Q4 2025 Compliance Horizon: Strategic Preparation Guide for DPOs and Compliance Officers

Essential regulatory deadlines, frameworks, and strategic actions for global compliance leaders as we approach the final quarter of 2025

Executive Summary

The final quarter of 2025 presents a convergence of critical compliance deadlines that will reshape global regulatory landscapes. Key immediate actions required include EU DORA Register of Information submissions by April 30, 2025, CSRD sustainability reporting preparation for 2025 financials, and NIS2 entity classification deadlines by April 17, 2025. Looking ahead to Q4 2025 and early 2026, organizations face significant implementation deadlines across cybersecurity, financial services, sustainability reporting, and data protection frameworks. This guide provides strategic insight for compliance leaders to navigate these complex, overlapping requirements.

Navigating the Digital Frontier: How DORA Reshapes Third-Party Risk Management

The modern digital supply chain is an increasingly intricate and interconnected web, posing significant risks that extend far beyond an organization’s direct third-party vendors. In response to a surge of damaging supply chain attacks, the European Union enacted the Digital Operational Resilience Act (DORA), a new set of laws designed

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Critical Immediate Deadlines (Q1-Q2 2025)

EU DORA Compliance - Active Now

Status: DORA entered full application on January 17, 2025, making compliance mandatory for financial entities operating in the EU

Immediate Actions Required:

• April 30, 2025: Financial entities must submit comprehensive registers of contractual arrangements with ICT service providers to national competent authorities, which must then report to ESAs
• July 2025: ESAs will perform criticality assessments and notify ICT third-party service providers of their classification as critical

DPO/Compliance Officer Priorities:

• Complete register of information documentation using final templates published November 29, 2024
• Review and remediate third-party ICT service provider contracts
• Implement digital operational resilience testing protocols
• Establish incident classification and reporting frameworks

DORA Compliance Guide: EU Digital Operational Resilience Requirements

Implement effective DORA compliance with comprehensive guidance on EU Digital Operational Resilience Act requirements, ICT risk management, and implementation strategies for financial entities.

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NIS2 Directive - Post-Implementation Phase

Status: NIS2 replaced NIS1 as of October 18, 2024, with Member States required to transpose into national law by October 17, 2024

Key Upcoming Deadlines:

• April 17, 2025: Member States must publish lists of essential and important entities
• January 17, 2025: Cooperation Group must establish peer review methodology

Strategic Considerations:

• Organizations face potential fines of up to €10 million or 2% of annual revenue for non-compliance
• Many Member States missed the October 2024 transposition deadline, creating compliance uncertainty
• Medium-sized and large entities in critical sectors must implement comprehensive cybersecurity risk management measures

Navigating NIS2 Compliance: A Deep Dive into ENISA’s Technical Implementation Guidance for Robust Cybersecurity Risk Management

As the digital landscape continuously evolves, so do the threats to our network and information systems. In response, the European Union has strengthened its cybersecurity framework through the NIS2 Directive. To aid entities in meeting these stringent requirements, the European Union Agency for Cybersecurity (ENISA) has published comprehensive Technical Implementation

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