Why Qfirst’s RISK 3D Assessment is Critical to Secure AI Deployments Under NIS2 and in alignment with the EU AI Act
The AI Gold Rush Meets Cyber Risk
In early 2026, NeuroLink BE Systems, a mid-sized ICT service provider classified as an essential entity under NIS2, was riding high. It supported critical infrastructure clients across the financial sector, including several entities under DORA regulation. To accelerate client support, it quietly introduced a generative AI model into its ticketing and knowledge retrieval systems—without a formal AI policy, oversight, or usage registration.
What began as an internal time-saver quickly spiraled into a compliance nightmare.
An AI-generated suggestion pulled incomplete historical data during a client’s DORA audit prep, advising a misaligned configuration. Worse, there was no audit log of who queried the system, why it was consulted, or what model version was used. The financial entity flagged the anomaly, triggering an external review.
The findings were clear:
- No AI governance policy or approved usage thresholds
- No purpose limitation, transparency, or explainability records
- No user access logs or query intent registration
The incident violated key clauses of NIS2 (Articles 21 & 23) and compromised DORA’s ICT third-party risk expectations. Within weeks, NeuroLink lost its NIS2 compliance certification and faced scrutiny from multiple competent authorities.
As AI systems revolutionize business and public services, organizations across Europe face a dual challenge: embracing innovation while managing risk. Without clear guardrails, AI can introduce systemic vulnerabilities, bias, and compliance breaches. The NIS2 Directive and EU AI Act now mandate strict controls to prevent such pitfalls.
Enter Qfirst’s RISK 3D Assessment: a comprehensive methodology designed to safeguard organizations from the uncharted risks of AI while ensuring full alignment with regulatory obligations.
What is QFIRST RISK 3D?
Qfirst’s RISK 3D Assessment tackles three interconnected layers of risk:
- Digital Infrastructure Risk: Identifies cybersecurity threats from AI misuse, adversarial input, or model vulnerabilities.
- Data Ethics & Governance Risk: Examines data lineage, training transparency, and fairness.
- Directive & Regulatory Risk: Aligns AI use with NIS2, GDPR, DORA, and the AI Act to ensure lawful, explainable, and auditable deployments.
Without such a framework, AI integration often becomes a blind gamble with legal and reputational stakes.
Why AI Without RISK 3D Is Dangerous
Deploying AI without a structured risk methodology can lead to:
- Violations of NIS2 Article 21 (Risk management & incident response)
- Breaches of the EU AI Act, especially for high-risk use cases
- Unchecked bias, hallucinations, or model drift
- Non-compliance with GDPR’s transparency and data minimization obligations
- Reputational fallout from ethical lapses or system failure
In other words: no risk assessment = high-risk exposure.
The 10 DOs and DON’Ts of AI Policy Design
To ensure AI use is safe, ethical, and compliant, Qfirst recommends integrating these best practices into your organizational AI policy:
Top 10 DOs (Compliant & Proactive)
- Conduct RISK 3D assessment prior to development or deployment
- Classify AI systems based on the EU AI Act risk tiers
- Ensure human oversight for critical decisions
- Document explainability mechanisms (per Article 13)
- Audit training data for bias and legality
- Continuously monitor performance and drift post-deployment
- Establish an AI Risk Committee for governance
- Design cybersecurity-by-default into AI pipelines
- Maintain detailed logs and technical documentation
- Train employees on AI risks and compliance duties
Top 10 DON’Ts (Risky & Non-Compliant)
- Don’t deploy AI without a risk review and legal mapping
- Don’t use opaque models in regulated decision-making
- Don’t assume vendors carry your compliance risk
- Don’t bypass human validation in high-risk use cases
- Don’t neglect GDPR principles in AI data processing
- Don’t use generative AI in operations without policy controls
- Don’t allow silent updates without logging or rollback
- Don’t treat pilots or sandboxes as risk-free zones
- Don’t skip stakeholder communication or user warnings
- Don’t see AI governance as a one-time project
Here is a short sample RISK 3D Assessment using Qfirst’s framework, integrating CIA (Confidentiality, Integrity, Availability) impact ratings, likelihood, occurrence in the past 12 months, and a mitigation and control proposal aligned with NIS2, the EU AI Act, and DORA principles.
Sample RISK 3D Assessment – AI Use Case: Customer Support Chatbot with Generative AI
| Risk Dimension | Description |
|---|---|
| Digital Infrastructure Risk | AI model exposes internal logs or configurations through unfiltered responses. |
| Data Ethics & Governance Risk | No transparency on training dataset origin; risk of bias or outdated knowledge. |
| Directive & Regulatory Risk | No record of who queried AI, when, or for what purpose (GDPR + AI Act breach). |
Risk Analysis Table
| Risk Category | CIA Impact | Likelihood | Occurred in Past 12 Months? | Risk Level |
|---|---|---|---|---|
| Confidential Information Leak | C = High, I = Med, A = Low | Likely | Yes – 1 incident (Apr 2025) | High |
| Bias in AI Output | C = Low, I = High, A = Low | Possible | No | Medium |
| Non-compliance (NIS2/AI Act) | C = Med, I = Med, A = High | Likely | Yes – flagged in DORA audit | High |
Proposed Mitigations & Controls
| Risk | Mitigation & Controls Proposal |
|---|---|
| Confidential Information Leak | – Implement input/output filtering layer – Train AI on sanitized knowledge base only – Apply Role-Based Access Control (RBAC) to AI interface |
| Bias in AI Output | – Conduct bias testing pre-deployment – Ensure human-in-the-loop (HITL) validation – Publish model limitations to users |
| Lack of AI Auditability (NIS2/GDPR/AI Act) | – Establish an AI usage registry logging user, query, time, and purpose – Add Purpose Limitation prompts at the start of each query – Implement monthly AI governance reviews |
Think first: AI Governance is Now a Strategic Imperative
With NIS2 and the EU AI Act now enforceable, organizations can no longer afford to experiment with AI without proper oversight. Qfirst’s RISK 3D Assessment equips you to confidently deploy AI that is secure, explainable, auditable, and lawful.
Need help from Qfirst to develop a NIS2 proof setup – call the Qfirst experts
