EU AI Act & AI Governance Toolkit — curated by Devseis
Collection
AI Act, GDPR/PII and LLM-security resources curated by Devseis, a Luxembourg AI governance & cybersecurity consultancy. Not legal advice. • 13 items • Updated
Datasets:
regulation stringclasses 3
values | category stringlengths 7 26 | entity_or_product_type stringlengths 5 258 | scope_note stringclasses 10
values | legal_basis stringclasses 10
values | supervisory_authority_note stringclasses 10
values |
|---|---|---|---|---|---|
NIS2 | essential_entity_sector | Energy (electricity, district heating/cooling, oil, gas, hydrogen) | Annex I sector. Generally an 'essential entity' if large (250+ staff or >50M EUR turnover/43M EUR balance sheet); some sub-types (qualified trust service providers, TLD registries, DNS providers) are in scope regardless of size. | Directive (EU) 2022/2555, Annex I | Luxembourg: ILR is the national competent/supervisory authority (per Devseis's understanding of the national transposition -- verify current text, see note below). |
NIS2 | essential_entity_sector | Transport (air, rail, water, road) | Annex I sector. Generally an 'essential entity' if large (250+ staff or >50M EUR turnover/43M EUR balance sheet); some sub-types (qualified trust service providers, TLD registries, DNS providers) are in scope regardless of size. | Directive (EU) 2022/2555, Annex I | Luxembourg: ILR is the national competent/supervisory authority (per Devseis's understanding of the national transposition -- verify current text, see note below). |
NIS2 | essential_entity_sector | Banking | Annex I sector. Generally an 'essential entity' if large (250+ staff or >50M EUR turnover/43M EUR balance sheet); some sub-types (qualified trust service providers, TLD registries, DNS providers) are in scope regardless of size. | Directive (EU) 2022/2555, Annex I | Luxembourg: ILR is the national competent/supervisory authority (per Devseis's understanding of the national transposition -- verify current text, see note below). |
NIS2 | essential_entity_sector | Financial market infrastructures | Annex I sector. Generally an 'essential entity' if large (250+ staff or >50M EUR turnover/43M EUR balance sheet); some sub-types (qualified trust service providers, TLD registries, DNS providers) are in scope regardless of size. | Directive (EU) 2022/2555, Annex I | Luxembourg: ILR is the national competent/supervisory authority (per Devseis's understanding of the national transposition -- verify current text, see note below). |
NIS2 | essential_entity_sector | Health (care providers, EU reference labs, pharma R&D/manufacture) | Annex I sector. Generally an 'essential entity' if large (250+ staff or >50M EUR turnover/43M EUR balance sheet); some sub-types (qualified trust service providers, TLD registries, DNS providers) are in scope regardless of size. | Directive (EU) 2022/2555, Annex I | Luxembourg: ILR is the national competent/supervisory authority (per Devseis's understanding of the national transposition -- verify current text, see note below). |
NIS2 | essential_entity_sector | Drinking water | Annex I sector. Generally an 'essential entity' if large (250+ staff or >50M EUR turnover/43M EUR balance sheet); some sub-types (qualified trust service providers, TLD registries, DNS providers) are in scope regardless of size. | Directive (EU) 2022/2555, Annex I | Luxembourg: ILR is the national competent/supervisory authority (per Devseis's understanding of the national transposition -- verify current text, see note below). |
NIS2 | essential_entity_sector | Waste water | Annex I sector. Generally an 'essential entity' if large (250+ staff or >50M EUR turnover/43M EUR balance sheet); some sub-types (qualified trust service providers, TLD registries, DNS providers) are in scope regardless of size. | Directive (EU) 2022/2555, Annex I | Luxembourg: ILR is the national competent/supervisory authority (per Devseis's understanding of the national transposition -- verify current text, see note below). |
NIS2 | essential_entity_sector | Digital infrastructure (IXPs, DNS/TLD, cloud, data centres, CDNs, trust services, public e-comms) | Annex I sector. Generally an 'essential entity' if large (250+ staff or >50M EUR turnover/43M EUR balance sheet); some sub-types (qualified trust service providers, TLD registries, DNS providers) are in scope regardless of size. | Directive (EU) 2022/2555, Annex I | Luxembourg: ILR is the national competent/supervisory authority (per Devseis's understanding of the national transposition -- verify current text, see note below). |
