What is the NIS2 Directive? Your Guide for Compliance in Italy

For CISOs and IT leaders overseeing operations in Italy, the NIS2 Directive (Directive EU 2022/2555) represents a significant paradigm shift in European cybersecurity mandates. This is more than an updated regulation; it’s a robust framework designed to elevate cyber resilience across a broad spectrum of Italian enterprises. Navigating these new, stringent obligations requires a precise understanding of NIS2’s core principles and its specific transposition into Italian national law. Failure to comply can result in substantial financial penalties, severe reputational damage, and critical operational disruptions.

This guide aims to cut through the complexity, providing English-speaking cybersecurity professionals in Italy with authoritative and actionable insights. We will detail NIS2’s overarching purpose, Italy’s unique national implementation process, the types of entities in scope, and the critical cybersecurity requirements you must address to ensure your organisation is not only compliant but genuinely robust against the ever-evolving cyber threat landscape.

The Evolution of EU Cybersecurity: From NIS1 to NIS2

The NIS2 Directive is the successor to the original Network and Information Security (NIS) Directive (EU 2016/1148). While NIS1 laid foundational groundwork for EU-wide cybersecurity, its implementation varied considerably among Member States, and its scope proved insufficient to address modern cyber threats. NIS2 rectifies these shortcomings by:

Expanding Scope: Significantly increasing the number of sectors and entities covered, now including critical industries and digital service providers previously exempt.
Strengthening Requirements: Introducing more rigorous cybersecurity risk management measures and harmonised, stricter incident reporting obligations.
Harmonising Enforcement: Aiming for greater consistency in supervisory mechanisms and the application of penalties across the EU.
Enhancing Supply Chain Security: Placing a strong emphasis on managing cybersecurity risks across the entire digital supply chain.

Adopted in November 2022 and effective since January 16, 2023, NIS2 is designed to achieve a high common level of cybersecurity across the Union, fortifying Europe against increasingly sophisticated and pervasive cyber attacks.

Italy’s National Approach: Transposing NIS2 into Italian Law

As an EU Directive, NIS2 necessitates that each Member State transpose its provisions into national law. In Italy, this process involves integrating the directive’s requirements into the national legal framework, primarily under the guidance and oversight of the Agenzia per la Cybersicurezza Nazionale (ACN), Italy’s national cybersecurity agency. This typically involves the adoption of one or more legislative decrees (decreti legislativi), which are then published in the **Gazzetta Ufficiale della Repubblica Italiana** (Official Journal of the Italian Republic) to officially come into force.

The original EU deadline for national transposition was October 17, 2024, with the transposed provisions applying from October 18, 2024. However, like many other Member States, Italy has faced challenges in fully meeting this stringent deadline. As of September 2025, the legislative work for the NIS2 transposition in Italy is ongoing. This likely involves the finalisation and approval of specific **legislative decrees** which will detail the exact obligations, competent authorities, and enforcement powers for the ACN and other relevant bodies.

This ongoing legislative process does not provide a reason for Italian organisations to delay preparation. The fundamental principles and requirements of NIS2 are clear, and Italian CISOs must proactively align their cybersecurity posture. The ACN’s existing expertise and guidance in national cybersecurity will form the bedrock of Italy’s NIS2 implementation, making engagement with their recommendations paramount for businesses operating in Italy.

Are You in Scope? NIS2 Entity Types in the Italian Context

A critical initial step for any Italian enterprise is to definitively ascertain if it falls within NIS2’s scope and, if so, under which classification. NIS2 primarily targets medium and large entities in designated critical sectors, but also includes certain smaller entities if they are deemed highly critical. Entities are categorised into two main types, affecting the level of supervision and potential penalties:

