General Counsel

Apr 24, 2025

5 min. read

NIS2 directive regulations and implementation in Finland

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NIS2 directive regulations and implementation in Finland

The moment I saw the scope of the Cybersecurity Act 124/2025—Finland’s legislative transposition of the NIS2 directive—I realized this was more than a simple regulatory update. It’s a reshaping of national cyber resilience, woven tightly with industry obligations, municipal readiness, and executive accountability. For professionals in ICT, compliance, and finance, this law signals a shift from ad hoc preparedness to systemic, verifiable operational resilience.

Without further ado, let me walk you through how NIS2 Finland implementation is unfolding, what’s expected of organizations, and what timelines, penalties, and sector-specific duties are already in motion.

Understanding the scope and legal structure

Finland has moved swiftly in implementing the Directive (EU) 2022/2555 on measures for a high common level of cybersecurity across the Union, commonly known as NIS2. The Finnish transposition came in the form of the Cybersecurity Act (Kyberturvallisuuslaki), approved as Act 124/2025. It replaces earlier NIS-1 provisions and integrates aspects of the Critical Entities Resilience (CER) directive for a more holistic regulatory reach.

The Act expands the scope dramatically, increasing the number of covered entities from around 1,100 under NIS-1 to approximately 5,500. It now includes mid-sized manufacturers and all municipalities with more than 50,000 residents.

Entities are categorized as either välttämättömät toimijat (essential entities) or tärkeät toimijat (important entities), depending on employee count and turnover thresholds. Notably, digital infrastructure providers (like DNS services and cloud platforms) fall under the law regardless of size.

Classification criteria under Cybersecurity Act 124/2025

CategoryCriteriaExamples
Essential entities≥250 employees or ≥€50 million turnoverTelcos, large hospitals, LNG firms
Important entities≥50 employees or ≥€10 million turnoverMid-sized manufacturers, MSPs
Mandatory coverageRegardless of size (sector-specific)DNS, trust services, cloud
Public sector (essential but exempt from fines)Based on population ≥50,000 or role in critical infrastructureMunicipalities, ministries

The implementation timeline and legal milestones

Finland’s legislative path to NIS2 implementation has been both transparent and rapid. After a consultation period in mid-2024, the law progressed steadily through Parliament and will formally enter into force in July 2025. However, the compliance journey for organizations spans into 2026.

Finland NIS2 implementation timeline

DateMilestoneStatus
6 Jun 2024Consultation draft publishedCompleted
31 Aug 2024Consultation closed (87 statements received)Completed
9 Oct 2024Government Bill submitted to Parliament (HE 208/2024 vp)Completed
14 Feb 2025Parliamentary approval (169 yea / 11 nay)Completed
7 Mar 2025Promulgation of Act 124/2025Completed
1 Jul 2025Law enters into forceUpcoming
30 Sep 2025Deadline for entity registrationUpcoming
31 Mar 2026Deadline for full compliance for essential entitiesUpcoming

To review the full legislative text, visit the official Finlex database.

Supervisory architecture and enforcement

The National Cyber Security Centre Finland (NCSC-FI), under Traficom, has emerged as the central authority. It issues common regulations and manages incident reporting, while sectoral supervision remains with existing regulators like Energiavirasto (Energy Authority) and the Financial Supervisory Authority (FSA).

The incident reporting ladder mirrors EU norms: an early alert within 24 hours, a detailed report within 72 hours, and a final investigation report within 30 days. This applies to both essential and important entities. However, public entities are not subject to monetary fines, although they must comply and may face corrective orders.

Fines, sanctions, and management responsibility

The stakes are high. For essential entities, failure to comply can result in fines of up to €10 million or 2% of global turnover, whichever is greater. For important entities, the ceiling is €7 million or 1.4%.

Executives are not off the hook either. Directors must approve and periodically review the organization’s cybersecurity program. Continued negligence may even trigger disqualification under the Companies Act.

Sanctions and enforcement mechanisms

Type of entityMax fineEnforcement stagesBoard responsibility
Essential€10M / 2% turnoverWarning → corrective order → daily fine → suspensionCyber programme approval
Important€7M / 1.4% turnoverSame as above, minus license suspensionLiability applies similarly
Public SectorNo finesCorrective orders; possible State Audit Office reviewStill subject to requirements

For background, see Traficom’s official cybersecurity page.

Sector-specific impacts

Each industry faces unique obligations under Finland’s NIS2 directive. For example, digital infrastructure providers are now essential entities regardless of their size, while healthcare organizations must implement ISO 27001 governance and conduct regular backup drills.

Finance sees an overlap with the Digital Operational Resilience Act (DORA), meaning banks and insurers must navigate both frameworks—potentially facing cumulative penalties for non-compliance.

Sector-specific changes under Finland NIS2 implementation

SectorNew obligations
ManufacturingAnnual red-team tests, OT/IT segmentation, supply-chain audits
Energy & utilitiesKPI reporting, continuous monitoring, SBOM exchange
HealthcareISO 27001, 24 h reporting, quarterly drills
Digital infrastructure24×7 SOC in EU, zero-trust plan, critical vendor register
FinanceDual reporting with DORA, penetration testing, ICT criticality assessment
Public adminAppoint CISO, comply with reporting rules, adopt Traficom baseline

What companies should know right now

Organizations should start by using NCSC-FI’s self-assessment tool, currently in beta, to determine whether they are classified as essential or important. By the end of September 2025, all relevant entities must register their Y-tunnus (business ID), industry classification (TOL code), and a cybersecurity contact person.

Compliance preparation includes gap analysis against Article 21 controls, creating an incident response standard operating procedure, and briefing the board to formally adopt a cyber programme.

Many organizations may benefit from the certification fast-track, where possessing ISO 27001 or Finnish Katakri Level IV accreditation counts as partial compliance. However, this only reduces the burden—it does not eliminate it.

Are you prepared for the next incident?

The Finland NIS2 directive isn’t just a regulation—it’s a call to rethink how cybersecurity is embedded into business governance. With broad industry impact, firm deadlines, and board-level responsibility, the NIS2 Finland transposition demands urgent attention.

While the road to March 2026 may seem long, proactive preparation now is what separates resilience from reaction. If your organization hasn’t already started evaluating its exposure, now is the time. Because come July, compliance stops being optional—and becomes enforceable.

For official tools and templates, consult the NCSC-FI’s implementation hub.

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General Counsel

He is regulatory compliance strategist with over a decade of experience guiding fintech and financial services firms through complex EU legislation. He specializes in operational resilience, cybersecurity frameworks, and third-party risk management. Nojus writes about emerging compliance trends and helps companies turn regulatory challenges into strategic advantages.
  • DORA compliance
  • EU regulations
  • Cybersecurity risk management
  • Non-compliance penalties
  • Third-party risk oversight
  • Incident reporting requirements
  • Financial services compliance

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