Who needs to prioritize NIS2 implementation?

The NIS2 Directive applies widely across the EU to both industrial and non-industrial organizations, as well as their suppliers, operating in critical sectors such as healthcare, energy, transport and logistics, and public administration. If your company delivers essential services or plays a key role in the supply chain for these sectors, you are likely within scope.

Not sure if NIS2 applies to you? Use the DataGuard NIS2 Checker to get clarity and take the right next steps.

In Germany alone, approximately 30,000 businesses are expected to fall under NIS2 compliance. Organizations are categorized under NIS2 into two primary groups based on their sector and size: important entities and essential entities, with essential entities subject to stricter compliance obligations.

The thresholds for the size of affected companies vary depending on the sector and fall into two categories: either 50 employees (or annual revenues above €10 million), or 250 employees (with annual revenues exceeding €50 million and a balance sheet total above €43 million). 

NIS2 applies to entities operating within sectors of high criticality, including: 

• Energy
• Transport
• Banking
• Financial market infrastructure
• Health (including manufacture of pharmaceutical products)
• Water supply
• Digital infrastructure
• Public administration
• Space  

In addition to these, NIS2 also affects organizations in other critical sectors. These include: 

• Food  
• Postal and courier services
• Chemicals
• Manufacturing
• Digital providers
• Research organizations
• Waste management 

Key requirements of NIS2  

Before you can implement NIS2 effectively, you need a clear understanding of its requirements. The directive sets out concrete, actionable measures, including:

• Governance and leadership: Management must actively oversee the organization's cybersecurity strategy and explicitly approve relevant measures. Under NIS2, executives can be held personally accountable if these responsibilities aren’t fulfilled.  
• Awareness and training: Employees must receive regular training to identify and respond to cybersecurity threats. Management also requires targeted training to fulfill their oversight responsibilities. 
• Risk management: Organizations must conduct thorough risk assessments and implement appropriate measures to prevent and manage cybersecurity incidents. This includes securing your supply chain, protecting sensitive data, and ensuring operational continuity. 
• Incident reporting: Significant security incidents must be reported to the relevant authority within 24 hours of becoming aware. Organizations will also need to register with an official incident reporting platform once national laws go into effect. 

Supervision of compliance with these requirements depends on your organization’s classification. Important entities are monitored after incidents occur or when there’s evidence of non-compliance, while highly critical entities face proactive, regular audits by national authorities. Failure to meet the requirements can lead to severe penalties of up to €10 million or 2% of global annual turnover for essential entities. 

Key steps for NIS2 implementation 

Implementing NIS2 may seem complex at first, but successful NIS2 implementation doesn’t need to be difficult. With a structured, step-by-step approach, you can turn it into a manageable process that strengthens your security posture and ensures long-term compliance. 

1. Define clear responsibilities 

A successful NIS2 implementation starts with clear ownership. Assign formal responsibility for compliance to individuals or teams with the authority and capacity to lead the effort. These roles need to be clearly defined and fully supported. Make sure those responsible have the time, tools, and training to stay up to date with evolving requirements, oversee security controls, coordinate audits, and manage incident response.

When accountability is established early, staying on track and demonstrating compliance becomes much easier. If internal resources are limited, consider bringing in external advisors and using automation tools to reduce manual workload and save time.

2. Integrate cybersecurity into leadership and governance

Under NIS2, executives are expected to take an active role in overseeing security strategy and can be held accountable for compliance failures. Set aside time to align leadership on their responsibilities, including risk oversight, incident reporting, and resource planning.

Make cybersecurity a regular part of your company’s risk management process, alongside financial and legal topics. Document how decisions are made, who approves policies, and how performance is tracked. When leadership is fully engaged, it becomes easier to secure support, allocate the right resources, and maintain accountability.

3. Assess your current security posture

To build a strong foundation for NIS2, you must first evaluate your current security setup. Begin by auditing your existing security controls across infrastructure, applications, internal processes, and employee behavior. Go beyond technical checks to include administrative policies, incident response readiness, and visibility into your supply chain.

