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· 6 min read

ISO 27001, GDPR, NIS2, DORA, KVKK: the case for one system, not five

If your organization sells into the EU and operates in or from Türkiye, you are very likely managing compliance for at least four regimes at once: ISO 27001 for information security, GDPR for EU personal data, and — depending on your sector — NIS2 (cybersecurity obligations for essential and important entities, in force since October 2024) and DORA (digital operational resilience for EU financial entities and their ICT providers, in force since January 2025). On top of that sits KVKK, Türkiye's own data protection law, which applies independently of GDPR the moment you process the personal data of people in Türkiye.

Most organizations we've talked to handle this by running separate tracks for each regime: a KVKK consultant, a GDPR DPA review, an ISO 27001 auditor, and — increasingly — a NIS2 or DORA readiness project bolted on top. Each track has its own spreadsheet, its own evidence folder, and its own version of "is this control actually implemented." That duplication is the real cost, and it compounds every year the regulatory list grows.

The five regimes overlap more than they differ

ISO 27001, GDPR, NIS2, DORA and KVKK are not five unrelated checklists. They overlap heavily on the same underlying controls: access control, encryption, incident response, vendor risk management, business continuity, and — across all five — some form of risk assessment and treatment. A single well-implemented access control policy can satisfy requirements in every one of these frameworks simultaneously. The problem is that most compliance programs don't track it that way: they track it once per framework, because that's how the audit or the consultant engagement was scoped.

This is the same pattern that made Vanta and Drata successful in the SOC 2 / ISO 27001 world: map a control once, apply it to every framework it satisfies, and let the evidence you collect for one audit stand in for another. It works just as well — arguably better — across KVKK and the EU stack, because the underlying control expectations (lawful basis for processing, breach notification timelines, data subject rights, security-of-processing measures) rhyme closely between KVKK and GDPR specifically.

Where KVKK and GDPR actually diverge

They're close, not identical. A control library that treats KVKK as "GDPR with a Turkish translation" will miss real differences — the Turkish Data Protection Authority (KVKK Kurumu) has its own registration requirements (VERBİS), its own breach notification timeline, and its own approach to cross-border data transfer that doesn't map cleanly onto GDPR's adequacy/SCC framework. Treating the two as interchangeable creates exactly the kind of gap an auditor — or a regulator — will find.

The right approach is a control library with both KVKK and the EU stack mapped as first-class frameworks against a shared set of controls, so the overlap is captured once and the genuine differences are flagged explicitly rather than papered over. That's the model Govexa is built around, and it's a large part of why we exist: in surveying the GRC platform market, we found several credible EU-native platforms covering NIS2, DORA, ISO 27001 and GDPR together — but none of them appear to also cover KVKK natively. For a Turkish company selling into Europe, or a European company operating in Türkiye, that gap means running a separate tool or consultant relationship just for KVKK, on top of everything else.

What to look for if you're evaluating this

The point isn't fewer audits — it's less duplicated work

You'll still need a KVKK-specific review, a GDPR DPA process, and a proper ISO 27001 audit. Combining frameworks into one system doesn't remove any of that. What it removes is re-proving the same control five separate times, in five separate formats, for five separate reviewers — and the drift that creeps in when one of those five copies gets updated and the other four don't.

If you're building or scaling a compliance program that touches both the EU and Türkiye, it's worth asking your current (or prospective) GRC tool directly: does KVKK live in the same control library as everything else, or is it an afterthought? For most platforms we looked at, it's the latter — or it isn't supported at all.

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