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Knowledge base Updated: February 5, 2026

Key Requirements of NIS2 Directive - Actions, Process, Obligations, Preparations, Implementation Deadline, and Incident Reporting

The NIS2 Directive imposes new cybersecurity requirements. Check what actions and obligations companies must meet.

Marcin Godula Marcin Godula

The NIS2 Directive imposes on organizations the obligation to introduce risk management measures, incident reporting, and preparation for cyber threats. Key requirements include infrastructure monitoring, risk analysis, security implementation, and timely incident reporting within 24 hours. The implementation deadline for these regulations is approaching, so organizations must accelerate adaptation processes.

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What are the key requirements of the NIS2 directive?

The NIS2 Directive introduces a number of key requirements aimed at significantly strengthening cybersecurity in the European Union. These requirements encompass a comprehensive approach to cyber risk management, incident reporting, and building organizational resilience.

First and foremost, NIS2 requires organizations to implement advanced cyber risk management measures. This includes systematic identification, analysis, and assessment of cybersecurity-related risks, as well as implementation of appropriate technical and organizational measures to mitigate them. Organizations must regularly conduct risk assessments and adapt their security strategies to the changing threat landscape.

Another key requirement is the obligation to report security incidents. NIS2 introduces more rigorous deadlines and a broader scope of reporting. Organizations must report serious incidents within 24 hours of detection, and then provide a more detailed report within 72 hours. This aims to enable faster response at both national and EU levels.

The directive also emphasizes building a cybersecurity culture in organizations. It requires regular employee training and awareness programs, as well as top management engagement in cybersecurity issues. NIS2 introduces personal responsibility for board members for compliance with cybersecurity regulations.

NIS2 also expands the scope of sectors covered by regulations. In addition to traditional critical sectors such as energy or transport, the directive now also covers sectors such as medical equipment manufacturing, waste management, or food production. This reflects the growing importance of cybersecurity in all areas of the economy.

An important aspect is the requirement to implement advanced threat monitoring and detection systems. Organizations must be able to quickly identify potential attacks and anomalies in their systems. NIS2 promotes the use of modern technologies, such as artificial intelligence and machine learning, in cybersecurity processes.

The directive also introduces more rigorous requirements for supply chain security. Organizations must assess and manage risks associated with suppliers and business partners, recognizing that weak links in the supply chain can pose a serious threat to the entire organization.

NIS2 emphasizes cross-sectoral and international cooperation in cybersecurity. It requires organizations to actively participate in information exchange about threats and best practices, both at national and EU levels.

In summary, the key requirements of NIS2 create comprehensive frameworks for strengthening cybersecurity in the EU. They require organizations to adopt a proactive, systematic, and holistic approach to cybersecurity that extends beyond traditional IT department boundaries and encompasses the entire organization.

What actions must companies take to adapt to NIS2?

To adapt to the requirements of the NIS2 Directive, companies must take a number of specific actions covering both technical and organizational aspects. The adaptation process requires a comprehensive approach and engagement at all levels of the organization.

The first key step is to conduct a detailed compliance assessment with NIS2 requirements. Companies must thoroughly analyze their current cybersecurity practices and systems in the context of new requirements. This gap analysis will identify areas requiring improvement and prioritize necessary actions.

Next, organizations must develop or update their cybersecurity strategy. This strategy should be tailored to the company’s specific risks and needs while meeting NIS2 requirements. It’s crucial that this strategy be approved and supported by top management.

Implementing advanced cyber risk management systems is another essential action. Companies must establish processes for systematic identification, assessment, and mitigation of cybersecurity-related risks. This includes regularly conducting risk assessments and implementing appropriate control measures.

Organizations must also significantly strengthen their threat monitoring and detection systems. This may require investment in advanced tools such as SIEM (Security Information and Event Management) systems or solutions based on artificial intelligence for analyzing user and system behavior.