Entità Essenziali (Essential Entities):
- These are typically larger organisations operating in sectors listed in Annex I of the Directive, considered highly critical to the economy and society. Examples relevant to Italy include major players in the energy sector (e.g., Enel, Snam, Terna), the transport sector (e.g., Trenitalia, Aeroporti di Roma, major port authorities), banking and financial market infrastructures (e.g., Intesa Sanpaolo, UniCredit, Borsa Italiana), healthcare providers (e.g., large public hospitals, major pharmaceutical manufacturers), digital infrastructure providers (e.g., major ISPs like TIM, Fastweb, large data center operators), and public administration at central and regional levels.
- These entities will be subject to stricter supervisory and enforcement measures, including proactive audits and inspections by the ACN or other designated national authorities.
Entità Importanti (Important Entities):
- This category generally covers medium and large enterprises in other critical sectors listed in Annex II. Relevant Italian examples include companies in the manufacturing sector, particularly those involved in critical products like machinery, automotive suppliers, or the highly specialized luxury goods sector. Other sectors include postal and courier services (e.g., Poste Italiane), waste management, and digital providers (e.g., large online marketplaces, search engines, social media platforms).
- While these entities must implement the same cybersecurity risk management measures as Essential Entities, they are typically subject to reactive supervision. This means the ACN or other authorities would intervene primarily after an incident or upon evidence of non-compliance.

Both Essential and Important Entities face substantial fines for non-compliance. Essential Entities can face penalties of up to €10 million or 2% of total worldwide annual turnover (whichever is higher), and Important Entities up to €7 million or 1.4% of total worldwide annual turnover. The ACN, under the transposed Italian law, will have the power to impose these fines.

Organisations must conduct a thorough self-assessment based on their industry, size, and critical service provision. The ACN is expected to provide comprehensive guidance and tools to help Italian entities determine their exact classification once the national decrees are published in the Gazzetta Ufficiale.

Deep Dive: NIS2 Scope & Entity Classification

Core NIS2 Requirements: What Italian CISOs Must Implement

NIS2 Article 21 outlines the comprehensive cybersecurity risk management measures that all in-scope entities in Italy must implement. These measures are designed to be proportionate to the risks faced and the entity’s size. CISOs must ensure their organisations address all of the following:

Policies on risk analysis and information system security: Establish clear strategies for identifying, assessing, and mitigating cyber risks, aligning with ACN’s existing national frameworks and best practices.
Incident handling: Develop robust procedures for detecting, containing, analysing, and responding to cybersecurity incidents, including specific reporting obligations to the ACN.
Business continuity and crisis management: Implement measures like backup management, disaster recovery, and crisis communication plans to ensure continuity of critical services during and after a cyber incident.
Supply chain security: Address cybersecurity risks stemming from your direct suppliers and service providers through due diligence and contractual measures. This is particularly crucial given Italy’s complex industrial ecosystem, including the vital luxury goods and automotive supply chains.
Security in network and information systems acquisition, development, and maintenance: Integrate security throughout the lifecycle of IT systems, including robust vulnerability handling and disclosure processes.
Policies and procedures regarding the use of cryptography and, where appropriate, encryption: Ensure appropriate use of cryptographic solutions to protect data and communications, consistent with national security and privacy regulations.
Human resources security, access control, and asset management: Implement robust measures for personnel security, managing user access to systems and data, and maintaining an inventory of information assets.
Use of multi-factor authentication (MFA) or continuous authentication solutions: Where appropriate, mandate MFA to enhance access security, along with secured voice, video, and text communications, and emergency communication systems.

Beyond these technical and organisational measures, NIS2 also introduces strict incident reporting obligations. Entities will need to notify the ACN of significant cybersecurity incidents within specific timelines (e.g., initial notification within 24 hours of becoming aware, an update within 72 hours, and a final report within one month). The ACN will then coordinate responses and information sharing, leveraging its established national incident management framework.

The Role of the ACN: Italy’s National Cybersecurity Authority

The Agenzia per la Cybersicurezza Nazionale (ACN) is Italy’s central authority for cybersecurity, established in 2021 to strengthen national cyber resilience and capabilities. The ACN plays a critical role in the implementation and enforcement of national and European cybersecurity regulations, and its responsibilities under the Italian NIS2 transposition will be extensive, including:

Guidance and Recommendations: Issuing specific guidelines, recommendations, and best practices tailored to the Italian context to help entities comply with NIS2 requirements. This builds upon ACN’s existing strategic frameworks and national cybersecurity plans.
Supervision and Enforcement: Overseeing the compliance of in-scope entities, conducting audits, requesting information, and imposing administrative fines for non-compliance. The ACN’s powers for critical infrastructure (Organismi Essenziali e Fornitori di Servizi Digitali) will be adapted and extended for NIS2.
Incident Coordination: Acting as the central point of contact for cybersecurity incident reporting, coordinating responses, and sharing threat intelligence nationally and with ENISA.
Vulnerability Management: Supporting vulnerability handling and disclosure processes, leveraging its national expertise.

