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.
98 articles found · #reglementaire
Amazon vs CNPD (12/03/2026): fine annulled, fine methodology reset
On 12 March 2026, Luxembourg’s Administrative Court annulled Amazon’s €746m fine while upholding core findings. Key takeaway: apply CJEU (Deutsche Wohnen/Nacionalinis) and robustly justify the GDPR fine methodology.
NIS 2 in Luxembourg: what ILR really expects under Article 21
ILR clarifies board duties and expected controls for NIS 2 Article 21, aligned with Implementing Regulation (EU) 2024/2690 and Luxembourg’s 5 May 2026 law.
NIS 2 vs DORA in Luxembourg: notify in 24 h or 4 h?
Verifiable fact: CSSF Circular 25/893 (27/05/2025) aligns DORA reporting with a first notification “within 4 hours” after classification. NIS 2 requires a preliminary alert “within 24 hours.” Key issue: who to notify, when, and against which clock in Luxembourg.
DORA TLPT vs TIBER‑EU/LU: the key gap on internal testers
Delegated Regulation (EU) 2025/1190 allows, under strict conditions, internal testers for DORA TLPT. TIBER‑EU/TIBER‑LU require external providers for recognition.
Art. 28 GDPR: Garante fines Velletri over sub-processing chain
On 12 Feb 2026, the Italian Garante fined Velletri Servizi for non‑compliant sub‑processing contracts under Art. 28(4) GDPR and insufficient oversight. Key takeaway: document and audit the entire sub‑processing chain.
Data transfers outside the EU: EDPB vs ICO — essential equivalence or risk test?
On 15 Jan 2026, the ICO introduced a simplified three‑step test and TRA, diverging from the EDPB/CNPD’s ‘essential equivalence’ plus supplementary measures approach. Bottom line: distinct compliance tracks for EU vs UK transfers.
Workplace video surveillance: DPIA before any camera (Coccaglio)
Italy’s Garante fined the Comune di Coccaglio €6,000 for employee video surveillance without a credible DPIA and for disciplinary use of footage. In Luxembourg, a prior DPIA is almost always required when employees may be captured.
GDPR Record: CNPD fines for insufficient ROPA, ICO promotes flexibility
On 16 December 2025, the CNPD fined an organisation for an “insufficient” record of processing (Art. 30 GDPR). By contrast, the ICO updated a more flexible approach in June 2026. This gap affects EU–UK groups.
Vehicle geolocation in Luxembourg: CNPD requirements 2024
On 10 April 2024, the CNPD updated its guidelines: no continuous tracking or outside working hours, DPIA often required, retention generally 2 months, and obligations under Labour Code L. 261‑1.
CNPD: recording private meetings — legitimate interest only under conditions
CNPD finds consent rarely valid in meetings and allows legitimate interest only after a strict necessity and balancing test. Recordings must be deleted as soon as minutes are approved.
UL: €98,000 for late notification — what Article 33 really requires
Ireland’s DPC fined the University of Limerick for three late GDPR notifications. Here is how to meet Article 33 and notify the CNPD within 72 hours, with documented timing and solid content.
C‑97/23 P — Binding decisions of the EDPB are challengeable
The CJEU allows direct actions against an EDPB binding decision (WhatsApp v EDPB, 10/02/2026). Bottom line: intra‑group data sharing must be documented and defensible before the EU courts.