A key action is establishing or strengthening a security incident response team (CSIRT). This team must be able to quickly detect, analyze, and respond to security incidents. Companies must develop detailed incident response procedures compliant with NIS2 reporting requirements.

Implementing training and awareness programs for employees is essential for building a cybersecurity culture. These trainings should cover all employees, with special attention to IT staff and senior management.

Companies must also conduct an audit and strengthen their supply chain security. This includes assessing risks associated with suppliers, introducing appropriate security clauses in contracts, and regularly auditing key suppliers.

An important action is reviewing and updating security policies and procedures. Companies must ensure their documentation complies with NIS2 requirements and reflects best practices in cybersecurity.

Organizations must also implement advanced technical solutions, such as data encryption systems, advanced firewalls, intrusion prevention systems (IPS), or identity and access management (IAM) solutions.

Finally, companies must establish processes for continuous improvement and adaptation of their cybersecurity practices. This includes regular penetration tests, incident response exercises, and continuous updating of security strategies in response to new threats.

Adapting to NIS2 requires significant investment of time and resources, but it’s crucial for ensuring the organization’s cyber resilience in today’s dynamic threat environment.

What does the risk management process look like under NIS2?

The risk management process under the NIS2 Directive is a comprehensive and continuous activity that includes several key stages. NIS2 requires organizations to adopt a systematic and proactive approach to identifying, assessing, and mitigating cybersecurity-related risks.

The first step in the risk management process is identifying assets and processes critical to the organization. Companies must thoroughly inventory their IT systems, data, and business processes, with special attention to those crucial for business continuity and security.

Next, organizations must conduct a detailed threat analysis. This includes identifying potential threat sources, both external (e.g., cybercriminals, competition) and internal (e.g., disgruntled employees, human errors). NIS2 requires this analysis to consider the latest cyber threat trends and be regularly updated.

The next stage is assessing system and process vulnerabilities to identified threats. Companies must conduct comprehensive vulnerability scanning, penetration tests, and system configuration analyses to identify weak points in their IT infrastructure.

Based on threat analysis and vulnerability assessment, organizations must conduct risk assessment. NIS2 requires this assessment to consider both the likelihood of incident occurrence and potential impact on the organization. Companies must use advanced risk quantification methods to enable prioritization of mitigation actions.

After risk assessment, organizations must develop and implement a risk management plan. This plan should include specific technical and organizational measures aimed at reducing identified risks. NIS2 emphasizes that these measures should be proportionate to the risk level and consider the latest technological achievements.

A key element of the NIS2 risk management process is continuous monitoring and evaluation of implemented measures’ effectiveness. Organizations must establish real-time monitoring systems that enable rapid detection of potential incidents and anomalies.

NIS2 also requires regular review and updating of the entire risk management process. Companies must at least once a year, as well as after each significant incident, conduct a full revision of their risk assessment and mitigation plans.

An important aspect of NIS2 risk management is considering supply chain-related risks. Organizations must assess and manage risks associated with suppliers and business partners, recognizing that weak links in the supply chain can pose a serious threat to the entire organization.

The directive also emphasizes top management engagement in the risk management process. The board must be regularly informed about the organization’s cybersecurity status and actively participate in making key risk management decisions.

In summary, the risk management process under NIS2 is comprehensive, continuous, and requires the involvement of the entire organization. It requires a systematic approach to identifying, assessing, and mitigating risks, as well as continuous adaptation to the changing threat landscape.

What are organizations’ reporting obligations under NIS2?

The NIS2 Directive introduces significantly more rigorous and detailed reporting obligations for organizations covered by its scope. These new requirements aim to ensure faster and more effective response to cybersecurity incidents, both at organizational and national levels.

First and foremost, NIS2 requires organizations to report serious security incidents within 24 hours of their detection. This is a significant shortening of time compared to the previous NIS directive, which gave organizations 72 hours to report an incident. The initial report should contain basic information about the incident, such as its nature, potential impact, and immediate actions taken.

