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GDPR vs NIS2 in Belgium: Key Differences

10 March 20257 min readICTLAB Team

Belgian organizations often face two major EU regulations simultaneously: GDPR and NIS2. While both aim to protect digital assets, they serve different purposes and impose different obligations. Understanding where they overlap and diverge is essential for building an efficient compliance strategy.

GDPR: Protecting Personal Data

The General Data Protection Regulation (GDPR) focuses on the protection of personal data. It applies to any organization that processes personal data of EU residents, regardless of sector or size. Key obligations include lawful data processing, data subject rights, breach notification within 72 hours, and appointing a Data Protection Officer when required.

NIS2: Securing Networks and Systems

The NIS2 Directive focuses on the security of network and information systems. It applies to organizations in specific sectors (energy, healthcare, transport, digital infrastructure, and more) that meet size thresholds. The directive requires risk management measures, incident reporting within 24 hours, supply chain security assessments, and regular vulnerability testing including penetration testing.

Key Differences at a Glance

  • Scope: GDPR applies to all organizations processing personal data. NIS2 applies to essential and important entities in designated sectors.
  • Focus: GDPR protects personal data privacy. NIS2 protects network and information system security.
  • Incident reporting: GDPR requires breach notification within 72 hours. NIS2 requires initial notification within 24 hours.
  • Penalties: GDPR fines reach up to 4% of global turnover or €20 million. NIS2 fines reach up to 2% of global turnover or €10 million for essential entities.
  • Enforcement: GDPR is enforced by national data protection authorities. NIS2 is enforced by national cybersecurity authorities (CCB in Belgium).

Where They Overlap

Despite their different focuses, GDPR and NIS2 share common ground. Both require organizations to implement appropriate technical and organizational security measures. Both mandate incident detection and reporting processes. And both expect organizations to assess and manage risks from third-party suppliers.

For organizations subject to both regulations, this overlap is an opportunity. A strong cybersecurity foundation — including risk assessments, access controls, monitoring, and incident response — serves both GDPR and NIS2 compliance simultaneously.

Practical Compliance Strategy

Rather than treating GDPR and NIS2 as separate compliance projects, Belgian organizations should build a unified security program:

  1. Map your obligations — identify which regulations apply to your organization and which specific requirements overlap.
  2. Consolidate risk management — use a single risk management framework that addresses both data protection and system security requirements.
  3. Unify incident response — build incident response processes that satisfy both the 24-hour NIS2 and 72-hour GDPR notification timelines.
  4. Integrate security into development — adopt DevSecOps practices to embed security and privacy by design into your software development lifecycle.
  5. Audit regularly — conduct regular security assessments that cover both regulatory frameworks in a single engagement.

How ICTLAB Can Help

ICTLAB helps Belgian organizations build security programs that satisfy both GDPR and NIS2 requirements efficiently. We assess your current posture against both frameworks, identify gaps, and implement technical measures that address overlapping obligations without duplicating effort. Our Brussels-based team understands the Belgian regulatory landscape and provides practical guidance tailored to your sector and size.

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