TL;DR: NIS-2, the Cyber Resilience Act and eIDAS 2.0 shift European digital security from guidance to enforceable control, with more than 30,000 mid-sized companies in Germany alone newly or explicitly in scope, according to KOBIL. The practical message is that documentation without technical identity and access enforcement will not withstand regulatory scrutiny.
Editorial analysis by NHI Mgmt Group, based on content published by KOBIL: “NIS-2, Digital Identities, and Operational Security 2026”.
Key questions
Q: What fails first when NIS-2 is handled as documentation instead of enforcement?
A: The first failure is evidentiary.
Q: Why do shared credentials and stale accounts matter so much under NIS-2?
A: They destroy traceability and ownership.
Q: How do security teams know if identity controls are supporting privacy compliance?
A: Look for evidence that access decisions are contextual, logged, and reviewable.
Practitioner guidance
- Map regulated systems to identity-owned access paths Identify where human users, service accounts and third parties can reach regulated systems, then assign a clear owner to each access path and approval route.
- Eliminate shared credentials and orphaned accounts Inventory shared logins, stale accounts and unclear role assignments, then remove or reissue them so every active identity can be traced to a responsible owner.
- Prove least privilege with auditable evidence Check whether entitlement reviews, provisioning events and revocations produce evidence that survives external challenge, not just internal policy sign-off.
Bottom line: NIS-2, the Cyber Resilience Act and eIDAS 2.0 change identity governance from a supporting discipline into a regulated control requirement.
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Identity governance is now the enforceable boundary of European cyber compliance. The article correctly shows that NIS-2, the Cyber Resilience Act and eIDAS 2.0 move identity from an enabling function to a regulated control plane. That changes how boards and security leaders should think about accountability, because access control is no longer just an IT implementation detail. Practitioners should treat identity governance as part of regulated operational control.
A question worth separating out:
Q: How should organisations govern identity across NIS-2, the Cyber Resilience Act and eIDAS 2.0?
A: Treat identity as a shared governance layer rather than separate compliance tasks. The practical test is whether access, authentication, traceability and reporting can be enforced consistently across systems and business units. If the controls differ by platform, the organisation will struggle to demonstrate a coherent security posture under inspection.
👉 Read our full editorial: NIS-2, CRA and eIDAS 2.0 make identity control mandatory