Use recognized frameworks like ISO 27001 to benchmark your current posture. While you may already have many measures in place, there are likely gaps in areas such as documentation, continuous monitoring, or third-party risk management. Prioritize improvements based on business impact and risk exposure. Keep detailed records of your findings and decisions, as auditors and regulators expect clear evidence of your approach.

4. Conduct a risk assessment and prioritize improvements

NIS2 requires more than just ticking boxes. It calls for a risk-based approach, where you can clearly show how you identified threats, evaluated their likelihood and impact, and selected the proper mitigation measures. Use structured tools such as risk matrices to guide your process.

Consider a wide range of risks, including threats like ransomware and data breaches, and business disruptions in your supply chain. For each risk, assign clear ownership and document your decisions. A roadmap with timelines will help you keep your implementation focused and on track.

5. Implement an ISMS (Information Security Management System)

An Information Security Management System (ISMS) is more than a set of policies. It’s an ongoing process for managing and improving your organization’s security posture. An ISMS aligned with ISO 27001 already covers around 70% of NIS2 implementation requirements, making it a strong foundation for compliance.

A digital ISMS brings structure and transparency to your security efforts. It reduces manual effort, keeps documentation up to date, and ensures consistency across teams.  

6. Run regular security audits

You need to validate your controls regularly. Schedule audits at least once a year, including control testing, documentation review, and clear follow-up on any issues found. Use findings to refine your ISMS.

Track all audit activity in a central system, with timestamps, owners, and resolution status. If you get audited by your national authority, you’ll need to show this audit trail. Audits are not just about catching problems. They’re how you demonstrate active, ongoing compliance.

7. Establish an incident reporting workflow

NIS2 introduces strict timelines: significant incidents must be reported to the relevant authority within 24 hours of becoming aware of them. To meet this deadline, you need a straightforward, structured process. Start by defining what qualifies as a reportable incident, such as data loss, unauthorized access, or service disruption.  

Outline the complete response workflow, including investigation steps and regulator notification. Set up a triage system with severity levels, escalation paths, and pre-approved templates to speed up communication. Regular simulations ensure your team can respond quickly and stay compliant under pressure. If a breach occurs, the first few hours are critical, and hesitation can lead to non-compliance.

8. Deliver continuous security training to all employees

NIS2 compliance relies not just on technology but on people. Every employee plays a role in protecting your organization. Develop a training program that covers key topics like phishing, password hygiene, incident reporting, and data handling.

Track participation, test knowledge retention, and keep content up to date with evolving threats. A well-informed team reduces risk and strengthens compliance, and regulators will expect to see proof that training is ongoing.

9. Assess and monitor your supply chain

Under NIS2, you are responsible for the security risks introduced by your vendors. Evaluate each vendor’s security posture through questionnaires, certifications, or independent assessments. Update contracts to include requirements for data protection, incident reporting, and audit rights.

Where appropriate, ask critical suppliers to meet NIS2 or equivalent standards. Review vendor performance regularly and ensure you have contingency plans in place. Managing supply chain risk is essential to meeting NIS2 expectations and protecting your service delivery.

10. Document every decision and control

Thorough documentation is a core part of NIS2 compliance. This includes policies, risk assessments, training records, audit logs, incident reports, and vendor evaluations. A centralized system with version control helps keep everything organized and accessible.

Link your internal documentation to specific NIS2 requirements so you can respond efficiently to audits or reviews. Assign clear ownership to keep records current and consistent. Well-maintained documentation supports transparency, simplifies reporting, and helps demonstrate that your security program is actively managed.

11. Automate where possible

Manual processes don’t scale well, especially as your organization grows. Use security and compliance platforms to automate risk tracking, policy creation, and reporting. It improves consistency, saves time, and supports scalability. 

What are the consequences of NIS2 non-compliance?

