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Security report for luminor.ee

Luminor Bank AS · Finance · Estonia

High risk. 18 critical or high findings in GDPR outside view and Network security.

Security score

49/100

Risk levelHigh

0–100, higher is better. How it is calculated

Luminor Bank AS operates as a leading financial institution in the Baltic region, offering a comprehensive suite of banking services including payments, loans, savings, investments, and private banking. The website targets both retail and business customers and positions itself as the third largest financial services provider in the Baltics. The digital presence is built on modern web technologies such as React and integrates tools like Google Tag Manager and LiveChat for enhanced user engagement. However, the website suffers from a critical security flaw due to the absence of a valid SSL certificate, exposing users to potential data interception risks. Privacy and cookie policies are well implemented and GDPR compliant, reflecting a strong commitment to user data protection. Overall, while the business credibility and content quality are high, the security posture requires urgent improvement to meet industry standards and protect customer data effectively.

Scanned

NIS2 and GDPR posture

GDPR outside view
0/ 100 · Critical
Checks completed
7of 7

NIS2 Art. 21(2)

  1. (a) Risk analysis and security policies: Not visible from outside
  2. (b) Incident handling: One indicator
  3. (c) Business continuity, backups and crisis management: Not visible from outside
  4. (d) Supply chain security: Not visible from outside
  5. (e) Secure acquisition, development and maintenance, including vulnerability handling: Partly checked
  6. (f) Assessing the effectiveness of security measures: Not visible from outside
  7. (g) Cyber hygiene and security training: Not visible from outside
  8. (h) Cryptography and encryption: Partly checked
  9. (i) HR security, access control and asset management: One indicator
  10. (j) Multi-factor authentication and secured communications: Not visible from outside

This scan rated NIS2 with an earlier keyword method that is no longer shown; rescan for the per-article view. Risk management, continuity, supply chain, training, MFA, management oversight (Art. 20) and incident reporting (Art. 23) need internal evidence, and Guard cannot tell whether NIS2 applies to this organisation.

GDPR is indicative only, based on publicly visible signals: Articles 7, 12, 13 and 32 of Regulation (EU) 2016/679 and Article 5(3) of the ePrivacy Directive. Not a certification or legal assessment.

Priority findings

18 findings rated critical or high. Fix these first.

  1. GDPR outside view

    These are the privacy signals visitors and data protection authorities look for under GDPR.

    • Critical

      EU business without adequate privacy measures

      EU businesses are subject to strict GDPR requirements

      What to do: Implement comprehensive GDPR compliance including privacy policy, cookie consent, and data protection measures

  2. Network security

    Services reachable from the internet are the first thing attackers probe. Anything open that does not need to be should be closed.

    • Critical

      Critical Service Exposed: Telnet

      Port 23 (Telnet) is publicly accessible - Telnet - Unencrypted remote access

      What to do: Immediately restrict access to Telnet using firewall or VPN

      • NIS2 21(2)(e)
      • IR 2024/2690 6.7.2(f): Implementing Regulation (EU) 2024/2690, Annex point 6.7.2(f): Network security
      • NIST CM-7: NIST SP 800-53 Rev. 5 CM-7: Least Functionality
      • NIST SC-7: NIST SP 800-53 Rev. 5 SC-7: Boundary Protection
    • Critical

      Critical Service Exposed: SMB

      Port 445 (SMB) is publicly accessible - SMB - Windows file sharing, high risk

      What to do: Immediately restrict access to SMB using firewall or VPN

      • NIS2 21(2)(e)
      • IR 2024/2690 6.7.2(f): Implementing Regulation (EU) 2024/2690, Annex point 6.7.2(f): Network security
      • NIST CM-7: NIST SP 800-53 Rev. 5 CM-7: Least Functionality
      • NIST SC-7: NIST SP 800-53 Rev. 5 SC-7: Boundary Protection
    • Critical

      Critical Service Exposed: MSSQL

      Port 1433 (MSSQL) is publicly accessible - MSSQL - Database server

      What to do: Immediately restrict access to MSSQL using firewall or VPN

      • NIS2 21(2)(e)
      • IR 2024/2690 6.7.2(f): Implementing Regulation (EU) 2024/2690, Annex point 6.7.2(f): Network security
      • NIST CM-7: NIST SP 800-53 Rev. 5 CM-7: Least Functionality
      • NIST SC-7: NIST SP 800-53 Rev. 5 SC-7: Boundary Protection
    • Critical

      Critical Service Exposed: Oracle

      Port 1521 (Oracle) is publicly accessible - Oracle - Database server

      What to do: Immediately restrict access to Oracle using firewall or VPN

      • NIS2 21(2)(e)
      • IR 2024/2690 6.7.2(f): Implementing Regulation (EU) 2024/2690, Annex point 6.7.2(f): Network security
      • NIST CM-7: NIST SP 800-53 Rev. 5 CM-7: Least Functionality
      • NIST SC-7: NIST SP 800-53 Rev. 5 SC-7: Boundary Protection

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  • TLS certificates and expiry
  • DNS records
  • SPF, DKIM and DMARC
  • Security headers
  • GDPR and NIS2 posture
  • Exposed services
  • Third-party trackers
  • Security score drift

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Results by check

Each check with its score, findings and the evidence it collected.

