Unpacking compliance, security and AI.
Our DPOs and CISOs regularly share their take on regulatory and technical news here: new CNPD guidelines, notable sanctions, incident lessons learned, evolutions on the AI Act, NIS 2 and DORA. To go beyond the press release.
120 articles found · #luxembourg
NIS 2: EU adopts the supply chain Toolbox — what ILR will check
On 13/02/2026, the EU adopted the EU ICT Supply Chain Security Toolbox. Under NIS 2 and Implementing Regulation 2024/2690, supplier management becomes prescriptive and must be evidenced in Luxembourg before the ILR.
15 August 2026: the Dutch Cybersecurity Act (NIS 2 NL) has entered into force
As of 15 August 2026, the Dutch NIS 2 law (Cyberbeveiligingswet) applies. For groups in Luxembourg with activities or providers in the Netherlands, obligations now apply on both sides of the border.
NIS 2 in Luxembourg: scope, categories and self‑registration
Luxembourg’s law of 5 May 2026 transposing NIS 2 has been in force since 10 May 2026. The ILR clarifies scope, the “essential/important entity” categorization, and self‑registration.
August 11, 2026: cold calling banned without consent
Since August 11, 2026, B2C cold calling in France is banned without prior explicit consent. Fines can reach €375,000 per breach for legal entities.
CJEU C‑312/24 — Erasure vs legal obligation: a relative right
The CJEU clarifies that erasure (Art. 17 GDPR) yields when a clear, foreseeable and proportionate legal obligation justifies retention, including for criminal data in HR files. Once no longer necessary, erasure becomes mandatory again.
DGFiP: 600,000 tax records for sale — warning on stealth exfiltration
On 14 August 2026, France’s Finance Ministry confirmed a DGFiP breach with over 600,000 tax records exported. A stealth exfiltration via a spoofed VPN, fueling targeted fraud risks.
NIS 2: common 24h/72h/1‑month templates — what ILR expects
On 26 May 2026, the EU adopted common incident reporting templates (24h/72h/1 month). In Luxembourg, ILR confirms this sequencing and sets out the expected content for entities.
CJEU C‑414/24 (18 June 2026): parallel GDPR remedies are not exclusive
The CJEU confirms that GDPR complaints to the authority (Art. 77) and judicial actions (Art. 79) are parallel and not mutually exclusive. An authority may not dismiss a complaint solely because a court action is pending.
CEVA Logistics: data leak at supplier — Bol and De Bijenkorf customers warned
On August 6, 2026, Bol and De Bijenkorf warned customers that a possible data leak at CEVA Logistics may have exposed names, addresses and phone numbers. The Dutch DPA was notified on August 3; no payments or passwords are implicated so far.
DORA Art. 28: Register of Information — CSSF expectations for 2026
The CSSF opened eDesk and set a DORA Register of Information submission window from 11 February to 31 March 2026. Content is standardized by ITS (EU) 2024/2956 and subject to strict validation rules.
AI Act: labelling of AI‑generated content — deadline on 2 December
AI providers get a short extension: for systems already on the market by 2 August 2026, labelling of generated content (Art. 50(2) AI Act) is due by 2 December 2026 at the latest. Deployers’ obligations remain unchanged.
AI Act: mandatory transparency from August 2 — act now
The AI Act’s transparency rules (Art. 50) have applied since August 2, 2026. Chatbots, deepfakes and AI-generated content must now be disclosed — including by deployers in Luxembourg.