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§03/EVIDENCE-BY-DEFAULT

Compliance for self-hosted infrastructure

Which regulations bind your infrastructure, what each one actually demands of it, and the controls that satisfy several at once.

Most compliance writing is organised by regime, which is the wrong shape for the question engineers actually face. You do not get to pick one framework. A European fintech running inference on customer data is inside GDPR, DORA and the AI Act simultaneously, and if it has an Indian subsidiary it is also running a six-hour CERT-In clock that none of the European instruments prepare it for.

This page is organised the other way round. First, which regimes bind you and what each one demands of infrastructure rather than of policy. Then the reporting clocks side by side, because among the regimes on this page they differ by an order of magnitude and the tightest one that applies to you silently sets your detection requirement. Then the control surfaces that recur under different names in every regime — the part that is genuinely shared, and the reason a self-hosted platform can serve several frameworks with one set of mechanisms.

Everything here is drawn from the deep dives linked beside it. Where a regime is still moving — and several are — the article says so rather than pretending the ground is settled.

01 — Which of these binds you

The regimes, and what each demands of infrastructure

SOC 2

US-originating, global in practice

Binds — Service organisations whose customers demand assurance — driven by procurement, not statute.

Demands — Evidence that named controls operated over a period. On a self-hosted platform that means access changes, workload mutations and audit events are produced by the system rather than assembled by hand.

SOC 2 Compliance on Self-Hosted Kubernetes: Own the Evidence

ISO 27001

International

Binds — Organisations seeking certification of an information security management system.

Demands — A defined scope boundary and a Statement of Applicability that maps every Annex A control to a mechanism you operate — with no controls inherited from a provider you cannot audit.

ISO 27001 Without Inherited Controls: Annex A You Operate

GDPR

General Data Protection Regulation

EU / EEA

Binds — Controllers and processors established in the Union, and — under Article 3(2) — those outside it who offer goods or services to people in the Union or monitor their behaviour. Scope turns on establishment or targeting, not on a data subject's location alone.

Demands — Article 32 technical measures an auditor can verify, Article 30 records of processing, and Article 33 breach notification by the controller (subject to the unlikely-to-result-in-a-risk exception).

GDPR Article 32 in Practice: Technical Measures an Auditor Can Verify

DORA

Digital Operational Resilience Act

EU financial sector

Binds — Financial entities and the ICT third parties they depend on.

Demands — Identification of critical or important functions, resilience testing against them, Article 30 contractual provisions for the ICT services supporting those functions, and a reporting cascade measured in hours.

DORA Compliance Without Concentrating Your Risk: The Self-Hosted Case

EU AI Act

EU

Binds — Providers and deployers of AI systems, with obligations scaled to risk classification.

Demands — For high-risk systems: logging, traceability, human oversight and data governance that survive an inspection — which is difficult when inference runs on someone else's tenancy.

The EU AI Act for High-Risk AI Systems: An On-Prem Compliance Path

Cyber Resilience Act

CRA

EU

Binds — Manufacturers of products with digital elements — which reaches further into build pipelines than most teams expect.

Demands — Vulnerability handling, a documented SBOM, and Article 14 reporting of actively exploited vulnerabilities.

The Cyber Resilience Act Reaches Your Build Pipeline

DPDP Act

Digital Personal Data Protection Act, 2023

India

Binds — Data Fiduciaries — those deciding the purpose and means — processing digital personal data in India, and processing outside India where it relates to offering goods or services in India. A Data Processor is a distinct role with different duties.

Demands — Consent machinery, data-principal rights including erasure, and a breach notice — architecture decisions, not a policy document.

The DPDP Act for Engineers: Data Residency Architecture, Not Policy

CERT-In Directions

India

Binds — Service providers, intermediaries, data centres and body corporates operating in India.

Demands — The tightest clock in this table measured from becoming aware — six hours — plus 180 days of ICT logs retained within Indian jurisdiction and clock synchronisation to NIC/NPL.

CERT-In's 6-Hour Rule: On-Prem Logging for India's Reporting Mandate

MeitY empanelment

India, public sector

Binds — Providers hosting Indian government workloads.

Demands — Eligibility for public-sector procurement rather than a cyber-incident statute: hosting constraints on where and how the platform runs. The residency architecture behind them is covered on /sovereignty, not restated here.

MeitY Empanelment: Architecting for Indian Government Cloud

HIPAA

US healthcare

Binds — Covered entities and business associates handling protected health information.

