General Counsel

Apr 23, 2025

5 min. read

NIS2 directive regulations and implementation in France

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NIS2 directive regulations and implementation in France

When I first stumbled across the term “Loi Résilience,” I assumed it was just another cybersecurity reform making the rounds in legislative halls. But as I dug deeper, it became clear that France’s approach to implementing the NIS2 directive isn’t just comprehensive—it’s ambitious, strategic, and deeply transformative. This article dives into the country’s sweeping legislative rollout that brings NIS2, the CER Directive, and DORA under one roof, fundamentally reshaping the cybersecurity landscape for thousands of French entities.

Let’s unpack the key changes, sector impacts, enforcement measures, and what companies need to do to stay ahead of compliance deadlines under the evolving france NIS2 directive regime.

Key take-aways from France’s NIS2 strategy

France is moving forward with a bundled legislative approach under the “Projet de loi Résilience des infrastructures critiques & renforcement de la cybersécurité,” also known as “Loi Résilience.” It’s an all-in-one law that transposes not only the NIS2 directive but also the Critical Entities Resilience (CER) Directive and the Digital Operational Resilience Act (DORA).

The scope has exploded—shifting from about 500 entities under the original NIS1 to over 10,000 under NIS2 France, including local governments and universities. Entities are classified as either entités essentielles (EE) or entités importantes (EI) based on thresholds like employee count and turnover, with some entities listed regardless of size.

Here’s a snapshot of the regulatory transformation underway:

Key regulatory developments under Loi Résilience

ThemeDetails
Scope~10,000+ entities across 18 sectors; includes local authorities, universities
ClassificationEE: ≥ 250 FTE or €50M; EI: ≥ 50 FTE or €10M; some sectors size-agnostic
Lead authorityANSSI manages registration, audits, and enforcement
SanctionsEE: up to €10M / 2% turnover; EI: €7M / 1.4%; public entities exempt from fines
ReportingEarly warning: 24h, Update: 72h, Final: 1 month via Mon Espace NIS2
Implementation bodyNew multi-ministerial “Commission des sanctions” handles penalties

This comprehensive framework signals a new era for cybersecurity governance in France. And it’s just getting started.

Important timelines and legislative milestones

Although France missed the EU’s official NIS2 transposition deadline of 17 October 2024, it has since accelerated the legislative process. A final vote is expected by summer 2025, with laws entering into force shortly after.

France NIS2 implementation timeline

DateMilestoneStatus
14 Dec 2022NIS2 Directive published in EU Official JournalCompleted
15 Oct 2024Loi Résilience submitted to Senate with fast-track procedureCompleted
4 Mar 2025Senate special committee report (Rapport n° 393)Completed
12 Mar 2025Senate adoption (Texte n° 78)Completed
Q2 2025Debate and vote in National AssemblyOngoing
Late 2025Law promulgated; detailed decrees issuedUpcoming

You can follow updates via the Senate’s dedicated legislative portal for the bill.

Structure and national specificities of the French law

France has uniquely chosen to wrap three major EU cyber directives into a single legislative vehicle, dividing them across separate titles within the Loi Résilience.

Legislative structure of Loi Résilience

TitleContent highlights
Title INIS2 transposition: obligations, classification, ANSSI powers, and reporting
Title IICER Directive: resilience of vital activities, defense code updates
Title IIIDORA: financial sector ICT risks, integrated with existing financial regulations
SanctionsGraduated approach: compliance orders, fines, Commission des sanctions involvement

Among its unique national decisions, France has declared that local authorities with populations over 30,000 and all universities are considered entités essentielles. Meanwhile, fines will not apply to public bodies, though they remain bound by ANSSI’s compliance orders.

Enforcement and sanctions: what’s at stake

The newly established Commission des sanctions is tasked with enforcing the framework, operating with a hybrid team of ministry officials and cybersecurity experts. Sanctions escalate progressively—starting from warnings to orders and ultimately monetary fines for private entities.

Management boards are under pressure to step up: they must now approve and oversee cyber-risk programs, and failure to do so may expose them to civil liability. However, France has deliberately excluded personal fines for executives at this stage.

Industry-specific impacts under NIS2 France

The expanded scope of the NIS2 directive means a wide range of sectors are facing regulation for the first time, while others are seeing enhanced obligations.

Sectoral impact of the France NIS2 directive

SectorImpact overview
Critical manufacturingNewly regulated as EI; must secure OT/IT convergence, supplier risk reviews
HealthcareAll medium-to-large hospitals now EE; must meet tight incident reporting deadlines
Digital infrastructureCloud and DNS providers are EE regardless of size; 24/7 monitoring required
FinanceNow governed by DORA; mandatory TLPT and critical ICT provider oversight
Public administration~300 communes and all regions now EE; subject to binding ANSSI orders
Postal, food, wasteNew entrants under NIS2; expected to implement basic cyber hygiene frameworks

ANSSI projects that total compliance costs may range from €1 to €2 billion over the first three years, but anticipates savings through centralized response teams and standardized compliance frameworks like the “label NIS2”.

How companies should prepare

Whether you’re in manufacturing, healthcare, or digital services, preparation starts with understanding your designation under the new law. France’s Mon Espace NIS2 portal will soon provide self-assessment tools and entity registration forms. Organizations must prepare internal capabilities to respond within the mandated 24/72-hour incident timeline, and begin briefing boards now to document their cyber-risk governance efforts.

Key preparatory steps include:

France NIS2 compliance preparation roadmap

StepAction
Entity classificationUse Mon Espace NIS2 to determine if you are EE or EI
RegistrationSubmit NACE code, key cyber contact via ANSSI portal
Risk assessmentConduct Article 21 gap-analysis across core control areas
Incident responseDevelop internal playbook for 24h early-warning and 72h follow-up
GovernanceEducate and involve board, document risk oversight

Are you ready for the resilience revolution?

France’s implementation of the NIS2 directive is more than a box-ticking exercise—it’s a reshaping of the cyber-risk paradigm for both private and public actors. With wide-reaching implications across nearly every sector, the Loi Résilience is a signal that resilience and accountability are no longer optional.

If your organization operates in France or interacts with French networks, now is the time to assess, adapt, and act. The transition won’t be without its hurdles, but with the right planning and board-level commitment, it’s a chance to build a more secure, transparent digital future.

For detailed updates and guidance, bookmark France’s official NIS2 FAQ page and stay informed as implementing decrees begin to roll out.

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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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