Then, within 72 hours of detecting the incident, organizations must provide a more detailed report. This report should contain more precise information about the incident, including its causes, applied remedial measures, and potential long-term effects. NIS2 requires this report to be regularly updated as the situation develops and new information emerges.

Importantly, NIS2 expands the scope of incidents subject to reporting obligation. In addition to incidents that have already occurred, organizations must also report “significant cyber threats” - i.e., situations that potentially could lead to a serious incident. This proactive approach aims to enable earlier response to potential threats.

The directive also introduces the obligation to report incidents that affect suppliers or business partners. Organizations must inform their key suppliers and customers about incidents that may affect the services they provide or the security of their data.

NIS2 requires organizations to establish formal procedures and communication channels for reporting incidents. Companies must designate persons responsible for reporting and ensure they are available 24/7.

In addition to incident reporting, NIS2 also introduces the obligation to regularly report on the organization’s cybersecurity status. Companies must at least once a year present competent authorities with a comprehensive report on their cybersecurity status. This report should contain information about conducted risk assessments, implemented security measures, identified gaps, and improvement plans.

The directive also requires organizations to inform competent authorities about any significant changes in their IT infrastructure or business processes that may affect cybersecurity. This may include, for example, implementing new systems, mergers and acquisitions, or significant changes in the supply chain.

NIS2 emphasizes transparency in communication with customers and business partners. Organizations must inform their customers about serious incidents that may affect provided services or the security of their data. This requires developing clear crisis communication procedures.

It’s worth emphasizing that NIS2 introduces more rigorous sanctions for non-compliance with reporting obligations. Organizations that fail to report incidents within the required time or present incomplete information may be subject to significant financial penalties.

In summary, the reporting obligations introduced by NIS2 are significantly more comprehensive and demanding than in the previous version of the directive. They require organizations not only to respond quickly to incidents but also to take a proactive approach to reporting cybersecurity status. Effectively meeting these requirements will require significant investments in monitoring systems, reporting processes, and staff training.

How does NIS2 regulate corporate responsibility issues?

The NIS2 Directive introduces significant changes in corporate responsibility for cybersecurity, placing much greater emphasis on top management engagement and responsibility. These regulations aim to ensure that cybersecurity issues are treated as a strategic priority at the highest decision-making level.

First and foremost, NIS2 introduces direct responsibility for board members for compliance with cybersecurity requirements. This means that board members can be personally held accountable for serious violations of directive provisions. This personal responsibility is meant to be a strong incentive for prioritizing cybersecurity in the organization.

The directive requires the board to actively participate in shaping and overseeing the organization’s cybersecurity policy. Board members must regularly approve the cybersecurity strategy, assess its effectiveness, and ensure appropriate resources for its implementation. NIS2 imposes on the board the obligation to regularly review and update security policies in response to changing threats.

NIS2 also introduces the requirement for board members to undergo regular cybersecurity training. This aims to ensure that people in top positions have appropriate knowledge and awareness of cyber threats to make informed security-related decisions.

The directive imposes on organizations the obligation to clearly define roles and responsibilities in cybersecurity at all levels of the organization, with special attention to top management. This requires formal assignment of responsibility for various cybersecurity aspects to specific board members or senior management.

NIS2 also introduces the requirement for regular reporting to the board about the organization’s cybersecurity status. The board must be informed about key security indicators, identified risks, and security incidents. These reports must be presented in a form understandable to non-technical people to enable informed strategic decision-making.

The directive emphasizes the culture of responsibility throughout the organization. This requires creating an environment where all employees understand their role in ensuring cybersecurity and are encouraged to report potential problems without fear of negative consequences.

NIS2 also introduces the concept of “due diligence” in cybersecurity. Organizations must be able to demonstrate that they’ve taken all reasonable steps to ensure the security of their systems and data. This can be crucial in legal or regulatory proceedings after security incidents.

