Compliance Is Not a Security Strategy

A Reality Check for EU RegTech & Payment Companies

The European financial ecosystem - especially RegTech providers and payment institutions - lives under constant regulatory scrutiny. Between PSD2, DORA, NIS2 Directive, GDPR and PCI DSS, security is rarely ignored. Controls are mapped. Documentation is structured. Audit trails are maintained. Reports are submitted.

On paper, everything looks robust.

But here is the uncomfortable truth: Passing regulation does not mean you are protected. Compliance is mandatory but security is strategic. And confusing the two creates blind spots.

Regulation Sets the Floor. Attackers Aim for the Ceiling.

Regulatory frameworks define minimum expectations: governance models, risk registers, incident reporting timelines, outsourcing oversight, data protection safeguards. They enforce discipline and accountability, and that matters.

But attackers do not operate at the minimum threshold.

They look for architectural weaknesses, misconfigurations, excessive privileges, exposed APIs, unmonitored integrations and delays in correlation between systems. They exploit complexity. And modern payment ecosystems are complex by design.

You can satisfy every regulatory requirement and still lack real-time visibility across your environment. That gap - between formal compliance and operational awareness -  is where breaches happen.

DORA Changed the Tone - But Not the Reality

With DORA, the European Union made something explicit: financial institutions must demonstrate operational capability, not just documented readiness. Continuous monitoring, threat-led testing, strict incident timelines and third-party ICT risk oversight are no longer optional enhancements; they are structural expectations.

Yet even with DORA in force, many organizations still approach cybersecurity as a control-mapping exercise rather than an architectural discipline.

Security is not a document, it is a system. DORA does not replace compliance, it elevates it.

Book Dora Gap Analysis

What Comes After Compliance?

Compliance defines the baseline. It structures governance, aligns controls and ensures regulatory accountability. But once that baseline is in place, a more complex question emerges.

If compliance is not a security strategy, what is?

In regulated payment environments, the real vulnerability rarely comes from missing policies. It comes from disconnected systems, siloed controls and fragmented visibility. Because even when every requirement is documented, security can still fail quietly  inside the gaps between tools.

In our next article, we examine the structural risk that many RegTech and payment institutions overlook: fragmentation, and why integration, not accumulation, is what ultimately determines operational strength.

Read the next article: Your Biggest Risk Isn’t Compliance. It’s Fragmentation.