Compliance CalendarEU NIS2

EU NIS2 Directive deadlines and compliance calendar

Track the cited NIS2 dates that affect entity registration, Member State implementation, incident reporting, and recurring review work.

Assign legal, security, incident-response, procurement, and country owners to each date, trigger, filing route, and evidence record.

Author
Sorena AI
Published
May 9, 2026
Updated
Jul 24, 2026
Sections
6

Structured answer sets in this page tree.

Primary sources
14

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated Jul 24, 2026
Overview

Use this calendar to separate EU dates that have passed from deadlines that start when an entity becomes aware of an incident or changes registration data. The Directive required Member States to apply national measures from 18 October 2024, but an entity's current duties, authority, portal, and any national registration date come from the implementing law in the Member State with jurisdiction. Confirm that national position before assigning a filing date.

Section 1

Core NIS2 dates to anchor the compliance calendar

Article 41 required Member States to adopt and publish their measures by 17 October 2024 and apply them from 18 October 2024. Article 44 repealed Directive (EU) 2016/1148 from 18 October 2024. These were deadlines for Member States, not a single EU filing date imposed directly on every entity.

For an organisation in scope, the working calendar should identify the Member State with jurisdiction under Article 26, then record its national implementing law, competent authority or CSIRT, registration process, incident-reporting route, and any local dates. A provider operating across borders may need a different jurisdiction analysis depending on its service type; do not assume that every Member State where customers are located receives the same filing.

  • 17 October 2024: Member State transposition deadline under Article 41.
  • 18 October 2024: Member States apply the national measures adopted to comply with .
  • 18 October 2024: NIS1 is repealed, so legacy NIS1 references should be mapped to the replacement provisions.
  • Calendar owner: legal or public-policy owner tracks national implementing laws; security and incident-response owners update runbooks once the national route is confirmed.
  • Evidence to keep: Article 26 jurisdiction analysis, national law or authority page, applicable sector and entity type, owner sign-off, and date of last review.
Section 2

Article 27 registry data: 17 January 2025 and change updates

Article 27 creates a separate registry workstream for DNS service providers, TLD name registries, entities providing domain name registration services, cloud computing service providers, data centre service providers, content delivery network providers, managed service providers, managed security service providers, online marketplaces, online search engines, and social networking services platforms.

Member States had to require those entities to submit specified information to competent authorities by 17 January 2025. That date has passed, so a newly identified or unregistered entity should check the current national mechanism rather than treating the Directive's date as a new grace period. After submission, changes must be notified without delay and in any event within three months of the change.

  • 17 January 2025: affected Article 27 entity types submit registry information to the competent authority under the national mechanism.
  • Registry fields: entity name; sector, subsector, and entity type where applicable; address of the main establishment and other EU legal establishments, or the Article 26 representative; current email addresses and telephone numbers; Member States where services are provided; and IP ranges.
  • Change clock: notify changes without delay and within three months of the change.
  • Calendar owner: corporate secretary, legal, infrastructure, or compliance operations owner maintains the registration data source of truth.
  • Reopen trigger: new EU establishment, representative change, service launch in another Member State, contact change, IP range change, or provider-role change.
Section 3

Article 3 entity-list cycle: 17 April 2025 and every two years

Article 3 required Member States to establish a list of essential and important entities, plus entities providing domain name registration services, by 17 April 2025. Member States must review and, where appropriate, update the list regularly and at least every two years.

Two separate update clocks matter. An entity covered by the Article 3 list must notify changes to its submitted details without delay and within two weeks of the change. Competent authorities must report entity counts to the Commission and Cooperation Group every two years. The two-year authority cycle does not give an entity two years to correct its own details.

  • 17 April 2025: Member States establish the Article 3 list of essential and important entities and domain name registration service entities.
  • At least every two years thereafter: Member States review and update the list where appropriate.
  • By 17 April 2025 and every two years thereafter: competent authorities notify the Commission and the Cooperation Group of entity-count information.
  • Entity data changes: notify the competent authority without delay and within two weeks of the change, using the national mechanism where one exists.
  • Entity evidence to keep: sector, subsector, size-cap analysis, special-case trigger, Member States served, contact details, and authority correspondence.
  • Reopen trigger: acquisition, headcount or turnover change, new Annex I or Annex II service, critical-entity designation, or national authority request.
Section 4

Article 23 incident-reporting clocks to build into runbooks

Article 23 starts when an essential or important entity becomes aware of a significant incident. An incident is significant if it caused or could cause severe operational disruption or financial loss for the entity, or considerable material or non-material damage to another person. National rules and, for specified digital providers, Implementing Regulation (EU) 2024/2690 add detail to that assessment.

