DORA, NIS2, GDPR: The Compliance Guide for SAP Systems 2025 – How new regulations affect SAP landscapes and are implemented automatically

A recent study by the European Banking Authority shows that 78% of financial institutions see the implementation of the Digital Operational Resilience Act (DORA) as their biggest regulatory challenge in 2025. At the same time, companies in critical sectors must meet the tightened requirements of the NIS2 Directive, while the GDPR continues to impose strict data protection standards. SAP systems are particularly in focus: As a central hub for business processes and sensitive data, they must comply with all three regulations simultaneously.

The complexity is overwhelming: DORA requires detailed documentation of operational resilience, NIS2 demands comprehensive cybersecurity measures, and the GDPR requires strict data protection controls. Traditional, manual compliance approaches are reaching their limits. Modern automation solutions like the automatics SmartSecOps Platform are therefore becoming a decisive success factor for an integrated compliance strategy.

DORA: Operational Resilience for the Digital Age

The Digital Operational Resilience Act came into force on January 17, 2025, and revolutionizes the compliance landscape for financial service providers. DORA requires comprehensive operational resilience – from identifying critical business functions to detailed documentation of all ICT risks.

The DORA challenges for SAP systems

SAP landscapes are particularly affected: They process critical financial data, manage payment transactions, and form the backbone of operational processes. DORA Article 8 explicitly requires the identification and documentation of all "critical or important functions"—and SAP systems almost always fall into this category.

The requirements are precise: complete inventory of all ICT assets, continuous monitoring of operational risks, documented recovery strategies for all critical systems, regular resilience tests with detailed documentation, and comprehensive reporting to regulatory authorities.

The core requirements for DORA

DORA consists of five main pillars that are crucial for you and your team:

		Significance for SAP:
ICT risk management	Companies must establish formal IT risk management.	Risk analysis of SAP systems (e.g. unsecured RFCs, overprivileged users). Hardening SAP systems. Continuous monitoring (monitoring of logs, configurations and permissions).
ICT incident reporting	All “significant incidents” must be reported within 24 hours .	Security incidents such as SAP ransomware, unauthorized system changes, or failed SAP patches must be incorporated into central incident management. Automated interfaces to SIEM systems are essential here.
Digital operational resilience tests	Mandatory penetration testing (TLPT – Threat-Led Penetration Testing) .	SAP-specific attacks (e.g. transport manipulation, RFC hijacking) must be taken into account in the test. Many companies neglect SAP during pen testing – DORA will change that.
Third-party risk management	Companies must control their service providers.	Managed service providers or RISE/HEC providers must be included in the risk analysis. SLA requirements (patch cycles, monitoring) must be documented and verifiable.
Information exchange	Financial institutions should share information on threats.	Security teams must share SAP-specific vulnerabilities (e.g., new SAP Security Notes). Collaboration with CERTs or industry initiatives.

NIS2: Cybersecurity for Critical Infrastructures

The NIS2 Directive has significantly tightened cybersecurity requirements since October 2024. Companies in critical sectors—from energy to transportation to healthcare—must implement and document comprehensive security measures.

NIS2 requirements for SAP landscapes

Article 21 of the NIS2 Directive defines clear technical and organizational measures: implementation of appropriate security measures for network and information systems, continuous monitoring and incident detection, regular security assessments and penetration tests, and immediate reporting of security incidents to national authorities.

Particularly relevant for SAP environments: Supply chain security must be ensured end-to-end, encryption is mandatory for all sensitive data, zero-trust principles must be implemented, and continuous monitoring is required for all critical systems.

The core requirements for NIS2

NIS2 sets out 10 minimum security requirements :

		Significance for SAP:
Risk management	Commitment to safety measures to reduce risks.	Vulnerability management (SAP Security Notes). Monitoring RFC connections, user activities and custom code.
Incident handling	Response and reporting obligations in the event of security incidents	SAP-specific security incidents must be reported within 24 hours . Automated incident reports for SAP facilitate documentation.
Business Continuity & Crisis Management	Emergency operations and recovery plans.	Backup strategies for SAP HANA and ABAP systems. SAP ransomware attack scenarios.
Supply chain security	Assessing the safety of suppliers and service providers.	Monitoring SAP service provider access. Security agreements with hosting or cloud providers.
Security by Design	Security requirements must be taken into account in the system architecture.	Hardening SAP systems. Minimal authorizations (least privilege).
Vulnerability management	Continuous detection and remediation of vulnerabilities.	Automated analysis of missing security notes. Monitoring of insecure custom developments.
Multi-factor authentication & encryption	Mandatory MFA and data encryption.	MFA for SAP GUI and web access (Fiori). Encryption of RFC and SAPRouter connections.
Logging and monitoring	Obligation to log safety-relevant events.	Central collection of SAP logs (Security Audit Log). Anomaly detection in SAP transactions.
Reporting to national authorities	Initial notification within 24 hours, follow-up within 72 hours.	Automated incident reports with SAP-specific data.
Management liability	Managers can be held personally liable for violations.	Management must understand SAP risks and include them in risk reports.

GDPR: Data protection as a fundamental principle

The General Data Protection Regulation remains the gold standard for data protection in the EU. Articles 25 (Privacy by Design), 32 (Security of Processing), and 35 (Data Protection Impact Assessment) are particularly relevant for SAP systems.

