When the EU’s updated cybersecurity directive—NIS2, short for Network and Information Security Directive 2—came into force in January 2023, it signaled a new era of digital resilience across Europe. But as is often the case, translating Brussels’ intentions into national legislation has been anything but simple. Poland’s journey with the directive offers a textbook case of how complex this process can be. With the government now racing against an infringement notice for missing the EU’s October 2024 transposition deadline, the stakes couldn’t be higher.
So where do things stand now, and what should essential and important Polish entities be doing to stay ahead of the curve? Without further ado, let me walk you through the current state of NIS2 implementation in Poland—exploring the regulatory backbone, compliance timelines, enforcement mechanisms, and what it all means for businesses on the ground.
Key takeaways from Poland’s NIS2 path
Unlike several EU peers, Poland isn’t scrapping its existing cyber law. Instead, it’s opting to build upon its 2018 National Cybersecurity System Act (KSC-1) with a significant new chapter—KSC-2. This continuity may simplify adaptation for entities already under the old regime, but it also introduces layers of complexity, particularly as the scope expands from 400 entities to over 10,000.
What makes the Polish approach unique is its extraordinary sanctions cap of PLN 100 million (~€23 million) for incidents affecting national security, and the reclassification of traditionally lower-risk sectors—like general manufacturing—into the “essential” tier.
Before diving deeper, here’s a summary of where things currently stand:
Poland’s NIS2 transposition highlights (as of April 2025)
| Theme | Status |
| Legal instrument | Amendment to KSC-1 (now KSC-2), integrating NIS2 fully |
| Current draft version | 5th consolidated draft (v21), published February 2025 |
| Final government approval | Expected Q3 2025 |
| Parliamentary vote | Targeted for Q4 2025 |
| Entry into force | Early 2026 |
| Registration window | 2 months post-enactment |
| Compliance deadline | 6 months post-registration |
| Scope expansion | From 400 to ≥10,000 regulated entities |
| Sectoral oversight | Maintained (CSIRTs GOV, MON, NASK + ministries) |
| Maximum fines | Up to €10 million or 2% global turnover; PLN 100 million cap for critical cases |
With this foundation laid, let’s take a closer look at the evolving legal framework.
How Poland is implementing the NIS2 directive
Poland’s legislative strategy involves detailed amendments structured across thematic chapters. The updated draft aligns closely with the EU’s NIS2 directive, yet it introduces several national “twists” that companies must not overlook.
One of the most impactful changes is the mandatory self-classification of entities as either essential (podmioty kluczowe – PK) or important (podmioty ważne – PW) based on size, sector, and function. This classification determines the depth of compliance, supervision, and potential sanctions.
Key provisions in Poland’s KSC-2 draft
| Chapter | Main focus | Notable elements |
| Art. 1–3 | Definitions & sector classification | Chemicals, food, and general manufacturing moved to “essential” |
| Art. 4–7 | Self-registration | Entities must register within 2 months; Ministry of Digital Affairs (MoDA) oversees registry |
| Art. 8–15 | Risk management | Based on Art. 21 NIS2; MoDA will release ISO 27001/22301 alignment |
| Art. 16–22 | Incident handling | Notification ladder (24h → 72h → 30 days); sectoral CSIRTs handle reports |
| Art. 23–29 | Oversight | Ministries and CSIRTs can audit, mandate red teaming, or suspend entities |
| Art. 30–38 | Sanctions | Fine bands, disqualification of negligent executives, PLN 100M cap for threats to life/national security |
These legislative mechanics will soon form the compliance bedrock for thousands of Polish organisations—many of which have never been subject to cybersecurity regulation before.
Sanctions, oversight, and executive accountability
Perhaps the most eye-catching aspect of Poland’s NIS2 implementation is its strict sanctions regime. Beyond the financial penalties that align with the EU directive, Polish law adds an elevated fine cap for negligence in critical scenarios. And unlike in many EU countries, executives are directly liable, with courts empowered to ban board members for up to five years in cases of repeated non-compliance.
Sanctions under Poland’s NIS2 transposition
| Entity class | Standard fine cap | Turnover basis | Special threat fine |
| Essential (PK) | €10 million | 2% global turnover | PLN 100 million (~€23 million) |
| Important (PW) | €7 million | 1.4% global turnover | N/A |
| Executive sanctions | N/A | N/A | Disqualification up to 5 years for repeated negligence |
Public entities are a special case: although many are classified as essential, only state-owned enterprises (SOEs) face monetary penalties. Budget-funded bodies are subject to internal corrective measures instead.
Impact on Polish industries
One of the most seismic shifts from the Poland NIS2 directive is its impact on traditionally unregulated sectors. Mid-size manufacturers, regional governments, and even food processors are now brought under formal compliance regimes for the first time.
The revised scope isn’t just about more entities—it’s about deeper obligations. Think biennial external audits, real-time threat monitoring, and incident drills. Sectors like healthcare and telecoms face additional sector-specific rules, including outage reporting in as little as 8 hours.
Industry-specific changes under KSC-2
| Sector | New classification | Key compliance duties |
| Chemical & food | Essential | Biennial audits, ISO-aligned risk plans |
| General manufacturing | Essential/Important | OT-IT segmentation, SOC contracts |
| Energy & mining | Essential | Critical-supplier registry, SBOMs |
| Digital infrastructure | Essential | Zero-trust, 24×7 EU SOC, red teaming |
| Healthcare | Essential | Cyber-resilience drills, GDPR coordination |
| Public sector | Essential | Cyber Officer role, mandatory registry reporting |
According to the Ministry of Digital Affairs, first-year compliance costs could reach PLN 6–8 billion, though ISO-certified firms can offset much of this by building on existing frameworks.
What companies should do right now
If you’re reading this from a compliance or IT leadership chair, now is the time to act. With just months left before formal adoption and a short compliance window, there’s little margin for delay.
Start by classifying your organisation using MoDA’s self-assessment tools. Then prepare for registration by gathering internal data, especially those tied to digital operations and contact points.
Run a gap analysis based on Article 21 of NIS2, prioritising critical areas like multi-factor authentication, data backups, and vendor risk. And crucially, draft internal SOPs for incident reporting, considering the dual-reporting nature of cyber incidents that may also trigger GDPR obligations.
Finally, secure board-level buy-in. Documenting leadership approval of your cybersecurity programme and scheduling your first biennial audit can go a long way in reducing personal and corporate liability risks.
Is your organisation ready for the next compliance wave?
The clock is ticking. With Poland’s NIS2 transposition well into its final legislative stages, proactive engagement is no longer optional—it’s a matter of operational survival. What once was a niche concern for a few operators of essential services is now a national obligation that touches nearly every major sector.
Whether you’re in manufacturing, healthcare, digital infrastructure, or local government, the question isn’t whether you’re in scope. It’s whether you’re ready.
If you’re unsure where to begin, consult sector-specific CSIRTs or follow updates from the Ministry of Digital Affairs, which continues to publish guidance ahead of the law’s adoption.
One thing’s clear: Poland’s journey with the NIS2 directive is reshaping the cybersecurity expectations for an entire economy. The sooner you adapt, the better your chances of thriving in this new regulatory reality.