Reports are due without undue delay and no later than the stated outer limits: an early warning within 24 hours, an incident notification within 72 hours, an intermediate report if requested, and a final report no later than one month after the incident notification. If the incident is still ongoing when the final report is due, submit a progress report then and the final report within one month after handling the incident. A trust service provider has a specific exception: its incident notification for a significant incident affecting its trust services is due within 24 hours, not 72.

  • Without undue delay and within 24 hours of awareness: submit the early warning for a significant incident, including suspected unlawful or malicious cause or possible cross-border impact where applicable.
  • Without undue delay and within 72 hours of awareness: submit the incident notification with initial severity, impact, and available indicators of compromise. For a trust service provider reporting an incident that significantly affects its trust services, the outer limit is 24 hours.
  • Upon request: provide an intermediate report with relevant status updates.
  • Not later than one month after the incident notification: submit the final report, or a progress report if the incident is still ongoing; after handling an ongoing incident, submit the final report within one month.
  • Runbook evidence: awareness timestamp, facts supporting the significance assessment, service and cross-border impact, notification recipients, submitted report copies, authority feedback, root-cause and mitigation records, and the service-recipient communication decision.
Section 5

17 October 2024 implementing acts and technical-control planning

also placed implementing-act work on the Commission. Article 21(5) required the Commission, by 17 October 2024, to adopt implementing acts for technical and methodological cybersecurity risk-management requirements for specified digital infrastructure, ICT service management, digital provider, and trust service provider categories.

Commission Implementing Regulation (EU) 2024/2690 has applied since 7 November 2024. For the entity types it covers, it specifies Article 21 technical and methodological requirements and Article 23 significance criteria. The calendar should therefore include control reviews and incident-threshold testing for those entities, with evidence for policies, assets, incident handling, access control, supply-chain controls, vulnerability handling, and the other requirements in the Regulation.

  • 17 October 2024: Article 21(5) implementing-act deadline for specified digital and trust-service categories.
  • 7 November 2024: Implementing Regulation (EU) 2024/2690 became applicable to the entity types within its scope.
  • Covered teams: security governance, engineering, incident response, supplier risk, vulnerability management, business continuity, and access management.
  • Evidence fields: control owner, control text, system scope, implementation proof, test date, exception owner, and renewal trigger.
  • Do not apply the implementing regulation blindly to every entity; first confirm whether the entity type is covered by the regulation or only by national NIS2 implementation.
  • Reopen trigger: new covered service type, material control change, ENISA guidance update, authority feedback, or supplier-risk event.
Section 6

Current transposition watch and the 2027 Commission review

National implementation remained incomplete after the EU deadline. On 8 July 2026, the Commission decided to refer Ireland, Spain, France, and the Netherlands to the Court of Justice for failing to notify full transposition, and asked the Court to impose a lump sum and daily penalties until complete notification. This enforcement step concerns Member State transposition; it does not establish an entity's duties or excuse an entity from national measures already in force.

The longer-term EU review row is Article 40: by 17 October 2027 and every 36 months thereafter, the Commission must review the functioning of the Directive and report to the European Parliament and the Council. Compliance calendars should treat that as a policy-watch item, not an entity filing deadline.

  • Country watch item: track the Commission transposition page and the relevant national authority page for each Member State where services are provided.
  • 8 July 2026: Commission referral decision concerning Ireland, Spain, France, and the Netherlands for failure to notify full transposition.
  • 17 October 2027 and every 36 months thereafter: Commission review and report under Article 40.
  • Evidence fields: country, transposition status, competent authority, CSIRT or reporting portal, registration mechanism, incident route, and last checked date.
  • Do not add national deadlines from memory; add a country row only when it is supported by the national law or authority source used for that country.
Primary sources