NIS2 | essential_entity_sector | ICT service management (managed service & managed security service providers) | Annex I sector. Generally an 'essential entity' if large (250+ staff or >50M EUR turnover/43M EUR balance sheet); some sub-types (qualified trust service providers, TLD registries, DNS providers) are in scope regardless of size. | Directive (EU) 2022/2555, Annex I | Luxembourg: ILR is the national competent/supervisory authority (per Devseis's understanding of the national transposition -- verify current text, see note below). |
NIS2 | essential_entity_sector | Public administration (central government; regional at Member State discretion) | Annex I sector. Generally an 'essential entity' if large (250+ staff or >50M EUR turnover/43M EUR balance sheet); some sub-types (qualified trust service providers, TLD registries, DNS providers) are in scope regardless of size. | Directive (EU) 2022/2555, Annex I | Luxembourg: ILR is the national competent/supervisory authority (per Devseis's understanding of the national transposition -- verify current text, see note below). |
NIS2 | essential_entity_sector | Space | Annex I sector. Generally an 'essential entity' if large (250+ staff or >50M EUR turnover/43M EUR balance sheet); some sub-types (qualified trust service providers, TLD registries, DNS providers) are in scope regardless of size. | Directive (EU) 2022/2555, Annex I | Luxembourg: ILR is the national competent/supervisory authority (per Devseis's understanding of the national transposition -- verify current text, see note below). |
NIS2 | important_entity_sector | Postal and courier services | Annex II sector. Generally an 'important entity' if at least medium-sized (50+ staff or >10M EUR turnover/balance sheet). | Directive (EU) 2022/2555, Annex II | Luxembourg: ILR (verify current text, see note below). |
NIS2 | important_entity_sector | Waste management | Annex II sector. Generally an 'important entity' if at least medium-sized (50+ staff or >10M EUR turnover/balance sheet). | Directive (EU) 2022/2555, Annex II | Luxembourg: ILR (verify current text, see note below). |
NIS2 | important_entity_sector | Manufacture, production and distribution of chemicals | Annex II sector. Generally an 'important entity' if at least medium-sized (50+ staff or >10M EUR turnover/balance sheet). | Directive (EU) 2022/2555, Annex II | Luxembourg: ILR (verify current text, see note below). |
NIS2 | important_entity_sector | Production, processing and distribution of food | Annex II sector. Generally an 'important entity' if at least medium-sized (50+ staff or >10M EUR turnover/balance sheet). | Directive (EU) 2022/2555, Annex II | Luxembourg: ILR (verify current text, see note below). |
NIS2 | important_entity_sector | Manufacturing (medical devices, electronics, electrical equipment, machinery, motor vehicles, other transport equipment) | Annex II sector. Generally an 'important entity' if at least medium-sized (50+ staff or >10M EUR turnover/balance sheet). | Directive (EU) 2022/2555, Annex II | Luxembourg: ILR (verify current text, see note below). |
NIS2 | important_entity_sector | Digital providers (online marketplaces, online search engines, social networking platforms) | Annex II sector. Generally an 'important entity' if at least medium-sized (50+ staff or >10M EUR turnover/balance sheet). | Directive (EU) 2022/2555, Annex II | Luxembourg: ILR (verify current text, see note below). |
NIS2 | important_entity_sector | Research organisations | Annex II sector. Generally an 'important entity' if at least medium-sized (50+ staff or >10M EUR turnover/balance sheet). | Directive (EU) 2022/2555, Annex II | Luxembourg: ILR (verify current text, see note below). |
NIS2 | size_threshold_rule | General size-cap rule (both Annexes) | Micro and small enterprises (<50 staff AND <=10M EUR turnover/balance sheet) are generally OUT of scope, subject to named size-independent exceptions. | Art. 2 | Applies EU-wide; Member States can extend scope nationally. |
NIS2 | size_independent_exception | Sole provider of a service in a Member State; entity whose disruption could have significant public-safety/health impact; entity identified as critical by a Member State; public administration; qualified trust service providers, TLD registries, DNS providers | In scope REGARDLESS of size. | Art. 2(2)-(4) | Case-by-case; check Member State's own critical-entity designations. |
