Does my company have to implement NIS2?

NIS2.

Cyber security becomes a matter for the boss. What the German NIS2 law requires from companies, in clear steps.

In 60 seconds

  • Since 6 December 2025, NIS2 has applied in Germany to significantly more companies.
  • 10 measures, registration with the BSI and reporting deadlines of 24 hours, 72 hours and one month.
  • The management is responsible and can be held liable.
Document with checklist, shield with tick and deadlines 24 hours, 72 hours, 1 month

Briefly explained.#

What is NIS2?

An EU directive (2022/2555) for a high level of cyber security. In Germany it applies through the NIS2 Implementation Act and the revised BSI Act, since 6 December 2025 and without a transition period.

Who does it affect?

Significantly more companies than before. Estimates assume around 29,500 entities in 18 sectors, from medium company size upwards.

What is new?

The management is responsible, companies must register with the BSI, report security incidents quickly and expect high fines.

Am I affected?#

2 questions decide: sector and size.

Sectors of high criticality

Energy, transport, banking and financial market infrastructure, health, drinking water and waste water, digital infrastructure and business-to-business IT services, public administration, space.

Other critical sectors

Postal and courier services, waste management, chemicals, food, manufacturing (for example machinery, electronics, vehicles), digital services such as marketplaces or search engines, research.

Size

At the core, medium-sized and large companies are affected, meaning from 50 employees or more than €10 million annual turnover and balance sheet total. There are exceptions for smaller entities in special cases.

Essential entitiesImportant entities
WhoLarge companies in sectors of high criticality, plus other entities such as operators of critical facilitiesMedium-sized companies there, and medium-sized and large companies in the other critical sectors
SupervisionThe BSI can also carry out checks without a specific reasonThe BSI mainly intervenes after indications or incidents
Fine up to€10 million or 2% of worldwide annual turnover€7 million or 1.4% of worldwide annual turnover

The BSI offers an online applicability check. If in doubt, have the classification checked by experts or lawyers. Rough guidance, not legal advice.

Applicability assistant.#

2 questions, a rough classification.

Rough classification without legal advice. The exact activity, group structure and exceptions are decisive. The BSI offers its own assessment tool.

10 measures that apply.#

The law requires effective risk management. In practice, this means:

MeasureIn practice this meansMore on this
Risk analysis and security conceptsAssess risks systematically and have a documented conceptIT security
Handling security incidentsDetect, report and handle incidents, with roles and practiceCrisis management
Business continuityBackups, recovery and crisis managementCrisis management
Supply chain securityAssess suppliers and service providers and bind them by contractGlossary
Procurement, development, maintenanceManage vulnerabilities, patch systems, develop securelyMonitoring
Check effectivenessTests, audits, metrics and penetration testsMonitoring
Training and cyber hygieneTrain employees and management regularlyBasic check
Cryptography and encryptionConcepts for encrypting data and connectionsHigh-security networks
Personnel, access, asset managementKeep permissions, physical access and inventory under controlAccess control
MFA and secured communicationMulti-factor sign-in and protected emergency communicationIT security

NIS2, ISO 27001 and IT-Grundschutz.#

Law, standard and method compared directly.

NIS2 (BSI Act)ISO/IEC 27001BSI IT-Grundschutz
What is it?A law with cyber security obligationsInternational standard for an information security management system (ISMS)BSI method with standards 200-1 to 200-3 and the IT-Grundschutz Compendium
Mandatory?Yes, for affected entitiesVoluntary, often required by customersVoluntary, common in public authorities and among their service providers
FocusRisk management, reporting obligations, registration, management responsibilityRisk-based set-up of an ISMS, 93 controls in Annex ASpecific modules and requirements per system and process
EvidenceEvidence on request of the BSI, regularly for operators of critical facilitiesCertificate from an accredited body, valid for 3 years with annual surveillance auditsISO 27001 certificate based on IT-Grundschutz, issued by the BSI
EffortDepends on size and sectorMedium, scales wellHigh, but very specific

How does it fit together?

The frameworks complement each other. Anyone running an ISMS according to ISO 27001 or IT-Grundschutz already covers many NIS2 measures. Reporting obligations, registration and management duties still come on top.

Guidance, not legal advice.

Reporting deadlines for incidents.#

The clock starts when you become aware of a significant incident.

1AwarenessSignificant incidentis detected224 hoursEarly warning to theBSI372 hoursNotification with initialassessment41 monthFinal reportFor personal data: additional GDPR notification
Reports go to the BSI. If personal data is affected, a report to the data protection authority is added.

Early warning after 24 hours

Brief first information: incident detected, suspicion of an unlawful cause or cross-border impact?

Notification after 72 hours

Initial assessment of the incident, its severity, its impact and, as far as known, the cause.

Final report after one month

Detailed description, cause, measures taken and impact.

Deadline calculator.#

When do the reporting deadlines expire?

The deadlines run from the moment you become aware of the incident.

Guidance without legal advice. The BSI Act and the BSI's reporting requirements are decisive.

Management responsibility.#

Approve and supervise

The management must approve the risk management measures and supervise their implementation. Delegating is possible, handing over responsibility is not.

Build knowledge

Managing directors should take part in training regularly in order to assess risks and measures.

Liability

In the event of breaches of duty, the management can be held personally liable. Documentation protects.

Implementation roadmap.#

6 steps that have proven themselves.

  1. Check applicability

    Check sector and size. The BSI offers a tool for this.

  2. Register

    Affected entities register via the BSI portal.

  3. Identify gaps

    Compare risk analysis and inventory against the 10 measures.

  4. Prioritise measures

    First MFA, backups, patches, emergency plan, then depth.

  5. Practise the reporting process

    Who reports what within 24 hours? Play it through once.

  6. Prove and repeat

    Document, review regularly and update.

Frequently asked questions.#

Does NIS2 also affect my suppliers?

Indirectly, yes. Affected companies must take the security of their supply chain into account and pass requirements on in contracts. Smaller suppliers therefore also receive questionnaires and requests for evidence.

Is an ISO 27001 certification enough?

It covers many technical and organisational requirements, but does not replace registration, reporting obligations and management responsibility.

What about critical infrastructure?

Operators of critical facilities are also subject to stricter rules. Since 17 March 2026 the KRITIS Umbrella Act applies to physical protection, more under Protected infrastructure.

Are there other rules I should know?

Yes. The EU Cyber Resilience Act brings obligations for manufacturers of connected products, including reporting obligations. Which rules apply to you depends on your business model.

As of November 2026. Basis: Act implementing the NIS 2 Directive (BGBl. 2025 I No. 301) with the revised BSI Act. Guidance, not legal advice. Current details and the portal are available from the BSI: bsi.bund.de.

Questions about implementation?

Tell me which point is still open for you, and we will add it.

Learning path Understanding NIS2Steps 1 to 4 of 6Next: The first hours of an incident

Sources and further reading

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