References and citations

eur-lex.europa.eu
Referenced sections
  • EU implementing regulation that applies from 7 November 2024 and specifies Article 21 technical and methodological requirements and Article 23 significant-incident criteria for covered entity types.
"technical and methodological requirements"
eur-lex.europa.eu
Referenced sections
  • Primary legal text requiring Commission implementing acts by 17 October 2024 for technical and methodological cybersecurity risk-management requirements for specified entity categories.
"By 17 October 2024"
eur-lex.europa.eu
Referenced sections
  • Primary legal text for the 17 October 2024 transposition deadline, 18 October 2024 application date, and NIS1 repeal date.
"They shall apply those measures from 18 October 2024."
eur-lex.europa.eu
Referenced sections
  • Primary legal source for Article 3 entity lists, Article 21 implementing-act timing, Article 23 reporting clocks, Article 27 registry information, Article 40 review, Article 41 transposition, and Article 44 NIS1 repeal.
"high common level of cybersecurity across the Union"
enisa.europa.eu
Referenced sections
  • ENISA practical guidance and evidence examples for implementing the requirements in Commission Implementing Regulation (EU) 2024/2690.
"examples of evidence"
digital-strategy.ec.europa.eu
Referenced sections
  • Commission guidance source for the information entities submit under Article 3(4) when Member States build their essential and important entity lists.
"application of Article 3(4)"
digital-strategy.ec.europa.eu
Referenced sections
  • Commission FAQ summarising the multiple-stage incident reporting approach and explaining the early warning, incident notification, and final report sequence.
"The early warning should be followed by an incident notification"
digital-strategy.ec.europa.eu
Referenced sections
  • Commission overview confirming that Member States had until 17 October 2024 to transpose NIS2 and that NIS1 was repealed from 18 October 2024.
"Member States had until 17 October 2024"
Related guides

