In today’s rapidly digitalizing world, cyber threats have emerged not merely as individual security vulnerabilities or technical failures, but as serious threats in terms of national security, economic stability, and political sovereignty. As states become increasingly dependent on digital infrastructures, attacks targeting these infrastructures result in more destructive and strategic consequences. Within this framework, the European Union (EU) is restructuring its cybersecurity policies to reduce digital vulnerabilities and strengthen the cyber resilience of its member states.
At the center of these policies lies the “Directive on Security of Network and Information Systems (NIS2 Directive),” which entered into force in 2023 and is considered a significant turning point in the EU’s pursuit of digital sovereignty. Updated in response to the shortcomings of the previous directive (NIS1) and the impact of recent cyberattacks, this framework is notable not only for its technical dimensions but also for its political and economic implications. In particular, the cyber protection of critical sectors such as energy, health, transportation, and public services will determine Europe’s level of preparedness for future crisis scenarios.
This analysis will examine the scope, strategic objectives, and impact of the NIS2 Directive on the EU’s cybersecurity architecture. It will also assess the potential consequences of this regulation for countries like Turkey, which are closely integrated with the EU economically and digitally.
1. What is NIS2?
The NIS1 Directive, which was the EU’s first comprehensive regulation on cybersecurity, entered into force in 2016 and aimed to establish a minimum security standard among member states. However, over time, it became clear that this framework was inadequate to keep pace with the speed of digitalization and the changing threat environment. Therefore, the European Commission proposed the more comprehensive and binding NIS2 Directive in 2020, which entered into force in 2023.
NIS2 is not merely an updated version of the previous regulation; it contains much deeper structural changes in terms of its scope and impact. The directive’s main objective is to raise the level of cybersecurity across Europe, to establish common security standards for critical infrastructure, and to build a more effective cooperation and supervision mechanism among member states.[1]
2. Key Features of the Directive:
• Expansion of Scope: While NIS1 covered only specific sectors (energy, transportation, banking, health), NIS2 expands the regulation to include public administrations, wastewater management, space, postal services, digital service providers, and many other sectors.
• Increased Obligations: Institutions are now subject to stricter responsibilities such as systematic risk analyses, reporting of security breaches, emergency response plans, and employee training.
• Enforcement Mechanism: The new directive foresees heavier fines and administrative sanctions for institutions that fail to meet obligations. This demonstrates that cybersecurity is no longer just a technical concern but also a legal responsibility for companies.
• Supervision and Monitoring: Regulatory authorities to be established at the national level will regularly audit the cybersecurity levels of these institutions, and data sharing and early warning mechanisms will be activated across Europe.
In short, NIS2 aims to eliminate the fragmented structure of cybersecurity across the EU and to build a more coordinated and resilient framework. In this respect, it functions not only as a security mechanism for digital infrastructures but also for the EU’s digital integrity and strategic autonomy.
3. Strategic Dimension
The steps taken by the EU with NIS2 go beyond technical security regulations and also indicate a shift in geopolitical orientation. Developments in recent years (especially the outbreak of the Russia-Ukraine War in 2022) have clearly revealed that digital infrastructures have become instruments of warfare. Within this context, cyberattacks now not only target information systems but also directly impact the operational capacity of states by disabling critical infrastructure.
Therefore, the EU has begun to evaluate cybersecurity not merely as an issue related to information technologies, but as a comprehensive threat area concerning energy security, public health, transportation systems, and even the protection of democratic processes. The strategic importance of the NIS2 Directive lies in this change of perspective.
The “digital sovereignty” concept, frequently emphasized by the EU Commission in recent years, finds tangible expression through NIS2. This concept refers to Europe’s capacity to reduce its external dependency in the digital domain, to set its own norms, and to protect its systems during crises. Achieving this goal requires the establishment of common security norms, the institutionalization of public-private cooperation, and a balanced increase in cyber resilience across the EU.
NIS2 also aims to strengthen the EU’s cybersecurity coordination with NATO. In an era marked by growing hybrid threats, the importance of transatlantic cooperation in matters such as information sharing, joint response to incidents, and exchange of strategic analyses has increased.
The regulations introduced by NIS2 aim to enhance cyber resilience particularly in sectors of vital importance such as energy, health, finance, and transportation. A systemic collapse in these areas could result not only in service interruptions but also in disruptions to public order and even political stability. Therefore, NIS2 should be evaluated not only as a digital security tool but also as a policy instrument directly linked to physical security and national integrity.[2]
4. Economic and Technological Impacts
While aiming to strengthen the EU’s digital security infrastructure, the NIS2 Directive also brings significant consequences in the economic realm. Cybersecurity has now become a top priority not only for states but also for the private sector. In this context, NIS2 represents mandatory investments and new obligations especially for digital service providers, critical infrastructure operators, and small and medium-sized enterprises (SMEs).
For SMEs, which form the backbone of the EU economy, NIS2 is both a challenge and an opportunity. While the new regulations foresee heavy penalties for firms that fail to invest in cybersecurity, they also aim to make these businesses more conscious and resilient in their digitalization processes. However, for small businesses with limited technical capacity, this situation may result in additional cost pressures and adaptation difficulties. Therefore, the EU Commission has developed some support mechanisms and guidance documents under NIS2. The goal is to facilitate the compliance of SMEs with the regulation and to prevent security vulnerabilities from spreading across the economy. After all, the weakest link in the chain determines the fragility of the entire system.
The obligations introduced by NIS2 do not only concern small businesses but also include major digital platforms and technology companies. These firms providing critical digital services are now legally subject to oversight not only in terms of technical interventions but also in areas such as data storage policies, crisis management, and employee training. This can be interpreted as part of the EU’s tendency to exert tighter control over the digital sphere.
NIS2 is an extension of the EU’s digital regulation policy, which began with the General Data Protection Regulation (GDPR) and continued with the Digital Services Act (DSA) and the Digital Markets Act (DMA). This approach serves the strategy of positioning Europe not only as a consumer but also as a norm-setting actor in the digital market. NIS2 is also seen as a factor that triggers the growth of the cybersecurity sector in Europe. New markets are emerging in areas such as security software, consultancy, auditing services, and cyber crisis management; employment is increasing and R&D investments are being encouraged. Therefore, NIS2 is a strategic tool not only for security but also for innovation and economic growth.
The NIS2 Directive is a comprehensive response developed by the EU not only to cyber threats but also to the strategic uncertainties and external dependencies encountered in the digitalization process. While securing digital infrastructures, the regulation also aims to strengthen the EU’s role as a global digital rule-maker.[3]
In conclusion, NIS2 stands out as a cornerstone of the Union’s strategic autonomy vision in the field of cybersecurity, going beyond a mere technical reform. By assigning responsibilities to both public and private sector actors, the EU aims to create a common norm in digital security and to make its internal market more resilient.
For candidate countries like Turkey, NIS2 is a development that must be carefully monitored both in terms of the alignment process and the perspective of digital integration with the EU. In particular, the need to align with EU standards in critical infrastructures is directly linked to the priorities of Turkey’s digital security policies. Ultimately, NIS2 is not merely a directive but an expression of the EU’s determination to establish a new security architecture for its digital future.
[1] European Parliament Research Service (EPRS), https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX%3A32022L2555, (Access Date: 23.04.2025).
[2] ENISA’s NIS2 Page https://www.enisa.europa.eu/topics/awareness-and-cyber-hygiene/raising-awareness-campaigns/network-and-information-systems, (Access Date: 23.04.2025).
[3] European Commission Information Page on NIS2, https://digital-strategy.ec.europa.eu/en/policies/nis2-directive, (Access Date: 23.04.2025).
