FEATURES OF LEGISLATION ON CYBER SECURITY AUDITING IN DIFFERENT REGIONS OF THE WORLD

Abstract

The article is dedicated to a comparative analysis of the cyber security audit regulatory requirements in key regions of the world amidst global digital transformation. The study systematizes and compares regulatory approaches in the European Union, North America, Asia, and Africa, with a special focus on the requirements for the financial sector. The analysis covers key standards and legislative acts, including GDPR, NIS2, NIST CSF, PCI DSS, as well as leading national laws in China, such as MLPS 2.0, and in Africa, such as POPIA, NDPA, and DPA. The regional analysis revealed fundamental differences in approaches: from the strictly regulated and centralized in the EU (GDPR, NIS2) to the flexible, market-practice-driven in the USA (NIST CSF, SOC 2), heterogeneous in Asia with elements of strict state control (China's MLPS 2.0), and fragmented in Africa, where ineffective pan-African initiatives give way to national legislation facing implementation challenges. The study establishes that the main challenge for international companies is navigating this complex and inconsistent regulatory environment, which often results in significant operational overhead and the phenomenon of “compliance fatigue” due to duplicated audits across various standards. In response, the article offers practical "roadmaps" for financial companies to enter the markets of each of the considered regions, emphasizing the need for tailored, risk-based strategies. It also highlights the critical gap between formal compliance with requirements and actual cyber resilience. This disconnect is particularly noticeable in regions with a shortage of qualified personnel and weak institutional frameworks, where "paper compliance" may not translate into robust protection against sophisticated cyber threats. In conclusion, the article provides a structured overview of the global landscape of cybersecurity regulations and practical recommendations for building adaptive strategies for ensuring regulatory compliance in the context of international operations.