Explore more topics

Are managed service providers in scope of NIS2?
NIS2 scope answer for managed service providers and managed security service providers, including service definition, size-cap checks, entity status, and jurisdiction evidence.
EU NIS2 Directive applicability test for entity scope
Stepwise NIS2 applicability test for Annex I and Annex II sectors, medium and large entities, size-independent cases, essential or important classification, jurisdiction, and evidence.
NIS2 24-hour early warning: what to send and when
Under NIS2 Article 23, covered essential and important entities submit an early warning within 24 hours of becoming aware of a significant incident.
NIS2 72-hour incident notification FAQ
NIS2 incident-notification deadline, required initial assessment, evidence, follow-up, and the 24-hour trust-service-provider exception.
NIS2 Annex I and Annex II Sector Scoping Guide
Map NIS2 Annex I and Annex II sectors, entity types, size-cap rules, and essential versus important entity classification with official EU sources.
NIS2 Article 21 control baseline and evidence checklist
Build a NIS2 Article 21 control baseline from the Directive's minimum cybersecurity risk-management measures, proportionality test, supplier duties, and evidence expectations.
NIS2 Article 21 control-by-control evidence checklist
Map NIS2 Article 21 risk-management measures to evidence records for governance, incident handling, continuity, supply chain, testing, cyber hygiene, cryptography, access, assets, and authentication.
NIS2 Article 21 Gap Assessment Workflow: controls, evidence, and owners
Assess NIS2 Article 21 cybersecurity risk-management gaps by mapping current controls to Article 21(2), ownership, evidence, supplier risk, and management review.
NIS2 Article 23 incident notification workflow
Map NIS2 Article 23 reporting duties for significant incidents: 24-hour early warning, 72-hour notification, intermediate reports, final report, recipients, and evidence.
NIS2 Compliance Checklist: scope, controls, reporting
This NIS2 compliance checklist helps confirm scope, entity classification, management-body duties, Article 21 controls, Article 23 reporting, and evidence.
NIS2 Compliance Guide: scope, controls, reporting, and evidence
A practical NIS2 compliance guide for mapping entity scope, Article 21 risk measures, Article 23 incident reporting, management accountability, and evidence records.
NIS2 Country Implementation Matrix: Authorities, Portals, and Local Deltas
Build an operational NIS2 country matrix for applicable national law, competent authorities, registration, incident portals, local implementation deltas, evidence, and review dates.
NIS2 entity classification FAQ
Plain-English FAQ comparing NIS2 essential entities and important entities, with Article 3 classification rules, shared Article 21 and 23 duties, supervision differences, and evidence to keep.
NIS2 Entity Classifier Workflow: essential vs important entity scoping
Classify whether an EU service is out of scope, an important entity, an essential entity, or needs national-authority review under the NIS2 Directive.
NIS2 entity supervision guide
Compare NIS2 essential and important entities by scope, Article 21 and 23 duties, Article 32 and 33 supervision, evidence, jurisdiction, and penalties.
NIS2 essential vs important entities: Article 3 scope and supervision guide
Classify NIS2 essential and important entities using Article 3, Annex I and II sector scope, size-cap rules, registration evidence, and the Article 32/33 supervision split.
NIS2 FAQ: scope, Article 21 controls, incident reporting, and penalties
NIS2 FAQ on entity scope, essential and important classification, Article 21 measures, Article 23 reporting, national implementation, and evidence.
NIS2 incident clock triage workflow
Triage a possible NIS2 significant incident by recording awareness time, severity, impact, authority route, recipient communications, and Article 23 reporting clocks.
NIS2 Incident Reporting Workflow: 24-hour, 72-hour, and final report steps
Build a NIS2 Article 23 incident reporting workflow with significance triage, CSIRT or authority notification steps, recipient communication, cross-border checks, and evidence records.
NIS2 Management Body Accountability: board duties, training, and evidence
A guide to NIS2 Article 20 management body accountability: approval of Article 21 measures, oversight, national liability rules, training, reporting lines, and evidence.
NIS2 Member State Transposition: What Teams Must Check
How to handle NIS2 Member State transposition: use Article 41 as the EU baseline, then verify national law, authority routing, registration, and incident-reporting details.
NIS2 National Transposition Tracker: EU Member State Evidence Register
Track NIS2 national transposition with Commission country pages, Article 41 dates, reasoned-opinion flags, source wording, authority contacts, and legal review triggers.
NIS2 penalties and fines: Article 34 maximum levels and factors
NIS2 Article 34 fine levels, calculation factors, enforcement measures, GDPR overlap, and national-law checks for essential and important entities.
NIS2 Registration and Authority Notification Guide
Map NIS2 Article 3 entity-list duties, Article 27 registry submissions, competent-authority contacts, and national registration portal evidence without inventing country deadlines.
NIS2 Requirements: scope, Article 21 controls, reporting, and evidence
Map NIS2 requirements for essential and important entities: scope classification, management-body duties, Article 21 cybersecurity measures, Article 23 incident reporting, and evidence records.
NIS2 Size Cap Rule and Special Scope Cases
Apply the NIS2 medium-size test, group-data rules, regardless-of-size cases, exclusions, and essential-versus-important classification.
NIS2 size-cap rule: when medium and large entities are in scope
Plain-language FAQ on the NIS2 size-cap rule: medium and large Annex I or II entities, SME thresholds, regardless-of-size exceptions, and evidence to keep.
NIS2 Supply Chain Security Program: Article 21 Guide
Apply NIS2 Article 21 to direct suppliers and service providers, and distinguish its general duty from Regulation 2024/2690's digital-entity controls.
NIS2 vs CER Directive comparison: cyber obligations and critical-entity resilience
Compare NIS2 and the CER Directive using cited rows for scope, triggers, evidence, incident handling, supervision, and shared critical-entity work.
NIS2 vs DORA: scope, overlap, and evidence for EU cyber compliance
Compare NIS2 and DORA for EU cyber compliance: covered entities, when DORA replaces NIS2 duties for financial entities, incident reporting, evidence, and supervisory handoffs.
NIS2 vs GDPR breach reporting: EU deadlines and overlap
Compare NIS2 significant-incident reporting with GDPR personal-data-breach reporting, including scope, 24-hour and 72-hour clocks, evidence, and overlap.
NIS2 vs ISO/IEC 27001: legal duties, ISMS evidence, and reuse limits
Compare NIS2 legal obligations with ISO/IEC 27001 ISMS requirements: scope, Article 21 controls, incident clocks, SoA evidence, audits, and certification reuse.
NIS2 vs ISO/IEC 27017: legal duties, cloud controls, and reuse limits
Compare NIS2 legal obligations with ISO/IEC 27017 cloud-service controls: entity scope, Article 21 measures, incident clocks, shared responsibility, evidence, and assurance limits.
NIS2 vs NIS1: what changed in EU cybersecurity compliance
Compare NIS2 with the repealed NIS1 Directive: expanded sectors, essential and important entities, management-body duties, Article 21 controls, Article 23 reporting, and supervision.