The NIS2 Implementation Act significantly expands European IT security regulation. Since 01.01.2026, not only traditional operators of critical infrastructures have been subject to the requirements, but also a significantly larger number of companies from industry, IT, logistics, energy, healthcare and other sectors.
For many organizations, this raises the serious question of whether and to what extent they are affected by regulation. At the same time, the public debate is often characterized by exacerbation. High fines, tight reporting deadlines and the personal liability of management dominate perceptions.
What will actually change with NIS2
NIS2 is not a completely new idea. The aim remains to increase the resilience of companies to cyber risks and reduce systemic risks. What is new above all is its binding nature. Among other things, the directive requires
- structured risk management
- Measures to safeguard the supply chain
- Clearly defined responsibilities
- Regular training courses
- Defined processes for reporting security incidents
This shifts the focus away from selective technical measures towards verifiable structures and processes. Security is increasingly seen as a management task.
The role of company management is particularly relevant here. NIS2 explicitly anchors responsibility at management and board level. Decisions on security measures must not only be made, but also comprehensibly justified and documented.
Not everything is new
In practice, however, it is clear that many requirements do not start from scratch. Many companies already have security concepts, risk assessments or compliance structures in place. The challenges often lie less in a lack of measures than in a lack of clarity.
Typical questions are:
- Which requirements are actually relevant for our company?
- Where are there real gaps and where are there not?
- Which existing processes can be used or further developed?
NIS2 does not demand perfection, but appropriateness. It is crucial that risks are identified, prioritized and systematically addressed.
Why 2026 is not a year for quick fixes
The temptation to “tick off” NIS2 with short-term measures or individual tools is great. This is precisely where the risk lies. Individual measures without an overarching structure rarely lead to sustainable compliance. It makes more sense to use NIS2 as an opportunity to review existing assumptions:
- Are responsibilities clearly defined
- Are there transparent decision-making processes
- Is it comprehensibly documented why certain measures were taken or not taken
From a regulatory perspective, it is not only the result that is relevant, but also the path to it.
The three big questions that decision-makers should ask themselves at the start of 2026:
Am I affected by NIS2?
Not every company automatically falls under NIS2. The first step is to properly classify how you are affected.
What is NIS2 relevant for us?
The guideline is deliberately formulated to be open to all technologies. Not every requirement has the same significance for every company.
Where is there an actual need for action on NIS2?
There is often a difference between a formal gap and a real risk. Prioritization is crucial.
The role of the SRC
In this area of tension between regulation, risk and implementation, inspection bodies such as SRC play an important role. They help to classify requirements, evaluate existing structures and make the need for action transparent.
The added value here does not lie in the introduction of certain technologies, but in the structured preparation of decisions. Which risks are acceptable, which are not. Where are measures appropriate, where are they excessive. And how can decisions be documented in a comprehensible manner.
Especially in the context of NIS2, this ability to categorize becomes crucial.
Conclusion
NIS2 does not mark a sudden change, but rather a consistent further development of regulatory requirements. For companies, this means less panic, but more responsibility.
2026 will therefore be less a year of quick solutions and more a year of structural decisions. Those who address the impact, relevance and priorities now will create a resilient basis for regulatory certainty and the ability to act as a business.