DORA | financial_entity | Credit institutions | In scope as a 'financial entity' under DORA's ICT risk-management, incident-reporting, resilience-testing and third-party-risk rules. A simplified regime exists for some small/non-interconnected entities. | Regulation (EU) 2022/2554, Art. 2 | Luxembourg: CSSF supervises financial entities; CSSF also directly oversees 'critical' ICT third-party providers designated at EU level. |
DORA | financial_entity | Payment institutions (incl. exempt under PSD2 Art. 32) | In scope as a 'financial entity' under DORA's ICT risk-management, incident-reporting, resilience-testing and third-party-risk rules. A simplified regime exists for some small/non-interconnected entities. | Regulation (EU) 2022/2554, Art. 2 | Luxembourg: CSSF supervises financial entities; CSSF also directly oversees 'critical' ICT third-party providers designated at EU level. |
DORA | financial_entity | Electronic money institutions | In scope as a 'financial entity' under DORA's ICT risk-management, incident-reporting, resilience-testing and third-party-risk rules. A simplified regime exists for some small/non-interconnected entities. | Regulation (EU) 2022/2554, Art. 2 | Luxembourg: CSSF supervises financial entities; CSSF also directly oversees 'critical' ICT third-party providers designated at EU level. |
DORA | financial_entity | Investment firms | In scope as a 'financial entity' under DORA's ICT risk-management, incident-reporting, resilience-testing and third-party-risk rules. A simplified regime exists for some small/non-interconnected entities. | Regulation (EU) 2022/2554, Art. 2 | Luxembourg: CSSF supervises financial entities; CSSF also directly oversees 'critical' ICT third-party providers designated at EU level. |
DORA | financial_entity | Crypto-asset service providers & issuers of asset-referenced tokens | In scope as a 'financial entity' under DORA's ICT risk-management, incident-reporting, resilience-testing and third-party-risk rules. A simplified regime exists for some small/non-interconnected entities. | Regulation (EU) 2022/2554, Art. 2 | Luxembourg: CSSF supervises financial entities; CSSF also directly oversees 'critical' ICT third-party providers designated at EU level. |
DORA | financial_entity | Central securities depositories | In scope as a 'financial entity' under DORA's ICT risk-management, incident-reporting, resilience-testing and third-party-risk rules. A simplified regime exists for some small/non-interconnected entities. | Regulation (EU) 2022/2554, Art. 2 | Luxembourg: CSSF supervises financial entities; CSSF also directly oversees 'critical' ICT third-party providers designated at EU level. |
DORA | financial_entity | Central counterparties | In scope as a 'financial entity' under DORA's ICT risk-management, incident-reporting, resilience-testing and third-party-risk rules. A simplified regime exists for some small/non-interconnected entities. | Regulation (EU) 2022/2554, Art. 2 | Luxembourg: CSSF supervises financial entities; CSSF also directly oversees 'critical' ICT third-party providers designated at EU level. |
DORA | financial_entity | Trading venues | In scope as a 'financial entity' under DORA's ICT risk-management, incident-reporting, resilience-testing and third-party-risk rules. A simplified regime exists for some small/non-interconnected entities. | Regulation (EU) 2022/2554, Art. 2 | Luxembourg: CSSF supervises financial entities; CSSF also directly oversees 'critical' ICT third-party providers designated at EU level. |
DORA | financial_entity | Trade repositories | In scope as a 'financial entity' under DORA's ICT risk-management, incident-reporting, resilience-testing and third-party-risk rules. A simplified regime exists for some small/non-interconnected entities. | Regulation (EU) 2022/2554, Art. 2 | Luxembourg: CSSF supervises financial entities; CSSF also directly oversees 'critical' ICT third-party providers designated at EU level. |
DORA | financial_entity | Managers of alternative investment funds | In scope as a 'financial entity' under DORA's ICT risk-management, incident-reporting, resilience-testing and third-party-risk rules. A simplified regime exists for some small/non-interconnected entities. | Regulation (EU) 2022/2554, Art. 2 | Luxembourg: CSSF supervises financial entities; CSSF also directly oversees 'critical' ICT third-party providers designated at EU level. |
DORA | financial_entity | Management companies (UCITS) | In scope as a 'financial entity' under DORA's ICT risk-management, incident-reporting, resilience-testing and third-party-risk rules. A simplified regime exists for some small/non-interconnected entities. | Regulation (EU) 2022/2554, Art. 2 | Luxembourg: CSSF supervises financial entities; CSSF also directly oversees 'critical' ICT third-party providers designated at EU level. |
