2026 won’t invent new threats. It’ll just start auditing the ones we already have.

If you’re a CISO or cloud security architect with dealings in Europe, 2026 is when a bunch of “sensible principles” become uncomfortable questions. Not “Do you have a policy?” but “Who had access, when, and why did it make sense at the time?”

This isn’t because regulators suddenly became cloud engineers. It’s because they’ve realized the same thing we have: most modern incidents aren’t defeated by better slide decks. They’re beaten by removing unnecessary access (and proving you did).

EU cyber regulation draws a much clearer line around who is accountable and why. The scope now extends well beyond traditional critical infrastructure to include software and SaaS providers, cloud and digital infrastructure operators, managed service providers, and key suppliers embedded in regulated supply chains. Whether through the Cyber Resilience Act, NIS2, CER, DORA, or the EU Data Act, regulators are responding to the same systemic failure: breaches are rarely caused by missing policies, but by excessive, persistent, and poorly governed access. As a result, organizations are expected to prove that privileged access is granted only when needed, tightly scoped, continuously monitored, and automatically revoked. In short, if your business builds, operates, or supports digital services in the EU, regulators now care less about what you intend to control and far more about what access actually exists at any given moment.

The 2026 EU Cyber Regulation Pressure Points
1) The Cyber Resilience Act: 24 hours to report.

From 11 September 2026, manufacturers must report actively exploited vulnerabilities and severe incidents affecting products with digital elements. The EU’s own CRA guidance sets tight timelines: early warning within 24 hours, fuller notification within 72 hours, plus follow-ups.  

Whether you build software, ship devices, or sell “digital elements” as part of a wider offer, this changes the tempo of response. Fast reporting is hard if:

  • Your incident responders need to beg for access
  • Your engineers have broad admin “just in case”
  • You can’t show who touched what during the first frantic hours

CRA doesn’t explicitly name just-in-time access, but it forces an operational reality in which pre-approved, time-limited, audited access becomes the only sane way to move quickly without creating a secondary breach while responding to the first.

2) CER Directive: governments will designate critical entities, and then the bar rises.

Under the Critical Entities Resilience (CER) Directive, Member States must complete national risk assessments by 17 January 2026, and begin designating critical entities by 17 July 2026.  

If your organization sits anywhere near critical infrastructure (directly, or as an ICT supplier), the impact is predictable: once you’re “critical”, tolerance for loose access collapses. Expect scrutiny of:

  • Privileged access paths (cloud consoles, identity providers, CI/CD, endpoint admin)
  • Supplier and MSP access (especially persistent accounts and shared credentials)
  • Emergency access (“breakglass”) that hasn’t been tested since the last auditor was born
3) NIS2: access control becomes a measurable risk-management control, not a “best effort.”

NIS2 is the umbrella that drags cyber risk management into board accountability across many sectors. In practice, the controls regulators and national authorities keep leaning on are the ones you can demonstrate.

Ireland’s NCSC draft guidance for NIS2 risk management measures is explicit about controlling and monitoring privileged access, and assigning/revoking access based on need-to-know, least privilege, and separation of duties. In 2026, you don’t want to be arguing that your access sprawl is “compensated by awareness training”.

4) DORA + the EU Data Act: access expands, so access control has to mature

DORA has been applied since 17 January 2025 and keeps tightening expectations in financial services and their ICT supply chains.  

Meanwhile, the EU Data Act has been in force since September 2025 (so 2026 is where it becomes “normal business”), and it encourages more structured data sharing and portability.  

Both trends increase the number of legitimate access scenarios. More sharing, more vendors, more integrations, more workflows. If you don’t modernise access control, you’ll “solve” it the traditional way: permanent roles, shared accounts, and manual exceptions, which is… brave.

What “Better Access Control” Looks Like in 2026

Here’s the practical target state regulators are nudging everyone toward, whether they say it outright or not:

1) Zero Standing Privilege for the spicy stuff

Your riskiest permissions should not exist indefinitely. Admin access, production access, high-impact cloud privileges: make them requested, approved, time-bound, and automatically revoked.

2) Just-in-Time elevation with a tight scope

Not “here’s the Admin role for two hours”, but “here’s exactly the actions you need on exactly the resources you need, for exactly the time window you need.” In cloud terms: temporary, least-privilege policies minted to fit the job, not the other way around

3) Evidence is a Product, not a by-product

Auditors and regulators don’t want vibes. They want:

  • Who requested access
  • Who approved it (and on what basis)
  • When it started and ended
  • Proof it was removed, and the exception didn’t become permanent

If you can produce that on demand, the tone of every compliance conversation changes.

4) Third-party Access is treated like production code

Vendors, MSPs, contractors: give them the same JIT discipline you expect internally. No shared accounts. No permanent admin “for support”. No orphaned accounts that outlive the contract.

The platform pattern that makes this survivable (without hiring 12 more people).

To make the above real in multi-cloud, most teams end up adopting a cloud identity security platform that does four things well:

  1. Entitlement visibility across AWS/Azure/GCP and key SaaS

So you can answer “who can do what” without archaeology.

  1. JIT access workflows with approvals

Including self-service requests, policy-based auto-approval for low-risk access, and “two pairs of eyes” for high-risk access—ideally integrated into Slack/Teams so humans actually use it.

  1. Automated revocation and lifecycle hygiene

So, joiner/mover/leaver isn’t your only line of defense, and “temporary” doesn’t become a permanent role with delusions of grandeur.

  1. Privileged activity evidence

Session logs, decision trails, and reporting that turns access control into audit artifacts, not late-night spreadsheet therapy.

The Punchline

2026 isn’t a single deadline. It’s a shift in how Europe expects organizations to manage cyber risk: less trust in permanent privilege, more insistence on provable control.

If you treat access as an operational control (with JIT, tight scope, automated revocation, and audit-grade evidence), you’re not just “more compliant”. You’re harder to breach and faster to respond when something goes sideways.

And yes, you’ll still need policies. But in 2026, policies are just the opening act. The headline reads: "Show me the access receipts."

Nik Hewitt

Technology

January 5, 2026

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