It’s worth emphasizing that NIS2 provides for severe sanctions for non-compliance with requirements, which may include not only financial penalties for the organization but also personal consequences for board members, including potential bans on performing managerial functions.

In summary, NIS2 significantly raises the bar for corporate responsibility for cybersecurity. It requires organizations to fundamentally change their approach to cyber risk management, placing this issue at the center of top management attention. Effective implementation of these requirements will require significant changes in organizational culture and decision-making processes in many companies.

How to ensure business continuity in accordance with NIS2 requirements?

Ensuring business continuity is one of the key aspects of the NIS2 Directive, which emphasizes organizational operational resilience in the face of cyber threats. To meet NIS2 requirements for business continuity, organizations must take a number of comprehensive actions.

First and foremost, NIS2 requires the development and implementation of detailed Business Continuity Plans (BCP) and Disaster Recovery Plans (DRP). These plans must be comprehensive and cover various threat scenarios, including cyberattacks, technical failures, natural disasters, or pandemics.

A key element is conducting Business Impact Analysis (BIA). Organizations must identify their critical business processes and IT systems, determine maximum acceptable downtime (RTO - Recovery Time Objective) and data recovery points (RPO - Recovery Point Objective) for each of them.

NIS2 requires regular testing of business continuity plans. Organizations must conduct simulations of various threat scenarios to check the effectiveness of their plans and procedures. These tests should cover not only technical aspects but also decision-making and communication processes.

The directive emphasizes system and data redundancy. Organizations must ensure appropriate backups of critical data and systems, including considering the use of geographically dispersed data centers or cloud solutions to increase resilience to local threats.

NIS2 also requires the development and implementation of crisis communication strategies. Organizations must have clearly defined internal and external communication procedures in case of incidents affecting business continuity, including communication with customers, business partners, and regulatory authorities.

An important aspect is ensuring supply chain continuity. Organizations must assess the resilience of their key suppliers and business partners and include potential disruptions in their operations in their business continuity plans.

NIS2 emphasizes employee training and awareness in business continuity. All employees, especially key personnel, must be aware of their roles and responsibilities in case of business continuity plan activation.

The directive also requires regular review and updating of business continuity plans. These plans must be adapted to changing business conditions, new threats, and lessons learned from tests and actual incidents.

NIS2 introduces the requirement to report on business continuity readiness status. Organizations must regularly inform competent authorities about their plans, conducted tests, and identified areas requiring improvement.

It’s worth emphasizing that NIS2 requires business continuity plans to be integrated with the organization’s overall risk management strategy. This means that business continuity cannot be treated as a separate project but must be an integral part of daily operations and decision-making processes.

In summary, ensuring business continuity in accordance with NIS2 requires a comprehensive, systematic, and continuous approach. Organizations must not only develop solid plans but also regularly test, update, and integrate them with daily operations. Effective implementation of these requirements will significantly increase organizational resilience to various threats, including cyberattacks.

When must companies report security incidents according to NIS2?

The NIS2 Directive introduces more rigorous and precise requirements for reporting security incidents. It specifies clear timeframes and criteria according to which organizations must report incidents to appropriate authorities.

First and foremost, NIS2 requires organizations to report serious security incidents within 24 hours of their detection. This is a significant shortening of time compared to the previous NIS directive, which gave organizations 72 hours to report an incident. This initial report should contain basic information about the incident, such as its nature, potential impact, and immediate actions taken.

Then, within 72 hours of detecting the incident, organizations must provide a more detailed report. This report should contain more precise information about the incident, including its causes, applied remedial measures, and potential long-term effects.

Importantly, NIS2 expands the scope of incidents subject to reporting obligation. Organizations must report not only incidents that have already occurred but also “significant cyber threats” - i.e., situations that potentially could lead to a serious incident.

