Strategic Legal Insights for Businesses in a High-Risk Digital Environment

The European and Greek regulatory landscape for cybersecurity, data protection and digital governance is undergoing a structural transformation. What was once a technical compliance exercise has now become a core board-level responsibility, a source of liability exposure, and a decisive factor for market competitiveness.

For companies operating in or through Greece, the new framework creates:

• increased regulatory scrutiny

• expanded accountability for management

• cross-border compliance complexity

• new opportunities for secure digital growth

The latest legislative and institutional developments confirm a clear direction: cyber-resilience is no longer optional, it is a legal, operational and strategic obligation.

Greece’s National Cybersecurity Strategy 2026–2030: From Policy to Binding Governance Expectations

Greece has adopted a comprehensive National Cybersecurity Strategy for 2026–2030, aligned with the evolving EU framework (NIS2, DORA, Cyber Resilience Act).

This is not a policy document of political intent — it is a roadmap that will directly affect corporate compliance obligations, supervisory practice and enforcement priorities.

Core legal and regulatory impact

The Strategy introduces:

• a whole-of-society governance model

• mandatory security-by-design and lifecycle risk management

• national cyber-risk assessment mechanisms

• structured incident readiness and response frameworks

• formal vulnerability disclosure policies

For businesses, this means:

✔ stronger supervisory expectations
✔ measurable cyber-maturity requirements
✔ increased audit exposure
✔ higher liability for inadequate governance

Cybersecurity is now clearly positioned as a corporate governance duty, not an IT function.

The Hellenic Cybersecurity Authority Self-Assessment Tool: A New Compliance Benchmark

The introduction of the national web-based cybersecurity maturity self-assessment tool marks a decisive shift toward quantifiable compliance.

With 234 structured control questions, it effectively creates a de facto national baseline for due diligence.

Why this matters for companies

This tool will be used to assess:

• governance structures

• risk management mechanisms

• asset inventory controls

• system configuration security

• operational resilience

In practice, it will:

• shape supervisory audits

• influence liability assessments

• affect procurement eligibility

• become a reference in M&A due diligence

Companies that treat this as a voluntary exercise will be exposed.
Companies that integrate it into their governance framework will gain a competitive advantage.

Whistleblowing and Financial Sector Compliance: The Bank of Greece Framework

The establishment of a formal external reporting channel by the Bank of Greece under the EU Whistleblowing Directive significantly strengthens:

• regulatory enforcement

• internal accountability

• personal liability for executives

The framework provides:

• strict confidentiality safeguards

• protected reporting mechanisms

• structured investigation procedures

For credit institutions and regulated entities, this creates a new litigation and enforcement risk environment, particularly in:

• prudential supervision

• governance failures

• compliance breakdowns

• internal control deficiencies

Whistleblowing systems are now a mandatory risk-management tool, not a formal policy.

The EU Digital Omnibus Regulation: A Radical Simplification — and a Hidden Compliance Shock

The proposed Digital Omnibus Regulation will reshape the architecture of EU digital law by:

• amending the GDPR

• updating the AI Act

• consolidating the Data Act & Data Governance Act

Strategic implications

This is not merely simplification.

It will require:

• redesign of existing compliance programmes

• reassessment of AI governance frameworks

• restructuring of data-sharing models

• review of contractual ecosystems

Companies that invested early in compliance will need to re-calibrate.
Companies that delayed will face accelerated regulatory pressure.

This is a once-in-a-decade regulatory reset.

The New EU Cybersecurity Act: Certification, Supply Chains & Market Access

The forthcoming replacement of the 2019 Cybersecurity Act introduces:

• strengthened ENISA powers

• faster EU certification mechanisms

• alignment with NIS2 and the Cyber Resilience Act

• EU-wide ICT supply-chain risk control

Business impact

Cybersecurity certification will increasingly function as:

• a market access requirement

• a public procurement condition

• a contractual obligation

• an M&A valuation factor

Cyber-posture will become a commercial differentiator.

Landmark CJEU Ruling: Online Platforms as Joint Controllers

The Russmedia judgment (C-492/23) fundamentally lowers the threshold for becoming a GDPR data controller.

Online platforms must now:

• proactively screen content for sensitive data

• verify lawful processing bases

• demonstrate systemic GDPR compliance

This expands liability for:

• marketplaces

• platforms

• digital intermediaries

• advertising ecosystems

It signals a transition from reactive to preventive compliance.

What This Means for Corporate Leadership

The new framework transforms cybersecurity and data protection into:

A board-level governance obligation

A core M&A due-diligence parameter

A source of director liability

A competitive advantage for compliant organisations

Companies must move from: formal compliance → operational resilience → strategic digital governance

How Tsamichas Law Firm Supports Clients

Our approach combines:

• regulatory interpretation

• corporate governance integration

• sector-specific compliance architecture

• litigation and enforcement readiness

We advise on:

✔ NIS2 & DORA implementation
✔ GDPR & AI governance
✔ cyber-incident liability exposure
✔ digital regulatory strategy
✔ M&A cyber due diligence
✔ whistleblowing frameworks
✔ cross-border data flows

Why Early Action Creates Competitive Advantage

In the new EU digital economy:

• compliance reduces financing costs

• certification increases market access

• resilience strengthens valuation

• governance protects management

Cybersecurity is no longer a defensive exercise. It is a growth, investment and trust strategy.

From Regulatory Burden to Strategic Asset

The current wave of EU and Greek digital regulation is not simply about stricter rules. It marks the emergence of a new model: digitally secure companies will dominate the European market.

Those that act early will:

• attract investors

• win public contracts

• scale cross-border

• avoid enforcement exposure

Those that delay will face:

• regulatory sanctions

• contractual exclusion

• reputational damage

• reduced enterprise value