NIS2 not only introduces stricter cybersecurity standards but also increases the consequences of falling short. Organizations that fail to meet their obligations face serious financial and legal risks.

Fines depend on an organization’s classification and the severity of the breach:

• Essential entities can face penalties of up to €10 million or 2% of global annual revenue, whichever is higher
• Important entities may be fined up to €7 million or 1.4% of global annual revenue

Under NIS2, responsibility extends to the executive level. Senior leadership is expected to oversee cybersecurity efforts and ensure proper controls are in place. If a breach occurs due to negligence, leadership must be able to demonstrate that reasonable steps were taken. Without that evidence, legal liability becomes a serious concern.

NIS2 also requires leadership to stay engaged and ensure cybersecurity is actively managed across the organization. Policies alone aren't enough; regulators expect ongoing involvement and clear accountability.

Using the right tools can make this process more manageable. Automation supports monitoring, reporting, and documentation, helping your team stay efficient and audit-ready without additional overhead.

How to avoid common NIS2 implementation mistakes

When starting your NIS2 implementation, it’s easy to run into avoidable problems. A clear strategy and the right tools can help you avoid common pitfalls and keep your implementation on track:

• Relying too heavily on manual work: Manual work often seems manageable at first, but it quickly becomes a bottleneck. It slows progress and makes it harder to scale or maintain accuracy
• Using disconnected tools: A fragmented security stack leads to gaps in visibility and coordination. Without integration, implementation across systems becomes more difficult
• Lacking the right expertise: NIS2 comes with specific requirements. If your team doesn’t have the right knowledge, implementation can stall or go off track
• Taking a reactive approach: NIS2 expects continuous monitoring, not one-time checks. A reactive mindset won’t meet the standard. You need to build proactive processes from the start

Effective implementation isn’t just about ticking boxes. It’s about building systems that are sustainable, efficient, and audit-ready. Avoiding these early mistakes strengthens your team and makes long-term compliance much easier to maintain.

Simplify your NIS2 implementation with automation

Automation can significantly reduce the effort needed to meet NIS2 requirements. By integrating the right tools early on, you can streamline processes, improve consistency, and gain real-time visibility across your infrastructure.

Three steps to automate your NIS2 implementation process

These three steps will help you integrate automation into your implementation plan from the start:

1. Use a unified platform for security and compliance

Choose tools that consolidate pen testing, risk assessments, and compliance tracking. Look for platforms that support continuous monitoring rather than periodic checks so you maintain complete visibility at all times.

2. Automate reporting and documentation

Automated reporting helps generate audit-ready logs and compliance records with minimal manual input. This improves accuracy, saves time, and ensures you're always prepared for a review.

3. Monitor risk continuously and in real-time

Set up real-time alerts and use analytics to detect threats early. This allows your team to respond quickly and prevent issues before they affect your compliance status.

Advantages of an automated NIS2 implementation process

Here’s what your business gains by automating critical parts of NIS2 implementation early on:

Real-time vulnerability detection: Automated security tools continuously scan your systems for vulnerabilities and compliance issues, helping you stay aligned with NIS2 requirements.

Reducing human error: Manual processes often lead to mistakes, from incomplete documentation to inconsistent control implementation. Automation removes that risk by standardizing the processes and applying policies consistently across every department.

Ongoing oversight of third-party risk: NIS2 requires organizations to closely monitor their supply chain. Automated tools help you monitor vendor risk in real-time and ensure partners meet required standards.

Start your NIS2 journey now 

The NIS2 Directive is more than a legal obligation. It’s a chance to strengthen your cybersecurity strategy and build long-term resilience. With DataGuard’s step-by-step approach and automation features, you can prepare efficiently for the new regulation and increase your organization’s resilience against cyber threats.

With enforcement deadlines approaching, now is the time to act. Start your NIS2 implementation with a straightforward, structured process that reduces complexity and supports ongoing compliance. Together, we’ll strengthen your security posture and help future-proof your organization.