The directive defines a “serious incident” as an event that causes or may cause significant operational disruptions or financial losses to the organization. Criteria for assessing incident “seriousness” include:

  • Number of users affected by service disruption

  • Duration of the incident

  • Geographic scope of the area affected by the incident

  • Degree of service functioning disruption

  • Scope of impact on economic and social activities

NIS2 also requires reporting incidents that affect suppliers or business partners. Organizations must inform their key suppliers and customers about incidents that may affect the services they provide or the security of their data.

It’s worth emphasizing that NIS2 introduces the obligation to report not only successful attacks but also attack attempts that could potentially lead to serious incidents. This aims to enable earlier detection and response to new threats.

The directive requires organizations to establish formal procedures and communication channels for reporting incidents. Companies must designate persons responsible for reporting and ensure they are available 24/7.

NIS2 also introduces the requirement for regular reporting on the organization’s cybersecurity status, regardless of incident occurrence. Companies must at least once a year present competent authorities with a comprehensive report on their cybersecurity status.

It’s worth noting that NIS2 provides for severe sanctions for non-compliance with reporting obligations. Organizations that fail to report incidents within the required time or present incomplete information may be subject to significant financial penalties.

In summary, NIS2 significantly tightens and specifies requirements for reporting security incidents. Organizations must be prepared for rapid and comprehensive reporting, which requires not only appropriate monitoring and threat detection systems but also efficient internal processes and clearly defined roles and responsibilities.

Effectively meeting these requirements will require companies to:

  • Implement advanced incident monitoring and detection systems capable of quickly identifying potential threats.

  • Establish clear internal procedures for rapid escalation and incident assessment.

  • Create a dedicated team responsible for incident management and reporting.

  • Regular training and exercises for staff in recognizing and reporting incidents.

  • Develop report templates and tools for quickly gathering necessary information.

  • Establish secure communication channels with competent regulatory authorities.

  • Implement systems for tracking and documenting all incident-related activities.

Organizations must also remember that NIS2 reporting requirements may overlap with other regulatory obligations, such as GDPR. Therefore, a coordinated approach to reporting will be necessary, ensuring all relevant legal requirements are met.

What technical and organizational measures should be implemented to meet NIS2 requirements?

To meet the requirements of the NIS2 Directive, organizations must implement a number of advanced technical and organizational measures. These measures aim not only to ensure regulatory compliance but above all to significantly strengthen the organization’s overall cybersecurity position.

In terms of technical measures, it’s crucial to implement:

  • Advanced next-generation firewalls (NGFW) capable of deep packet inspection and protection against advanced threats.

  • Intrusion detection and prevention systems (IDS/IPS) monitoring network traffic for suspicious activities.

  • Identity and Access Management (IAM) solutions, including multi-factor authentication (MFA) for all privileged accounts.

  • Advanced antivirus and anti-malware systems using machine learning techniques to detect new threats.

  • Data encryption systems, both at rest and in transit, using strong encryption algorithms.

  • Network segmentation solutions enabling isolation of critical systems and data.

  • Log monitoring and analysis systems (SIEM) enabling central collection and analysis of security events.

  • Tools for continuous vulnerability monitoring and patch management, ensuring rapid patching of security gaps.

  • Backup creation and management solutions, including disaster recovery systems.

  • Secure remote work tools, such as VPN and secure remote access solutions.

In terms of organizational measures, NIS2 requires:

  • Establishing a formal information security policy, regularly updated and communicated to all employees.

  • Implementing a cybersecurity risk management process, including regular risk assessments and mitigation plans.

  • Creating a dedicated information security team with clearly defined roles and responsibilities.

  • Developing and regularly testing business continuity (BCP) and disaster recovery (DRP) plans.

  • Implementing a program of regular training and awareness-raising in cybersecurity for all employees.

  • Establishing incident management processes, including procedures for rapid detection, response, and reporting.

  • Implementing access management policy based on the principle of least privileges.

  • Developing and implementing supply chain security policy, including supplier risk assessment.

  • Establishing change management processes ensuring all IT system changes are appropriately assessed for security.

  • Implementing a program of regular security audits and penetration tests.

