Incident Notification and Information Sharing Requirements: EU Digital Laws

🔹 What’s Covered

The IAPP’s “Incident Notification and Information Sharing Requirements: EU Digital Laws” is a practitioner-focused reference guide that maps out who must report what type of digital incident, to whom, when, and under what legal trigger—across a broad regulatory spectrum. It covers 11 EU legal instruments:

GDPR and Law Enforcement Directive (for personal data breaches)
e-Privacy Directive (for telecom-related breaches)
Data Governance Act and Data Act (for unauthorised data reuse/access)
NIS2 Directive (for significant cybersecurity threats and near misses)
Digital Operational Resilience Act (DORA) and PSD2 (for ICT incidents in finance)
Cyber Resilience Act (CRA) (for vulnerabilities in digital products)
AI Act (for serious incidents involving high-risk AI systems)

Each row in the chart outlines:

The notifying entity (e.g. provider, controller, manufacturer)
The incident type (e.g. breach, vulnerability, cyber threat)
The recipient of the report (e.g. competent authority, ENISA, the public)
The notification timeline (e.g. “without undue delay,” 72 hours, etc.)
The legal trigger (e.g. “likely to result in high risk”)

Some laws also include further sharing obligations—e.g. cascading information to other regulators, ENISA, or the public. Notably, for DORA and CRA, timelines are granular and align with evolving regulatory technical standards.

Practitioners can use this as a compliance mapping tool, especially when managing overlapping obligations (e.g. a breach involving both GDPR and NIS2). While primarily a visual aid, the chart cites relevant articles and includes URLs to full legislative texts, enhancing its utility for legal deep dives.

🔹 💡 Why It Matters?

In a digital ecosystem shaped by overlapping sectoral laws, this tool reduces complexity and helps organisations avoid fragmented or incomplete incident response. It’s especially valuable for ensuring timely and legally sound communication with authorities and stakeholders during crises.

🔹 What’s Missing

The chart does not include enforcement risk or penalty implications for non-compliance. Nor does it offer strategic guidance on prioritisation in multi-law scenarios or sector-specific edge cases (e.g. joint incidents involving AI and finance). Some laws (like the DSA) are also not included.

🔹 Best For

Ideal for privacy officers, legal counsels, incident response teams, and regulatory liaisons managing cross-functional compliance during security or data incidents. Also useful for AI governance professionals navigating reporting under the new AI Act.