
Considerations when selecting controls:
- Effectiveness against current threat landscape
- Cost-to-benefit ratio in terms of operational impact
- Alignment with business-critical assets
In practical terms, I have seen organisations re-evaluate legacy security tools in favour of integrated solutions such as Microsoft Defender for Endpoint, Microsoft Defender for Office 365, and Microsoft Defender Vulnerability Management. These products support continuous monitoring while allowing teams to focus resources on areas where they can make the greatest impact.
Additionally, identity-centric approaches using platforms like Microsoft Entra ID (Azure Active Directory) enable granular access control that supports both compliance requirements and modern workforce needs.
From Regulation to Action: Bridging Strategy With Execution
Turning regulatory mandates into actionable programmes remains one of the largest hurdles facing technology leaders. Freddy Dezeure’s perspective highlights several pragmatic steps:
1. Conduct Comprehensive Risk Assessments
Leaders should develop holistic assessments encompassing both IT and OT environments. Tools such as Microsoft Defender for Identity facilitate proactive detection of anomalous behaviour across hybrid infrastructures.
2. Automate Response Where Possible
Automation reduces human error while accelerating incident response times. Solutions like Microsoft Security Exposure Management provide real-time visibility into emerging threats, supporting rapid containment strategies.
3. Strengthen Supply Chain Oversight
Third-party vulnerabilities remain a top concern under NIS2/DORA frameworks. Platforms such as Microsoft Entra Permissions Management help ensure vendors operate within defined risk parameters.
4. Integrate Regulatory Reporting Into Core Processes
Embedding compliance checks into existing workflows allows organisations to demonstrate ongoing alignment with regulatory demands without sacrificing efficiency.
The Role of Microsoft Deputy CISOs: A New Model For Shared Responsibility
The article discusses Microsoft’s deployment of Deputy CISOs across Europe—a model that exemplifies collaborative risk management between service providers and clients. By embedding security experts within customer teams, Microsoft enhances knowledge transfer while ensuring local context shapes strategic decisions.
Strategic implications include:
- Accelerated adoption of best practices tailored to regional regulations
- Improved coordination between internal IT teams and external partners
- Enhanced situational awareness through shared threat intelligence feeds
I see this approach as a blueprint for how global technology firms can support customers navigating complex regulatory environments.
Strategic Recommendations For Technology Leaders
Drawing from Freddy Dezeure’s analysis—and my own experience—I recommend technology leaders consider the following actions:
- Treat Regulation As An Opportunity: Use NIS2/DORA as drivers for broader digital transformation initiatives rather than isolated compliance projects.
- Invest In Visibility And Automation: Leverage integrated platforms like Microsoft Defender suites for continuous monitoring and automated response.
- Prioritise Identity And Access Management: Adopt solutions such as Microsoft Entra ID to secure access points across hybrid environments.
- Enhance Supply Chain Security: Review third-party relationships regularly using permission management tools.
- Develop Adaptive Incident Response Plans: Ensure plans are tested against evolving scenarios reflecting both IT and OT risks.
- Embed Compliance Into Business Processes: Design workflows so regulatory alignment becomes part of day-to-day operations rather than an afterthought.
- Foster Cross-Border Collaboration: Engage with industry peers and government bodies to remain current on best practices.
- Utilise Expert Support Models: Consider working with embedded experts or Deputy CISO programmes to accelerate capability development.
Conclusion: Navigating Complexity With Purpose
Europe’s risk-based regulations represent more than bureaucratic change—they signal a new era where strategic resilience underpins business success in critical infrastructure sectors. By prioritising effective controls, embracing automation, and fostering collaborative partnerships between vendors and internal teams, technology leaders can transform compliance obligations into competitive advantage.
In my view, those who approach regulation not just as an operational hurdle but as an opportunity will be best placed to navigate uncertainty while safeguarding their organisation’s future viability.
For further details on technologies referenced here: – Microsoft Entra ID (Azure Active Directory) – Microsoft Defender for Endpoint – Microsoft Defender Vulnerability Management – Microsoft Security Exposure Management
By aligning strategy with intelligent investment in these capabilities—and treating regulation as a catalyst—technology leaders can build operational resilience fit for today’s complex environment.
The Microsoft Cloud Blog 
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