When Italy formally enacted its updated cybersecurity legislation in October 2024, the impact rippled far beyond IT departments. I remember the buzz around Legislative Decree n. 138—dubbed the “Decreto NIS”—not just for its breadth, but for its signal: digital operational resilience had graduated from a technical ideal to a legal imperative. As the EU’s NIS2 directive reshapes cyber governance across member states, Italy’s transposition brings sweeping changes that extend well beyond critical infrastructure. Medium-sized manufacturers, public administrations, and cloud providers are all now in scope.
This article unpacks the key elements of the Italy NIS2 implementation, including the legislative timeline, industry impact, new compliance expectations, and how companies can act proactively.
Key takeaways from Italy’s NIS2 journey
Italy’s transposition of the NIS2 directive is now legally binding under Legislative Decree 138/2024. The Agenzia per la Cybersicurezza Nazionale (ACN) leads the enforcement effort, extending obligations to over 12,000 entities—up from fewer than 1,000 under the prior NIS1 framework.
The following table summarizes where things currently stand.
Overview of NIS2 Italy transposition status (April 2025)
| Theme | Status description |
| Transposition law | Decree 138/2024 fully implements NIS2 and repeals previous 2018 legislation. Effective from 16 Oct 2024. |
| Timeline | Key milestones span Feb 2024 – May 2025, including self-assessments, registrations, and nominations of cyber contacts. |
| Scope expansion | Coverage expands from ~900 to ≈12,000 entities, affecting sectors such as manufacturing, health, public administration, and digital services. |
| Entity classification | Soggetti essenziali (EE) and soggetti importanti (EI), based on staff and turnover thresholds. |
| Sanctions | Fines up to €10 million or 2% of turnover (EE), and €7 million or 1.4% (EI). ACN enforces in stages. |
| Reporting obligations | Pre-alert in 24 hours, full report in 72 hours, and final report within a month to CSIRT-Italia. |
| Lead authority | ACN acts as the national NIS authority, working with CSIRT-Italia and sector regulators. |
| Public sector scope | Applies to all central ministries, regions, and cities over 50,000 residents. Subject to corrective orders, not monetary fines. |
As the legal foundation settles, attention now turns to deadlines.
Important dates and compliance milestones
Italy’s legislative process for NIS2 Italy transposition began with Delegation Law 15/2024, giving the government authority to draft and implement the EU directive. Since then, several regulatory and procedural deadlines have shaped the compliance landscape.
The table below captures this evolving timeline:
TItaly NIS2 directive implementation timeline
| Date | Milestone | Status |
| 17 Jan 2023 | NIS2 enters into EU law | Completed |
| 21 Feb 2024 | Law 15/2024 published, authorizing transposition | Completed |
| 27 Aug 2024 | Draft decree submitted to Parliament | Completed |
| 4 Sept 2024 | Decree 138/2024 adopted | Completed |
| 1 Oct 2024 | Publication in the Official Gazette | Completed |
| 16 Oct 2024 | Decree comes into force | Completed |
| 9 Dec 2024 | DPCM 221/2024 defines safeguard clause and exclusions | Completed |
| 31 Dec 2024 | Deadline for entity self-assessments | Upcoming |
| Jan–Feb 2025 | Online registration on ACN portal | Upcoming |
| 31 Mar 2025 | Publication of essential and important entity list by ACN | Upcoming |
| 15 Apr 2025 | Cyber responsible contact to be nominated | Upcoming |
| 31 May 2025 | First round of risk assessments and additional data submissions | Upcoming |
With this structured roadmap, the onus now falls on organizations to prepare for significant operational changes.
Structure and responsibilities under the Italian decree
Italy’s NIS2 Italy directive transposition introduces both new governance responsibilities and stricter risk-management requirements. These are divided across six parts of the decree.
Key content in Decreto NIS structure
| Part | Content overview |
| Capo I | Definitions, entity criteria, sector codes (ATECO alignment). |
| Capo II | National governance; ACN confirmed as lead authority and EU liaison. |
| Capo III | Risk management obligations: MFA, supply-chain security, policies, and continuity planning. |
| Capo IV | Incident reporting: 24-hour alert, 72-hour full report, one-month follow-up. |
| Capo V | Enforcement mechanisms: inspections, audits, and orders. |
| Capo VI | Sanctions: fines, certifications suspension, mitigation factor considerations. |
The decree also includes coordination clauses ensuring alignment with Perimetro di Sicurezza Nazionale Cibernetica (PSNC), avoiding redundancy between legal regimes.
Sanctions, liability, and enforcement mechanics
The ACN uses a progressive enforcement model, starting with corrective orders before levying fines. For soggetti essenziali, fines can reach €10 million or 2% of global turnover. For soggetti importanti, the ceiling is €7 million or 1.4%.
Executives are not immune. Failure to adopt proper cybersecurity strategies may trigger civil liability and removal orders by regulators. While public administrations can’t be fined, they face binding remediation demands and reputational exposure through public disclosures.
Sector-specific impacts and expectations
The expansion of scope under Italy NIS2 implementation is most visible in sectors previously outside or only loosely covered by NIS1. Medium-sized manufacturers, biomedical labs, and regional governments are now directly impacted.
Sector impact of Italy’s NIS2 directive
| Sector | Change vs. NIS1 | New obligations and challenges |
| Manufacturing | Newly regulated if ≥ 50 FTE or €10m turnover | Risk audits, segmentation of OT/IT, playbooks, board engagement |
| Energy and utilities | Scope extended to medium DSOs, LNG, district heating | Full cyber programs, vulnerability disclosures, faster incident reporting |
| Health | Coverage now includes all medium-large hospitals | Governance aligned with ISO 27001, clinician awareness, joint audits with Health Ministry |
| Digital infrastructure | Now includes all providers regardless of size | 24/7 SOC, SBOMs, advanced monitoring, SecNumCloud-level controls |
| Financial services | DORA is lex specialis, NIS2 applies to infrastructure | TLPT every 3 years, vendor risk concentration policies |
| Public administration | All large municipalities in scope | Appoint cyber lead, adopt ACN’s security controls; no fines but binding orders |
ACN projects one-off compliance costs between €1 billion and €1.8 billion but anticipates funding synergies with EU digital programs.
What companies in Italy should focus on
Italian organizations must treat the Italy NIS2 directive as more than regulatory compliance—it’s a strategic imperative. Entities should immediately assess cyber maturity against Article 21 controls and initiate governance alignment.
Immediate actions for Italian organizations
| Priority area | Description |
| Self-assessment | Must be completed by 31 Dec 2024; key to determining classification (EE or EI). |
| Registration | Entities must register on ACN’s platform between Jan and Feb 2025. |
| Reporting SOPs | Draft and test response plans for 24 h/72 h/1-month incident reporting. |
| Executive accountability | Nominate a board-level cyber contact and prepare for mandatory training sessions. |
| Framework alignment | Consolidate compliance with GDPR, PSNC, and other cybersecurity programs to streamline obligations. |
Early engagement with ACN and sector regulators can uncover sector-specific nuances, mitigate risks, and reduce long-term compliance costs.
Is your organization ready for Italy’s new cyber frontier?
The road to full NIS2 compliance in Italy is both clear and complex. What stands out is not just the breadth of sectors affected, but the depth of responsibility introduced—from top-level board accountability to highly structured reporting and governance. Organizations that approach this strategically, by embedding cybersecurity into their culture and structure, will not only avoid penalties but position themselves for resilience in an increasingly digital economy.
Whether you’re in aerospace, energy, or municipal government, the time to act is now. Italy has defined the path—how you walk it is up to you.