DORA | financial_entity | Data reporting service providers | In scope as a 'financial entity' under DORA's ICT risk-management, incident-reporting, resilience-testing and third-party-risk rules. A simplified regime exists for some small/non-interconnected entities. | Regulation (EU) 2022/2554, Art. 2 | Luxembourg: CSSF supervises financial entities; CSSF also directly oversees 'critical' ICT third-party providers designated at EU level. |
DORA | financial_entity | Insurance and reinsurance undertakings | In scope as a 'financial entity' under DORA's ICT risk-management, incident-reporting, resilience-testing and third-party-risk rules. A simplified regime exists for some small/non-interconnected entities. | Regulation (EU) 2022/2554, Art. 2 | Luxembourg: CSSF supervises financial entities; CSSF also directly oversees 'critical' ICT third-party providers designated at EU level. |
DORA | financial_entity | Insurance intermediaries, reinsurance intermediaries, ancillary insurance intermediaries | In scope as a 'financial entity' under DORA's ICT risk-management, incident-reporting, resilience-testing and third-party-risk rules. A simplified regime exists for some small/non-interconnected entities. | Regulation (EU) 2022/2554, Art. 2 | Luxembourg: CSSF supervises financial entities; CSSF also directly oversees 'critical' ICT third-party providers designated at EU level. |
DORA | financial_entity | Institutions for occupational retirement provision | In scope as a 'financial entity' under DORA's ICT risk-management, incident-reporting, resilience-testing and third-party-risk rules. A simplified regime exists for some small/non-interconnected entities. | Regulation (EU) 2022/2554, Art. 2 | Luxembourg: CSSF supervises financial entities; CSSF also directly oversees 'critical' ICT third-party providers designated at EU level. |
DORA | financial_entity | Credit rating agencies | In scope as a 'financial entity' under DORA's ICT risk-management, incident-reporting, resilience-testing and third-party-risk rules. A simplified regime exists for some small/non-interconnected entities. | Regulation (EU) 2022/2554, Art. 2 | Luxembourg: CSSF supervises financial entities; CSSF also directly oversees 'critical' ICT third-party providers designated at EU level. |
DORA | financial_entity | Administrators of critical benchmarks | In scope as a 'financial entity' under DORA's ICT risk-management, incident-reporting, resilience-testing and third-party-risk rules. A simplified regime exists for some small/non-interconnected entities. | Regulation (EU) 2022/2554, Art. 2 | Luxembourg: CSSF supervises financial entities; CSSF also directly oversees 'critical' ICT third-party providers designated at EU level. |
DORA | financial_entity | Crowdfunding service providers | In scope as a 'financial entity' under DORA's ICT risk-management, incident-reporting, resilience-testing and third-party-risk rules. A simplified regime exists for some small/non-interconnected entities. | Regulation (EU) 2022/2554, Art. 2 | Luxembourg: CSSF supervises financial entities; CSSF also directly oversees 'critical' ICT third-party providers designated at EU level. |
DORA | financial_entity | Securitisation repositories | In scope as a 'financial entity' under DORA's ICT risk-management, incident-reporting, resilience-testing and third-party-risk rules. A simplified regime exists for some small/non-interconnected entities. | Regulation (EU) 2022/2554, Art. 2 | Luxembourg: CSSF supervises financial entities; CSSF also directly oversees 'critical' ICT third-party providers designated at EU level. |
DORA | ict_third_party_provider | ICT third-party service provider to a financial entity (e.g. cloud, SaaS, hosting, data analytics) | In scope indirectly: financial-entity clients must risk-manage the relationship (contracts, exit strategy, concentration risk). If designated 'critical' by the European Supervisory Authorities, the provider is directly overseen. | Art. 28-44 | Critical ICT third-party providers: direct EU-level oversight (Lead Overseer); in Luxembourg, CSSF is the relevant national authority for coordination. |
CRA | default | Any product with digital elements with a direct or indirect data/network connection to a device or network (most consumer & general-purpose hardware/software) | Manufacturers must meet essential cybersecurity requirements (Annex I), provide security updates for the support period, and (for important/critical) may need third-party conformity assessment rather than self-assessment. | Regulation (EU) 2024/2847, Art. 6-8 & Annexes | CE marking required; national market surveillance authority enforces. |