How this score is calculated

The security score runs 0–100, higher is better. It is the plain average of the security checks that completed in this scan, each counted equally. A check that could not run is left out: it counts neither as a pass nor as a fail.

Counted in this score

SSL/TLS
100
Security headers
85
Email security
75
DNS health
60
Network security
0
GDPR outside view
0
Average
53
After the cap
49

Not counted

  • NIS2 outside view: Re-weights evidence from the TLS, email, DNS, network and hygiene checks, so counting it would count that evidence twice. Shown on its own.
  • OffSeq Observations: An AI reading of the site, useful context but not reproducible evidence. Shown on its own.

Findings that cap the score at 49

Each of these is serious on its own, so while any is present the site cannot rate better than high risk, however good the other checks are.

  • The certificate is not trusted by browsers
  • The website is not served over HTTPS
  • A database, remote desktop, file-sharing or Telnet service is reachable from the internet · found on this site
  • The page loads a script from a compromised source
  • The domain registration has expired
  • SPF authorises every server to send mail as the domain

Partial scans

When the site blocks Guard or most checks cannot run, the score covers only the checks that ran (usually DNS and email), is capped at 75 and is shown as partial, without a risk level.

Risk levels

  • Critical0–25
  • High26–49
  • Medium50–75
  • Low76–100

Technical appendix

Business context, site observations and technical notes gathered during the scan, and the standards behind each reference.

Business context

Business profile

Luminor Bank's market positioning as a major Baltic financial services provider is supported by a mature domain and consistent WHOIS data. The bank leverages partnerships and subsidiaries such as Luminor Liising AS and Luminor Pensions Estonia AS to diversify its offerings. The business model focuses on retail and business banking with a strong emphasis on customer orientation and digital services. The website content and social media presence reinforce brand trust and customer engagement. Growth indicators include active marketing campaigns and investment services. The partnership ecosystem includes career portals and social media channels, enhancing recruitment and brand visibility.

Security posture

The current security maturity level is low due to the lack of HTTPS and missing security headers. This exposes the website and its users to significant risks including data interception and man-in-the-middle attacks. The absence of DMARC, DNSSEC, and CAA records further weakens domain security posture. No explicit incident response or security policies are published, indicating potential gaps in security governance. Privacy compliance is strong with comprehensive policies and consent mechanisms in place. Immediate remediation of SSL/TLS issues and implementation of security best practices are critical to reduce business risk and comply with regulatory requirements.

Recommendations

  1. Implement and maintain a valid SSL/TLS certificate to enable HTTPS across the entire site.
  2. Enable HTTP Strict Transport Security (HSTS) with includeSubDomains and preload directives.
  3. Publish and enforce DMARC, DNSSEC, and CAA DNS records to protect domain integrity.
  4. Add essential security headers such as Content-Security-Policy, X-Frame-Options, and X-Content-Type-Options.
  5. Develop and publish a formal security policy and incident response plan accessible to users.
  6. Optimize website performance to reduce page load times and improve user experience.
  7. Enhance accessibility features to meet WCAG standards for broader user inclusion.
  8. Regularly audit third-party scripts and tracking tools to ensure privacy compliance.
Technical notes

Notes

The website is built using React and leverages Cloudflare for DNS and likely CDN services. It integrates Google Tag Manager for analytics and OneTrust for cookie consent management, indicating a modern approach to digital marketing and privacy compliance. However, the site suffers from slow load times (over 18 seconds) and lacks a valid SSL certificate, which is a critical technical deficiency. The absence of security headers and domain security DNS records indicates technical debt and potential risks. The CMS appears custom or proprietary, with no common CMS detected. Hosting is likely via Cloudflare infrastructure. Mobile optimization is good, but accessibility is basic. SEO practices are adequately implemented with proper meta tags and structured content.
Standards and sources

Reference chips under each finding point to the standard, regulation or specification the finding relates to. They are taken from the official datasets below and mapped conservatively: a finding with no defensible link shows none. NIS2 and GDPR references mark where a finding is relevant evidence, not a compliance verdict. Implementing Regulation (EU) 2024/2690 binds digital infrastructure and digital service providers; for other entities it is the most detailed public reading of the Article 21 measures. WCAG, EN 301 549, European Accessibility Act and Web Accessibility Directive references name the requirement an automated accessibility rule relates to; they are not a conformance verdict.

Retrieved 2026-10-25

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