Additionally, NIS2 emphasizes:

  • Top management engagement in cybersecurity issues, including regular reporting to the board.

  • Building a cybersecurity culture throughout the organization.

  • Cooperation with other entities in the sector and regulatory authorities regarding threat information exchange.

  • Continuous improvement and adaptation of security measures in response to changing threats.

Implementing these measures requires significant investments in technology, processes, and people. However, effective implementation will not only ensure NIS2 compliance but also significantly strengthen the organization’s overall cybersecurity position, making it more resilient to increasingly advanced cyber threats.

How to prepare for a compliance audit with the NIS2 directive?

Preparing for a compliance audit with the NIS2 Directive requires a systematic and comprehensive approach. Here are the key steps organizations should take to effectively prepare for such an audit:

  • Conduct internal compliance assessment: The first step should be conducting a detailed self-assessment of compliance with NIS2 requirements. Each aspect of the directive should be analyzed and assessed to what extent the organization’s current practices and systems meet these requirements. This assessment should cover both technical and organizational aspects.

  • Identify gaps and develop an action plan: Based on self-assessment results, areas requiring improvement should be identified and a detailed action plan developed. This plan should contain specific tasks, deadlines for their completion, and persons responsible for their execution.

  • Update documentation: NIS2 requires comprehensive documentation of security processes and policies. All required documents should be ensured to be current, complete, and compliant with directive requirements. Key documents include information security policy, business continuity plans, incident management procedures, and risk assessments.

  • Review and strengthen technical measures: A technical audit of existing security systems should be conducted to ensure they meet NIS2 requirements. This may include updating firewall systems, implementing advanced network monitoring solutions, or strengthening access control mechanisms.

  • Staff training: All employees, especially key IT staff and management, should undergo training on NIS2 requirements and their implications for the organization. Simulation exercises should also be conducted to check the organization’s readiness to respond to incidents.

  • Review risk management processes: NIS2 places great emphasis on risk management. It should be ensured that risk assessment and management processes comply with directive requirements and are regularly conducted.

  • Verify incident reporting processes: It should be checked whether the organization is able to meet the rigorous incident reporting requirements specified in NIS2. This may require updating procedures and systems for detecting and reporting incidents.

  • Supply chain audit: NIS2 requires assessment and management of supplier-related risks. A key supplier audit should be conducted to ensure they meet security requirements.

  • Prepare compliance evidence: All documents, logs, reports, and other evidence that may be required during the audit should be collected and organized. This includes security test documentation, incident reports, training registers, etc.

  • Conduct internal trial audit: Before the official audit, it’s worth conducting an internal trial audit. This will identify any problems and areas requiring additional attention.

  • Management engagement: NIS2 requires active top management engagement in cybersecurity issues. It should be ensured that the board is fully aware of NIS2 requirements and actively participates in audit preparations.

  • Cooperation with external experts: If needed, it’s worth considering engaging external cybersecurity and compliance experts who can help with audit preparations and identify potential problem areas.

Preparing for a NIS2 compliance audit is a complex and time-consuming process, but it’s crucial for ensuring directive compliance and overall strengthening of the organization’s cybersecurity position. Effective preparation will not only facilitate passing the audit but also contribute to significantly increasing the organization’s resilience to cyber threats.

When will the NIS2 directive be effective in Poland?

The NIS2 Directive, as a European Union legal act, is subject to a process of implementation into national legal orders of member states. In the case of Poland, as well as other EU countries, this process has specific timeframes and stages.

Key dates related to NIS2 implementation in Poland are as follows:

  • January 16, 2023 - date of entry into force of the NIS2 Directive. From this day, the official process of implementing the directive in member countries began.

  • October 17, 2024 - final deadline for Poland and other member states to transpose the directive into national law. By this date, Poland must adopt and publish legislative, executive, and administrative provisions necessary to implement the NIS2 directive.

  • October 18, 2024 - date from which Poland should begin applying adopted provisions implementing NIS2.