CRA | important_class_i | Products such as identity/access management software, browsers, password managers, network management software, SIEM systems, boot managers, VPNs (lower-risk 'important' tier) | Manufacturers must meet essential cybersecurity requirements (Annex I), provide security updates for the support period, and (for important/critical) may need third-party conformity assessment rather than self-assessment. | Regulation (EU) 2024/2847, Art. 6-8 & Annexes | CE marking required; national market surveillance authority enforces. |
CRA | important_class_ii | Products such as firewalls, intrusion detection/prevention systems, tamper-resistant microprocessors, smart-card readers (higher-risk 'important' tier) | Manufacturers must meet essential cybersecurity requirements (Annex I), provide security updates for the support period, and (for important/critical) may need third-party conformity assessment rather than self-assessment. | Regulation (EU) 2024/2847, Art. 6-8 & Annexes | CE marking required; national market surveillance authority enforces. |
CRA | critical | Products such as hardware security modules, smart meter gateways, smartcards/secure elements used for critical infrastructure (subject to third-party conformity assessment) | Manufacturers must meet essential cybersecurity requirements (Annex I), provide security updates for the support period, and (for important/critical) may need third-party conformity assessment rather than self-assessment. | Regulation (EU) 2024/2847, Art. 6-8 & Annexes | CE marking required; national market surveillance authority enforces. |
CRA | exclusion | SaaS (unless it is a remote data-processing solution that is part of a product's essential digital functions) | Generally OUT of scope of the CRA itself -- but SaaS vendors should still check whether the underlying product they operate is in scope, and note GDPR/NIS2/DORA may apply separately. | Recital / Art. 3 scope discussion | Verify against current guidance -- SaaS/CRA boundary has been a point of ongoing clarification. |
CRA | exclusion | Open-source software NOT supplied in the course of a commercial activity | Generally OUT of scope, though a 'steward' of widely-used open-source software can have lighter-touch obligations if it is commercially exploited by others. | Art. 3, Recitals on open source | Case-by-case -- depends on funding model and commercial exploitation. |
CRA | exclusion | Products already regulated under sector-specific EU law (medical devices, aviation, motor vehicles, marine equipment) | OUT of scope of CRA to avoid duplicating existing sectoral cybersecurity/safety regimes. | Art. 2(6)-(9) | Confirm which sectoral regime applies instead. |
NIS2 / DORA / CRA Applicability Reference
A structured reference table for determining which of the EU's three major cybersecurity regulations — NIS2 (Directive (EU) 2022/2555), DORA (Regulation (EU) 2022/2554), and the Cyber Resilience Act (Regulation (EU) 2024/2847) — applies to an organisation or product, based on sector, entity type, or product category.
Compiled by Devseis, a Luxembourg cybersecurity, data protection and AI governance consultancy, from the regulations' own text (NIS2 Annexes I/II and Article 2, DORA Article 2 and Articles 28-44, CRA Articles 2-8 and Annexes).
⚠️ Not legal advice — two specific caveats
- General reference only. Applicability depends on exact entity size, activities, and Member State transposition — always verify against the current consolidated text for your specific situation.
- Luxembourg-specific notes are unverified. Rows referencing the Luxembourg NIS2 transposition law (dated 5 May 2026) and ILR/CSSF supervisory roles were not independently re-verified against the current text at time of writing — confirm directly with ILR (nis2.lu) / CSSF before relying on them.
Columns
| Column | Description |
|---|---|
regulation |
NIS2 / DORA / CRA |
category |
Sector/entity/product classification within that regulation |
entity_or_product_type |
The specific type covered |
scope_note |
Applicability conditions (size thresholds, exceptions) |
legal_basis |
Article/Annex citation |
supervisory_authority_note |
Relevant regulator, where known |
License
CC-BY-4.0 — compiled from public regulatory text.
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