The Evolving European Compliance Landscape

As essential and important European organizations work to meet NIS2 compliance deadlines and financial institutions implement DORA requirements, forward-thinking executives should already be preparing for the next wave of cybersecurity and compliance mandates. Based on current regulatory trajectories, market demands, and the evolving threat landscape, it’s increasingly evident that SOC2 compliance will emerge as the next de facto—and potentially mandatory—framework for critical infrastructure operators across Europe. While currently prevalent primarily in North America, SOC2’s comprehensive approach to security, availability, processing integrity, confidentiality, and privacy makes it the logical next step in Europe’s regulatory evolution. This article examines why SOC2 is positioned to become Europe’s next mandatory compliance framework and how proactive organizations can gain competitive advantage through early adoption.

The Regulatory Evolution: From NIS2 and DORA to SOC2

Current European Landscape

The European regulatory environment has progressed through increasingly comprehensive frameworks:

• GDPR (2018): Established baseline data protection requirements
• NIS Directive (2018): Introduced initial cybersecurity requirements for essential services
• NIS2 Directive (2022): Expanded scope and deepened security requirements
• DORA (2022): Added financial sector-specific resilience requirements

Each iteration has expanded both scope and depth of requirements, moving toward more comprehensive security and resilience frameworks.

Why SOC2 Is the Logical Next Step

Several indicators point to SOC2 becoming Europe’s next mandatory framework:

• Cross-Border Business Requirements
• Harmonization of Global Standards
• Gaps in Current Frameworks
• Increased Supply Chain Focus
• Shareholder and Stakeholder Pressures

European companies conducting business with North American entities already face market pressures to obtain SOC2 certification to remain competitive in global markets. The EU has consistently moved toward alignment with international best practices, and SOC2 represents the gold standard for security and operational controls. While NIS2 and DORA establish strong baseline requirements, they lack the comprehensive third-party assurance mechanisms and operational excellence focus that SOC2 provides. Recent regulatory trends emphasize vendor and supply chain security—an area where SOC2’s attestation model excels. Market demands for demonstrable security assurance are pushing organizations toward frameworks with independent attestation.

What SOC2 Adds Beyond NIS2 and DORA Requirements

SOC2 complements and enhances existing European regulatory frameworks in several critical areas:

1. Independent Third-Party Attestation

While NIS2 and DORA focus on self-assessment and regulatory reporting, SOC2 requires:

• Independent auditor verification of controls
• Regular attestation reports (Type I and Type II)
• Continuous monitoring rather than point-in-time compliance

2. Trust Services Criteria Beyond Security

SOC2 extends beyond cybersecurity to address:

• Availability: Systems remain operational and accessible as committed or agreed
• Processing Integrity: System processing is complete, valid, accurate, timely, and authorized
• Confidentiality: Information designated as confidential is protected
• Privacy: Personal information is collected, used, retained, disclosed, and disposed of in accordance with commitments

3. Operational Excellence Requirements

SOC2 encompasses operational elements often minimized in regulatory frameworks:

• Change management processes
• System operations and monitoring
• Human resource management
• Risk mitigation
• Logical and physical access controls

4. Customizable Control Selection

Unlike the prescriptive approach of NIS2 and DORA, SOC2 allows:

• Selection of relevant trust services criteria based on business needs
• Customization of control implementation to fit organizational structure
• Scaling of requirements based on organizational complexity

5. Continuous Compliance Model

SOC2 promotes a continuous compliance approach through:

• Ongoing monitoring requirements
• Type II reporting covering operational effectiveness over time
• Periodic reassessment and attestation

Implementation Challenges: Why Early Adoption is Critical

Implementing SOC2 presents several challenges that make early adoption advantageous:

1. Time Investment

SOC2 implementation typically requires:

• 6-12 months for initial gap assessment and remediation
• 3-6 months for audit preparation
• Observation period of at least 6 months for Type II attestation

Starting now means you’ll be prepared when regulatory requirements inevitably emerge.

2. Resource Requirements

Successful implementation demands:

• Cross-functional team involvement
• Executive sponsorship
• Dedicated compliance resources
• Technical expertise for control implementation

Organizations that begin building these capacities now avoid resource contention when compliance becomes mandatory.

