The Directive on measures for a high common level of cybersecurity across the EU (NIS2, Tracker) aims to increase the level of cyber resilience across the EU. It does so by requiring all entities in the EU that provide critical services (e.g. energy, telecoms, cloud) to take appropriate cybersecurity measures.

Cullen International released a series of reports comparing how different aspects of NIS2 have been transposed by EU countries. 

Request more information & access to the NIS2 report series

Transposition of the NIS2 Directive

Part 1: Transposition status of the NIS2 Directive

Cullen International is tracking and comparing the progress made by the 27 EU member states in transposing the NIS2 Directive.

Member states had until 17 October 2024 to transpose the directive. However, as of October 2025, 15 countries (Belgium, Croatia, Cyprus, Czech Republic, Denmark, Finland, Greece, Hungary, Italy, Latvia, Lithuania, Malta, Romania, Slovakia and Slovenia) have adopted national legislation to transpose NIS2.

Part 2: Entities in scope and authorities that oversee compliance

The Benchmark shows whether the scope of national transposition rules differs from that of NIS2, and maps competent authorities for sectors such as digital infrastructure (including telecoms), digital providers and ICT service management.  


In nine of the surveyed countries, the telecoms sector would be supervised by the national regulatory authority (NRA).

Part 3: Security risk-management and incident reporting requirements

Cullen International surveys differences in how the NIS2 transposition measures in 18 EU countries address cybersecurity risk-management and incident reporting requirements. 

The Benchmark shows that most of the countries surveyed have not introduced cybersecurity requirements beyond NIS2, except for Belgium and Poland. The Benchmark also shows that:
  • Belgium, Germany, and Portugal provide references to international standards or other instruments to demonstrate compliance with NIS2 requirements; and
  • Portugal and Romania have introduced reporting requirements that go beyond those set out in NIS2.

Part 4: Enforcement

In cases of non-compliance with NIS2 obligations, national competent authorities may impose administrative fines and other penalties. Cullen International tracks the enforcement regimes established under NIS2 transposition laws in 18 EU countries. 

The Benchmark covers applicable maximum fines, whether members of management bodies and public sector authorities may be subject to administrative fines, and other types of penalties beyond administrative fines.
  • In Belgium and Italy, NIS2 maximum fines can be doubled (or even tripled in Italy) in the event of a repeated violation. taly) in the event of a repeated violation. 
  • In six countries, members of management bodies can be fined for non-compliance, while in most of the countries observed public administration entities are subject to fines like other NIS2 entities.
  • In addition, five EU countries could impose additional penalties to enforce compliance with NIS2 obligations.enalties to enforce compliance with NIS2 obligations.

All you need to know about the new NIS2 Directive 

Cullen International provides a detailed overview of the requirements and obligations under the NIS2 Directive, including the cybersecurity risk-management measures and incident reporting obligations.

Part 1: Scope

The revised directive classifies the entities covered into those which are considered essential and those which are important. As a rule, all medium and large size entities will have to comply with the NIS2 security risk management and reporting rules. However, the directive will adjust the classification as being either essential or important depending on the size of the entity.


The first of five reports covers the objectives and scope of the revised directive and explains the applicable rules to classify entities as either essential or important. 

Part 2: Common security risk management and reporting requirements

The revised EU directive on the security of network and information systems (NIS2) sets baseline security risk management measures for all the entities operating across the sectors falling within its scope. The directive applies an “all-hazard” approach, thus the risk management measures should also address physical and environmental security (e.g. natural disasters, system failures). 


Our second of five reports provides an analysis of the common security risk management and reporting requirements, which apply to all essential and important entities covered by the revised directive.

Part 3: Specific obligations for the telecoms, ICT supply chain and digital sectors

The revised EU directive on the security of network and information systems (NIS2) imposes on critical entities (e.g. cloud providers, data centres, social media platforms) common security risk management and reporting requirements. Importantly, the NIS2 will also regulate the security of telecoms operators when providing both telecoms related services (e.g. mobile services) and non-telecoms services (e.g. cloud). 


Our third of five reports covers certain security obligations which apply specifically to the telecoms, ICT supply chain and digital sectors.

Part 4: Supervision and jurisdiction 

The revised EU directive on the security of network and information systems (NIS2) subjects essential and important entities to the same security risk management and reporting requirements. However, they differ based on supervision.


Our fourth of five reports outlines the supervisory and enforcement framework laid down by the NIS2 directive.

​Request 
one of our 
NIS2 reports  

To request one of our NIS2 reports and/or a demo of our Digital Economy intelligenceplease just complete the below form.

(Note: Our services are predominantly designed for the use of government entities, regulators, communications service providers or manufacturers. We reserve the right to offer access to our research only to selected organisations. Feel free to contact us if you have any question regarding your eligibility for free extracts or a demo.) 

Who? 

Founded in Brussels in 1986, we’ve built our reputation on our expertise and neutrality, as well as the ability to convey complex information in a concise way. This has won us the trust of customers in over 90 countries.
Discover how we make regulation simple

Don't miss any regulatory news

Subscribe to our newsletter!

Sign up!

Contact Us

Cullen International Brussels office

Clos Lucien Outers 11-21/1

1160 Brussels

Belgium


Phone: +32 2 738 72 00

Email: discover@cullen-international.com


Privacy

Terms


Cullen International - Copyright ©2025