Market guide
The DACH cybersecurity market and threat landscape in 2026
Threats, regulation and demand in the DACH cybersecurity market in 2026: BSI, Bitkom and BACS figures, NIS2 status and what buyers and providers should do.
Insights · Compliance guide
NIS2 is the EU directive 2022/2555 that sets a common cybersecurity baseline for medium and large companies in many sectors. If you operate in Germany or Austria and sit in a covered sector, the national laws are already in force (Germany since December 2025, Austria since 1 October 2026), so the question is no longer whether but how fast you can close your gaps.
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The directive replaced the first NIS directive and widened both the sectors and the depth of obligations. It binds you only through national law. The transposition deadline was 17 October 2024, and many countries were late: according to the European Commission, it sent reasoned opinions to 19 member states in May 2025, including Germany and Austria.
The directive rests on three pillars: security measures (Article 21), incident reporting to the authority (Article 23) and personal accountability of management (Article 20). High fines make this a board topic, not only an IT topic.
The directive lists sectors in two annexes. Annex I covers sectors of high criticality such as energy, transport, banking, health, drinking water and digital infrastructure. Annex II covers other critical sectors such as postal services, waste management, chemicals, food, certain manufacturing and digital providers. Essential entities are the larger ones in Annex I, important entities are the rest.
The basic size rule is that medium-sized enterprises and above are in scope. Germany expresses this in its BSI Act: 50 or more employees, or both turnover and balance sheet above 10 million euros, makes you at least an important entity. 250 or more employees, or turnover above 50 million euros together with a balance sheet above 43 million euros, makes you an essential entity in an Annex I sector. Some providers, for example DNS and top-level domain registries, are covered regardless of size.
Parent companies and partners count in the size calculation unless the entity runs its IT independently. Even below the thresholds, large customers will pass requirements down through contracts.
Article 21 asks for appropriate, proportionate technical, operational and organisational measures. It names a minimum set that works as the skeleton of your programme.
A significant incident triggers three steps. You send an early warning without undue delay and within 24 hours of becoming aware. Within 72 hours you send an incident notification with an initial assessment and, if available, indicators of compromise. A final report follows no later than one month after the notification; if the incident is still running, a progress report comes first. Germany implements this in section 32 of its BSI Act.
Management bodies must approve or implement the measures, oversee them and take part in training. In Germany, section 38 of the BSI Act makes managers liable to their company for culpable breaches. Delegating the work does not delegate the duty.
Fines are set nationally. The directive requires maximum fines of at least 10 million euros or 2 percent of worldwide turnover for essential entities, and at least 7 million euros or 1.4 percent for important entities, whichever is higher. German law sets these caps in section 65.
Germany: The NIS2 implementation act entered into force on 6 December 2025 and changed the BSI Act. There is no transition period for the obligations. Affected entities must register with the BSI; the BSI states on its site that the statutory deadline has expired. According to trade press reporting on a BSI statement, the BSI granted a grace period until 31 July 2026, more than 19,000 entities had registered by then, and it reserved the right to take steps backed by fines.
Austria: The Network and Information Systems Security Act 2026 (NISG 2026) was published as BGBl. I Nr. 94/2025, and the consolidated text in the legal information system shows 1 October 2026 as the date of entry into force. It replaces the old NISG and creates the new Federal Office for Cybersecurity. Check the office's official site for the registration procedure, as details may still change.
Switzerland: It is not an EU member, so NIS2 does not apply to Swiss companies as such. Since 1 April 2025, however, operators of critical infrastructure must report cyberattacks to the National Cyber Security Centre within 24 hours of discovery, and the full report may follow within 14 days. Failure to report can be fined up to 100,000 Swiss francs, and fines apply from 1 October 2025. Swiss companies with EU subsidiaries or EU customers should still check NIS2 exposure.
Most companies need a defensible, documented path, not a perfect programme in month one.
Few mid-sized companies can staff 24/7 monitoring or an incident team, and the 24-hour clock ignores office hours. External help is most useful for round-the-clock detection (managed SOC), an incident response retainer so containment starts within hours, independent assessments such as gap analyses, penetration tests and vulnerability scans, and support with policies and supplier processes.
Accountability stays inside the company: the board owns the decision and the reporting duty. Ask providers for written scope and response times, and for the evidence a supervisor would expect.
Usually not, because the base rule is medium-sized and above. Exceptions exist for some providers regardless of size, and you may still receive contractual security requirements from customers who are covered.
Essential entities are larger organisations in the high-criticality sectors and are supervised proactively. Important entities face the same duties but, under the directive, mainly ex-post supervision. The maximum fines differ.
No law in Germany or Austria requires it as such. A certified management system is a recognised way to structure and evidence the measures, but you still have to cover every Article 21 area and the reporting process.
In short, an incident that causes or can cause serious operational disruption or financial loss, or considerable damage to others. Check the definition in your national law before you build the process.
Under the directive, management bodies can be held liable for breaches of Article 21. In Germany, managers are liable to their own company for culpable breaches, following the company-law rules for their legal form.
Market guide
Threats, regulation and demand in the DACH cybersecurity market in 2026: BSI, Bitkom and BACS figures, NIS2 status and what buyers and providers should do.
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