3. Cultural Transformation

SOC2 requires a shift toward:

• Security and compliance as business enablers
• Documentation and evidence-based operations
• Continuous monitoring and improvement

These cultural changes require time to develop and mature—time that won’t be available if implementation is rushed to meet regulatory deadlines.

4. Third-Party Management

SOC2’s emphasis on vendor management necessitates:

• Vendor assessment processes
• Contract revisions to include security requirements
• Monitoring of third-party compliance

Building these processes proactively allows for strategic vendor selection rather than reactive compliance efforts.

The Business Case for Proactive SOC2 Implementation

Beyond regulatory preparation, early SOC2 adoption delivers tangible business benefits:

1. Competitive Differentiation

Organizations with SOC2 attestation can:

• Demonstrate superior security posture to potential customers
• Expedite vendor approval processes
• Address security questionnaires more efficiently
• Stand out in procurement processes

2. Operational Efficiency

SOC2’s control framework promotes:

• Standardized processes that reduce operational variability
• Clear roles and responsibilities
• Automated monitoring and reporting
• Reduced incident response time

3. Risk Reduction

Comprehensive controls implementation results in:

• Lower likelihood of security incidents
• Reduced impact when incidents occur
• More consistent responses to threats
• Improved evidence for cyber insurance applications

4. Simplified Multi-Framework Compliance

Organizations that implement SOC2 find it easier to:

• Map controls to multiple frameworks (ISO 27001, NIST, etc.)
• Respond to customer security questionnaires
• Demonstrate compliance with various regulatory requirements
• Maintain consistent security posture across jurisdictions

How Minotaur Solutions Facilitates Proactive SOC2 Compliance

Recognizing the future importance of SOC2 compliance for European organizations, Minotaur Solutions offers specialized services designed to help energy sector BRPs and other critical infrastructure operators achieve SOC2 compliance efficiently while maintaining their existing NIS2 and DORA compliance programs.

1. Integrated Compliance Approach

Minotaur’s methodology harmonizes requirements across frameworks to:

• Leverage existing NIS2/DORA controls for SOC2 compliance
• Implement unified policies addressing multiple framework requirements
• Develop integrated evidence collection and reporting mechanisms
• Create compliance synergies rather than siloed approaches

2. Readiness Assessment and Gap Analysis

Our comprehensive evaluation:

• Determines current alignment with SOC2 requirements
• Identifies control gaps between existing frameworks and SOC2
• Prioritizes remediation activities by risk and impact
• Establishes realistic implementation timelines

3. Control Implementation Acceleration

Minotaur accelerates implementation through:

• Pre-built policy templates aligned with multiple frameworks
• Automated evidence collection tools
• Implementation prioritization based on risk exposure
• Facilitated workshops for expedited control development

4. Pre-Audit Preparation

Our pre-audit services include:

• Mock audits to identify potential findings
• Evidence package preparation and review
• Control narrative development
• Audit response coaching for key personnel

5. Continuous Compliance Management

Minotaur supports ongoing compliance with:

• Automated monitoring solutions
• Periodic control testing
• Change impact assessment for compliance
• Regulatory horizon scanning for emerging requirements

Conclusion: The Strategic Imperative of Early SOC2 Adoption

The progression of European regulatory frameworks points clearly toward SOC2 becoming the next mandatory compliance standard for critical infrastructure operators. Rather than waiting for this requirement to be formalized, forward-thinking organizations should view SOC2 implementation as a strategic opportunity to:

• Gain competitive advantage in an increasingly security-conscious marketplace
• Establish operational excellence that delivers business benefits beyond compliance
• Reduce the risk and resource burden of reactive compliance activities
• Demonstrate leadership in security and governance to stakeholders

As regulatory requirements continue to evolve, organizations that proactively adopt comprehensive frameworks like SOC2 will find themselves consistently ahead of compliance deadlines, able to focus on innovation rather than remediation. With NIS2 compliance now mandatory and the March 17th, 2025 registration deadline approaching, energy sector BRPs have a window of opportunity to extend their compliance programs toward SOC2 while implementing NIS2 requirements. This integrated approach, facilitated by Minotaur Solutions’ expertise, offers the most efficient path to comprehensive compliance and true operational resilience.

Minotaur Solutions provides end-to-end compliance support spanning NIS2, DORA, and SOC2 frameworks. Contact us today to learn how our integrated approach can position your organization ahead of regulatory requirements while delivering immediate security and operational benefits.