GDPR challenges in SAP environments

SAP systems process massive amounts of personal data: employee data, customer master data, payment information, and behavioral data. It is estimated that 70% of the world's corporate data is stored in SAP systems. GDPR compliance requires precise control over every data access, export, and processing operation.

Critical requirements: Purpose limitation must be documented for all data processing, deletion concepts must be implemented automatically, data subject rights (information, correction, deletion) must be quickly fulfilled, and data protection impact assessments are required for all critical processing.

Integration of the three regulatory frameworks : The holistic approach

The real challenge lies not in the individual implementation of DORA, NIS2, or GDPR, but in their intelligent integration. All three regulatory frameworks overlap in critical areas: data security, incident management, and documentation requirements.

Use synergies, avoid redundancies

Consistent documentation: Compliance-relevant events are recorded centrally and provided in regulation-specific formats. A security incident is automatically documented for DORA resilience reporting, NIS2 incident notifications, and GDPR data breaches.

Integrated monitoring: Simultaneously monitor DORA-relevant operational metrics, NIS2 security indicators, and GDPR data protection events. Correlation analyses identify overarching risks and compliance gaps.

Automated reporting: Predefined templates automatically generate compliant reports for various regulatory authorities. AI-based analytics proactively identify potential compliance risks.

Automated remediation: Intelligent detection of compliance deviations through continuous system scanning, automated response to identified findings through predefined workflows, and proactive implementation of necessary system changes to restore compliance – without manual intervention and with complete audit documentation of all corrective actions taken.

Practical implementation: The path to automated compliance

Phase 1: Assessment and Planning

Identify all affected departments and teams, define core requirements related to the specific business, and specify the requirements for the SAP operations team. This analysis leads to the implementation and planning of measurable security and compliance controls, as well as their recurring system administration. Use the Transparency Hub as a fundamental basis for a rapid assessment.

Phase 2: Technical implementation

Implementation is carried out systematically across all five hubs: The Transparency Hub creates transparency through centralized capture and visualization of security-relevant SAP system data. The Operation Hub automates all SAP Basis operations, from start/stop to full-stack patch management. The Lifecycle Hub handles critical processes such as certificate management and SAP Security Notes. The Refresh Hub enables efficient system and client refresh processes. Finally, the Security Hub implements zero-trust principles with context-based data classification and Microsoft Purview integration for encrypting sensitive data.

Phase 3: Operationalization

In the final phase, the continuous SecOps cycle is established – the intelligent connection of SAP Security and SAP Operations. This continuous loop ensures that SAP security and operations are no longer treated as separate disciplines, but as integrated, mutually reinforcing processes.

The OperationHub ensures stable operations: automated system maintenance outside of critical times, intelligent resource optimization for better performance, and integrated backup and recovery strategies.

The Lifecycle Hub automates central lifecycle processes in SAP systems. These include SAP certificate management with proactive renewal, distribution, and activation in STRUST, the deployment of support packages including automated pre- and post-processing, and the implementation of security-relevant SAP Notes at the push of a button.

The LifecycleHub supports companies in implementing safety-critical measures in a fully automated manner – including comprehensive documentation and auditing of all safety-relevant changes.

The RefreshHub supports compliance testing: Rapid creation of test environments for penetration testing, data refresh processes for GDPR compliance, and efficient rollback mechanisms after compliance testing.

The SecOps approach, combined with SIEM solutions, combines proactive security measures with operational excellence. Continuous monitoring identifies security risks and operational anomalies. Automated response mechanisms react to both security incidents and system problems. Predictive analytics anticipate both security threats and maintenance needs.

This holistic operationalization ensures that compliance is not established as a one-time project, but as a continuous, self-optimizing process – the key to sustainable DORA, NIS2, and GDPR compliance in dynamic SAP landscapes.

Measurable compliance benefits

Companies that use SmartSecOps Platform for targeted SAP compliance management report dramatic improvements:

Time savings: 75% less manual work for compliance documentation, automated report creation reduces effort by 60%, and proactive risk identification shortens incident response by an average of 45%.

Cost reduction: Avoidance of penalties through proactive compliance controls and their measures, reduced audit costs through continuous compliance documentation and optimization of compliance efforts through automation.

Risk minimization: 85% fewer compliance violations through automated controls, proactive identification of risks before audits and continuous monitoring of all regulatory-relevant processes and the possibility of automated correction of identified risks.

Conclusion: Intelligent automation as a compliance enabler

DORA, NIS2, and GDPR pose unprecedented challenges for SAP landscapes. The complexity and overlap of these three regulatory frameworks overwhelm traditional, manual compliance approaches. Only through intelligent automation can companies achieve the required compliance quality with reasonable effort.

The automatics SmartSecOps Platform demonstrates how integrated compliance automation works. Through the clever combination of five specialized hubs, all three regulatory frameworks are addressed simultaneously – without redundancies, with maximum efficiency.

Companies that invest in modern, integrated compliance solutions today not only create better regulatory compliance but also sustainable competitive advantages through optimized processes and reduced risks.

Given the current regulatory density, intelligent compliance automation is no longer a small task, but a strategic necessity for sustainable business success in regulated markets.

Contact us today to learn how the SmartSecOps Platform can revolutionize your DORA, NIS2, and GDPR compliance.