NIS2 guide: what you need to do and by when Your KSC Act obligations as a list of steps. For each one: who does it, the legal basis and the evidence the auditor will ask for.
- 23 steps in five areas
- deadlines up to 3 April 2028
- law as of 20.10.2026
- Organisation and roles0 of 5
- Risk and documentation0 of 4
- Technology and business continuity0 of 5
- People0 of 3
- Incidents, suppliers and audit0 of 6
Timeline of deadlines
For organisations that met the criteria on the day the Act came into force, i.e. 3 April 2026.
- The Act comes into force
The amendment to the KSC Act came into force.
- Entry in the register
The self-registration deadline has passed. What to do after the deadline
- Obligations and S46
ISMS, incidents, contact persons, documentation.
- Training for the head of the entity
The first annual training (FAQ 3.46).
- First audit and penalties
Audit of essential entities. From this date the authority can impose penalties.
Met the criteria later? For example, after exceeding the headcount threshold. You have 6 months to apply for registration, 12 to meet the obligations and 24 for the first audit, counting from that date (Art. 7c, Art. 16, FAQ 2.32, 3.32).
Were you an operator of essential services? You switch to the new incident reporting rules within 6 months of the Act coming into force, and keep your existing audit cycle (Art. 33(4), FAQ 9.5).
Obligations checklist
Tick what you already have. For each step: who does it, the legal basis and the evidence the auditor will ask for.
Organisation and roles0 of 5
Risk and documentation0 of 4
Technology and business continuity0 of 5
People0 of 3
Incidents, suppliers and audit0 of 6
Who is responsible for what
The Act names the head of the entity and the contact persons. The other roles are a proven division of work, which you can also see on the platform.
- Head of the entity
Approves the ISMS and the budget, assigns tasks, completes annual training. Also remains responsible for duties entrusted to others.
Art. 8c–8e · FAQ 4.1–4.4 - ISMS officer or coordinator
Manages risks, documentation, reviews and internal audits. Reports to the head of the entity and prepares decisions.
organisational role - IT and administrators
Technical safeguards, updates, backups, monitoring and first response to an event.
organisational role - Contact persons
Liaison with the CSIRT and the supervisory authority, reports in the S46 system.
Art. 9 · FAQ 3.17, 3.18 - Process owners
Identify important processes and data, accept risks in their area and provide evidence.
organisational role - Security service provider
Can take over some tasks, e.g. as the ISMS officer or SOC. Responsibility stays with the head of the entity.
Art. 14 · FAQ 3.19
Common misconceptions
Each one is settled by the Act or the KSC FAQ.
- “We bought NIS2-compliant documentation, so we’re compliant”
Documentation must describe your organisation and be applied in practice (FAQ 3.7).
- “We must have a SOC”
The Act doesn’t explicitly require a SOC. It requires continuous monitoring and incident handling (FAQ 3.16).
- “The provider will take over responsibility”
Tasks can be entrusted to others, but the head of the entity is responsible for their performance (Art. 8c, FAQ 4.4).
- “Every incident must be reported within 24 hours”
You handle every incident, but report only major ones (FAQ 6.3).
- “The registration deadline has passed, so it’s too late”
You can apply at any time, and the entry is made as soon as you apply (FAQ 2.32, 2.48). What to do after the deadline
- “Penalties only apply from 2028, so we have time”
True for penalties, but obligations apply from 3 April 2027 (Art. 33(1), Art. 35).
Printable checklist
An extended version of the list as a PDF, ready to show to management.
- 23 steps with columns: person, deadline, status, evidence
- deadline calendar and division of roles
- legal basis for every step
We’ll send it to the address you provide.
Thank you, the checklist is on its way. You can also download it here.
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