Demands — Safeguards over PHI and a business associate agreement — the gap that opens when inference is sent to a provider who will not sign one.

HIPAA-Compliant LLM: On-Prem PHI Inference Without the BAA Gap

Cross-border transfer

Schrems II and successors

EU → third countries

Binds — Transfers of EU personal data to a third country that cannot rely on an adequacy decision — the SCC and BCR paths, where a transfer impact assessment is required. Adequacy-covered transfers do not carry this burden.

Demands — A transfer impact assessment that survives contact with foreign surveillance law, plus supplementary measures where it does not. The residency architecture this implies is covered on /sovereignty.

Schrems II, Six Years On: EU Data on US Clouds Is Still Unsafe

02 — The clocks

Reporting deadlines differ by an order of magnitude

The tightest obligation you are subject to sets your detection requirement, not your paperwork requirement. An entity inside both CERT-In and GDPR is running a six-hour clock and a seventy-two-hour clock on the same incident, and only one of them is survivable with quarterly log review.

RegimeFirst deadline (from becoming aware)Then
CERT-In (India)6 hours from noticingReport what you have; supplement later. The window runs as wall-clock time from noticing, not from triage.
DORA (EU finance)24 hours from becoming awareBut the binding first filing can land sooner: initial notification within 4 hours of classifying the incident as major, capped at 24 hours from awareness. Intermediate report within 72 hours of that notification; final report within one month of the intermediate. The hour figures come from the RTS under Article 20, not from Article 19 itself.
NIS2 (EU)24 hours from becoming aware — early warningIncident notification within 72 hours of becoming aware; final report not later than one month after the incident notification.
Cyber Resilience Act (EU)24 hours from becoming aware, without undue delayFuller vulnerability or incident notification within 72 hours. A final report follows as a third stage on its own anchor — 14 days from a corrective measure being available for an actively exploited vulnerability, one month from the 72-hour notification for a severe incident.
GDPR (EU)72 hours from becoming aware, where feasibleWithout undue delay under Article 33; Article 34 communication to data subjects can be removed by effective encryption.

03 — One mechanism, many regimes

The control surfaces that recur in all of them

Read the frameworks side by side and the same seven mechanisms keep reappearing under different names. This is why a self-hosted platform can serve several regimes at once: you build the control, and each framework recognises its own vocabulary in it.

Workload identity and access

Every framework wants to know who did what, and increasingly what — not who — is calling. Short-lived cryptographic workload identity replaces long-lived shared credentials, and human access runs through a single reviewable path with break-glass as the documented exception.

SOC 2 CC6 · ISO 27001 Annex A · GDPR Article 32

Key custody and internal PKI

Encryption satisfies nobody if the keys sit in a tenancy you do not control. Running your own certificate authority and keeping secrets in a store you can audit turns an assertion into something an assessor can inspect.

GDPR Articles 32 and 34 · HIPAA safeguards · ISO 27001 Annex A

Logging, retention, and synchronised time

The single most reused control in this table, and the one most often broken by a foreign SaaS log store. Retention windows are jurisdictional, and correlated timestamps are what make an incident timeline defensible.

CERT-In 180 days in Indian jurisdiction · SOC 2 CC7 · NIS2 · DORA

Detection fast enough for the tightest clock

A six-hour reporting obligation is really a detection requirement. Kernel-level runtime detection is what closes the gap between an event happening and anyone noticing — the interval that consumes most of the window.

CERT-In · NIS2 · DORA · SOC 2 CC7

Recovery you have actually timed

Resilience obligations ask for a tested recovery objective, not a documented one. A restore drill with a date and a measured duration is evidence; a runbook nobody has executed is not.

DORA resilience testing · SOC 2 availability · ISO 27001 Annex A

Change control that refuses, not just records

Policy expressed as code and enforced at admission produces its own evidence: the refusal is the control operating. A review process that depends on people remembering is the one auditors find gaps in.

SOC 2 CC8 · ISO 27001 Annex A 8.9 · NIS2 risk measures

Supply chain and third-party risk

The newest obligation and the fastest moving. Knowing what is in your images, proving they are the ones you built, and holding a real contract with every provider whose failure you must survive.

CRA vulnerability handling and SBOM · DORA Article 30 · NIS2 supply chain

Executive Briefing

Thirty minutes to clarify your infrastructure risk

Walk us through your vendor footprint and regulatory constraints. We will tell you honestly where sovereignty creates leverage — and where it does not. No pitch deck. No obligation.