Multi-factor authentication is mandatory under NIS2 (current status, as it has not yet been implemented in Germany) and GDPR, at least in Germany.
German draft of NIS2 dated July 25, 2025
Chapter 2 Risk management, reporting, registration, verification, and notification obligations
§30
Risk management measures for particularly important facilities and important facilities
(2) Measures pursuant to paragraph 1 shall comply with the state of the art, take into account the relevant European and international standards, and be based on a cross-hazard approach. The measures must include at least the following:
10. Use of multi-factor authentication or continuous authentication solutions, secure voice, video, and text communication, and, where appropriate, secure emergency communication systems within the facility.
Compliance with the requirements of the GDPR
The GDPR itself does not directly stipulate that multi-factor authentication must be used. However, Article 32(1) GDPR stipulates that a controller must implement appropriate and state-of-the-art technical and organizational measures to help protect the rights and freedoms of natural persons.
Multi-factor authentication (MFA) is an important part of DORA compliance for financial institutions in the EU. DORA, the Digital Operational Resilience Act, requires financial companies to use strong authentication to increase digital resilience and minimize cyber risks.
Whether MFA makes sense is another matter. It is now required. And the typical argument is: But it works with MS365!
I also know that this is required during audits for customers who are subject to financial market supervision in Austria, Germany, or Switzerland.