CISOs in Italy should proactively engage with ACN’s official communications, publications, and guidance, as they will provide the authoritative interpretation of NIS2 requirements under Italian law. The ACN’s strategic importance and technical capabilities make it an indispensable partner in Italy’s cybersecurity landscape.

Critical Deadlines & Staying Compliant in Italy

As noted, while the EU set an initial transposition deadline of October 17, 2024, Italy’s legislative process for NIS2 is ongoing, with the final national decrees and laws expected to be published in the Gazzetta Ufficiale and take full effect in due course. However, this is not a justification for inaction. Proactive preparation is paramount:

Self-Assess Your Scope: Begin by definitively determining if your organisation falls under NIS2 and which entity type (Essential or Important) applies based on Italian industry context.
Perform a Gap Analysis: Compare your current cybersecurity posture and any existing Information Security Management System (ISMS) (e.g., ISO 27001) against the NIS2 requirements (Article 21) and ACN’s recommendations.
Strengthen Core Measures: Prioritise improvements in areas like incident response, supply chain security, and vulnerability management, which are central to NIS2 and already emphasized by the ACN.
Monitor ACN Guidance: Regularly check the ACN’s official website for updates, draft decrees, and specific recommendations regarding the national NIS2 implementation.
Review Contractual Agreements: Ensure your contracts with suppliers and service providers reflect NIS2’s supply chain security demands, potentially requiring specific clauses related to cybersecurity obligations and incident reporting.

The European Commission has already initiated infringement procedures against Member States for failing to meet the transposition deadline. This reinforces the urgency for Italy to finalise its law and for Italian organisations to be ready.

Understand NIS2 Deadlines & National Transposition

How Nistra Automates NIS2 Compliance in Italy

Navigating the evolving NIS2 landscape in Italy, particularly with the ongoing legislative process and the ACN’s detailed requirements, presents a complex challenge. Understanding your exact scope, interpreting the ACN’s comprehensive guidance, conducting a thorough gap analysis, and implementing new controls demands significant expertise and continuous monitoring.

Nistra’s AI-powered platform is specifically designed to streamline and automate your NIS2 compliance journey in Italy. Our NIS2 Compliance Assessment provides a tailored, step-by-step plan based on your organisation’s profile and the specific requirements under Italian law. It continuously monitors legislative updates from the ACN and the EU, cross-references ENISA guidance, and offers intelligent mappings to international standards like ISO 27001, highlighting gaps and suggesting actionable remediation steps.

With Nistra, you can:

Get a definitive determination of your NIS2 scope and entity type under Italian law.
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Eliminate guesswork, reduce manual effort, and achieve demonstrable NIS2 compliance faster and more confidently in Italy.

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Citations:

Directive (EU) 2022/2555 of the European Parliament and of the Council of 14 December 2022 on measures for a high common level of cybersecurity across the Union, amending Regulation (EU) No 910/2014 and Directive (EU) 2018/1972, and repealing Directive (EU) 2016/1148 (NIS 2 Directive). Official Journal of the European Union. L 333/80. (Accessible via EUR-Lex: https://eur-lex.europa.eu/eli/dir/2022/2555/oj)

Agenzia per la Cybersicurezza Nazionale (ACN). Official website and publications. (Refer to https://www.acn.gov.it/ for national decrees, guidance, and strategies relevant to cybersecurity, including references to the Gazzetta Ufficiale.)

European Commission. “Infringement procedures against Member States for non-notification of national transposition measures for NIS2 Directive.” (Refer to official press releases or infringement reports from the European Commission: https://ec.europa.eu/commission/presscorner/home/en)

European Union Agency for Cybersecurity (ENISA). Official website and publications. (Refer to www.enisa.europa.eu for relevant guidance.)