It’s worth emphasizing that although the final implementation deadline is October 2024, the process of adapting Polish law to NIS2 requirements has already begun. The Ministry of Digitization, in cooperation with other ministries and institutions, is working on a draft law to implement the NIS2 directive into the Polish legal system.

The NIS2 implementation process in Poland includes several key stages:

  • Analysis of current legal status and identification of areas requiring changes.

  • Development of draft law implementing NIS2.

  • Public and inter-ministerial consultations on the draft law.

  • Adoption of the law by the Sejm and Senate.

  • Signing of the law by the President of the Republic of Poland.

  • Publication of the law in the Journal of Laws.

It should be noted that although formal effectiveness of NIS2 provisions in Poland will begin in October 2024, organizations covered by the directive should already begin preparations to meet new requirements. The process of adapting to NIS2 can be time-consuming and require significant investments in infrastructure, processes, and training.

Additionally, Polish regulatory authorities, such as NASK (Research and Academic Computer Network) or CSIRT GOV, are already conducting informational and educational activities regarding NIS2 to help organizations prepare for new requirements.

It’s also worth emphasizing that although NIS2 will be formally effective from October 2024, many of its requirements reflect best practices in cybersecurity. Therefore, organizations that start implementing these practices now will not only be better prepared for new regulations but also significantly strengthen their overall security position.

For Polish organizations, it’s crucial to track progress in the NIS2 implementation process in the country, participate in public consultations regarding the draft law implementing the directive, and actively prepare to meet new requirements.

It’s worth paying attention to several additional aspects related to NIS2 implementation in Poland:

  • Adjustment of existing regulations: Poland will need to adapt existing provisions, including the National Cybersecurity System Act, to NIS2 requirements. This may mean significant changes in current regulations.

  • Expansion of subject scope: NIS2 covers a wider range of sectors and entities than current provisions. Polish regulatory authorities will need to identify and inform new entities covered by the directive.

  • Strengthening supervisory authorities: Poland may be required to strengthen or create new authorities responsible for cybersecurity oversight in various sectors.

  • International cooperation: NIS2 emphasizes enhanced cooperation between EU member states. Poland will need to ensure appropriate mechanisms for such cooperation, including information exchange about threats.

  • Sanctions: Polish provisions implementing NIS2 will need to include a system of sanctions for non-compliance with directive requirements, which may require changes in the current legal system.

  • Education and awareness: Polish institutions will need to intensify educational and awareness activities directed at organizations covered by NIS2 to ensure effective implementation of new requirements.

  • Support for small and medium enterprises: Poland may introduce additional support mechanisms for SMEs in adapting to NIS2 requirements, which may include advice, training, or financial support.

  • Reporting to the EU: Poland will be obliged to regularly report to the European Commission on progress in NIS2 implementation and the state of cybersecurity in the country.

Organizations operating in Poland should actively track the legislative process related to NIS2 implementation. It’s worth participating in public consultations, workshops, and seminars organized by Polish institutions responsible for cybersecurity. This will enable better understanding of the specifics of Polish directive implementation and appropriate preparation for new requirements.

At the same time, organizations shouldn’t wait with actions until the formal entry into force of Polish provisions implementing NIS2. Organizations should already begin:

  • Analysis of gaps between current practices and NIS2 requirements

  • Planning necessary investments in infrastructure and security systems

  • Staff training and building cybersecurity awareness

  • Review and updating of security policies and procedures

  • Strengthening risk and incident management processes

Early preparation will not only facilitate meeting NIS2 requirements but also contribute to overall strengthening of the organization’s cybersecurity position, which is crucial in the face of growing cyber threats.

In summary, although NIS2 will formally become effective in Poland from October 2024, the process of adapting to its requirements should begin much earlier. Organizations that proactively approach this challenge will be in a better position not only to meet regulatory requirements but also to effectively protect themselves against increasingly advanced cyber threats.

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