What CISOs and security leaders need to prepare for now

If 2024 and 2025 felt like the warm-up act for regulatory change, 2026 is when several major frameworks finally land with full weight. Enforcement deadlines solidify, supervisory expectations sharpen, and the bar for what “good” looks like in cyber security, operational resilience, and AI governance moves again.

For most organisations, the challenge isn’t a lack of information, it’s too much. Every vendor and regulation claims urgency. The reality is much simpler: a handful of regulatory shifts will meaningfully impact how security teams operate in 2026. Understanding these changes now gives CISOs space to plan, prioritise, and avoid last-minute scrambles. So, let’s take a look at the key changes that you need to stay on top of in the coming year.

NIS2: Enforcement Moves from Theory to Practice

NIS2 has dominated planning cycles for two years, but 2026 is the first time it becomes genuinely enforceable in a consistent way across Member States. While the legislative deadlines arrive sooner, the real pressure, and the real expectations, started to materialise across 2025, and now converge sharply as we enter 2026.

One of the biggest shifts is scope. Sectors that once considered themselves comfortably outside of NIS requirements now fall directly under its remit, including managed service providers, digital infrastructure, public communications services, and several segments of manufacturing. Many boards are discovering that the assumption of “we’re not critical national infrastructure” no longer holds up.

Governance also becomes more explicit. Senior leadership must now demonstrate clear oversight of cyber risk, including awareness of obligations, understanding of their responsibilities, and personal involvement in approving security measures. This is a regulatory shift designed to eliminate the idea that cyber security belongs solely to IT.

Then comes the operational challenge: incident reporting. The expectation to communicate a suspected significant incident within 24 hours, followed by structured updates, demands a level of rehearsal and cross-functional coordination that many organisations have never fully tested.

For CISOs, the work in 2026 isn’t just about documentation. It’s about designing processes that actually function at speed, training leadership teams to engage meaningfully with governance, and ensuring risk narratives remain consistent across legal, security, and operations.

DORA: The Maturity Test Begins

The Digital Operational Resilience Act officially applied from January 2025, but 2026 is when financial regulators will start expecting evidence of genuine maturity, not simply plans or early-stage implementation.

The early months of DORA will be dominated by foundational tasks: creating governance structures, mapping ICT assets and dependencies, formalising incident classification, and preparing testing programmes. But by 2026, regulators expect much more than frameworks. They want proof that organisations have embedded operational resilience into the rhythm of their operations.

That means risk assessments that are living documents rather than annual exercises. It means scenario testing that leads to measurable lessons and demonstrable remediation. It means continuous oversight of third-party providers, with a clear understanding of where human decisions could undermine operational stability.

For many organisations, the human risk element is where gaps will become visible. Technology controls may be robust, but resilience collapses quickly when employees misunderstand procedures, misclassify incidents, or make unexamined assumptions about third-party responsibilities. In 2026, regulators will look closely at how organisations cultivate awareness, shift behaviours, and ensure the workforce understands its role in continuity and recovery.

AI Governance: Security Teams Inherit a New Domain

AI regulation is evolving quickly, and 2026 marks the point where this becomes a practical responsibility rather than a strategic talking point. The EU AI Act begins phasing in obligations, and national regulators across the UK, US, and beyond follow suit with guidance aimed at ensuring transparency, safety, and accountability.

For security teams, this creates two parallel challenges. The first is the surge of shadow AI use. Employees are experimenting with AI tools, often with the best intentions, but without a full understanding of the privacy, data exposure, or security implications. The second challenge is the governance of official AI deployments. High-risk AI systems, in particular, will face scrutiny around data quality, human oversight, robustness, and monitoring.

By 2026, organisations will be expected to know which AI tools they use, how these tools make decisions, what data feeds them, and how risks are mitigated. Procurement teams will rely heavily on CISOs to evaluate AI solutions, and leadership will expect clear policies that employees can understand and follow.

This is not a purely technical shift. It is fundamentally behavioural. The biggest risk from AI in 2026 is people using powerful tools without understanding the guardrails.

Data protection: Tighter expectations and wider exposure

Data protection laws globally continue to evolve, and 2026 brings a mix of sharpened enforcement and expanded expectations, particularly in areas where security and privacy intersect.

Across Europe, regulators are preparing to focus more heavily on cross-border transfers, the use of behavioural analytics, and tools that process employee data. The rise of AI-generated personal data also introduces new complexities for both privacy teams and CISOs.

In the UK, the Data Protection and Digital Information Bill, if finalised as expected, will introduce adjusted record-keeping expectations and greater flexibility around legitimate interests, while still maintaining an emphasis on demonstrable accountability. For organisations operating across both the UK and EU, this dual regulatory narrative becomes a permanent operating condition.

Globally, the picture becomes more fragmented. More US states adopt privacy laws with new obligations around children’s data, biometrics, and algorithmic transparency. Other regions tighten breach reporting windows and impose more stringent rules on data brokers and processors.

Regardless of jurisdiction, one trend cuts across all of these developments: regulators increasingly expect organisations to demonstrate that people, not just systems, handle data appropriately. Poor decision-making, rushed workflows, and procedural shortcuts are now as much compliance concerns as technological vulnerabilities.

What this means for 2026: A shift from compliance to capability

Across NIS2, DORA, new AI rules, and evolving data protection obligations, the regulatory direction is clear. The focus is no longer on whether organisations have policies or controls in place. It’s on whether those controls work in practice, under pressure, and in the hands of the workforce.

2026 rewards organisations that treat regulation as a catalyst for capability rather than a checklist. Those who invest early in cultural maturity, situational awareness, role-specific training, and cross-functional readiness will enter the year with confidence, not anxiety.

Regulators are converging on the same expectation: security and resilience depend on behaviour as much as technology. Leadership engagement, employee decision-making, and consistent reinforcement become as important as technical safeguards.

This is the moment where cyber security truly becomes an enterprise-wide discipline.

Working with MetaCompliance

Helping organisations turn regulatory pressure into behavioural and operational strength

As regulatory expectations intensify, organisations are under increasing pressure to show not just that controls exist, but that people across the business understand them, follow them, and behave securely in the moments that matter.

MetaCompliance helps organisations meet these obligations by strengthening the human layer of security and providing clear, auditable evidence of cultural and behavioural change.

Our Human Risk Management platform gives organisations visibility into where human-factor risks originate and how they evolve, turning what has traditionally been a blind spot into a measurable element of operational resilience. Automated awareness programmes allow teams to deliver targeted, adaptive learning that mirrors the way people actually absorb information, while NanoLearning provides ongoing reinforcement to keep secure behaviour active, instead of theoretical.

Policy management tools simplify governance, streamline attestations, and create defensible evidence for regulators. Meanwhile, phishing simulations and behavioural insights help organisations validate readiness and demonstrate that they can respond effectively under pressure.

As 2026 reshapes regulatory expectations, MetaCompliance provides the tools, insight, and automation to help organisations measure, mitigate, and manage human risk at scale, turning compliance into capability and culture into resilience.

To find out more about how we can help your team, contact our team today, or book a demo.

FAQs: What CISOs Need to Know for 2026

What is NIS2 and why does it matter for CISOs in 2026?

NIS2 is a cybersecurity directive expanding the scope of critical sectors. In 2026, enforcement begins across EU Member States, requiring CISOs to ensure governance, incident reporting, and operational readiness.