Across the EU and the EEA, countries display varied transpositions of the NIS2 Directive, with the following notable highlights:

• Belgium, Croatia, Cyprus, Slovakia, Finland, Denmark, Greece, Hungary, Italy, Latvia, Lithuania, Malta, Liechtenstein and Slovakia have transposed NIS2. Often this includes additional decrees, amendments or acts. For Romania NIS2 is partially transposed 
• Registration deadlines already passed for a significant number of countries that have transposed NIS2. Organisations that did not register yet, should do so as soon as possible. 
• Security measures of the transpositions can be categorized in three main approaches: either a maturity based national cybersecurity control frameworks, a compliance based control framework or more principle based approach. Most countries define their list of required security controls. 
• Countries such as Croatia, Hungary, Italy and Slovakia extend beyond the sectors mentioned in the Directive and add sectors such as education, defence or culture. 
• Croatia, Cyprus and Lithuania do not require entities to register themselves, instead the government agencies of these countries will identify entities in scope. 
• Most countries align with the reporting schedule of the Directive, however Cyprus imposes a 6-hour early warning for significant incidents instead of the standard 24 hours. Lithuania requires an ‘automated’ incident reporting. 

The Directive’s emphasis on management accountability is clear, with executive boards and managing directors mandated to ensure compliance with risk management measures. Government oversight and audit mechanisms vary. In most countries essential entities require audits by a government accredited auditor. Frequency varies between yearly and every 5 years.

In essence, the transpositions studied showcase important specifics which can have significant impact for organisations operating in these countries. For these organisations, it means closely following up on the transpositions and trying to define a common ground to reach a workable level of compliance. 

Most of the NIS2 laws are expected in 2025, but some only by late 2026. Having a strategic cybersecurity control framework to navigate this evolving regulatory landscape will be important moving forward.