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NIS2 in effect in spring 2026

Implementation of the NIS2 Directive Postponed Further. The introduction of the NIS2 Directive has been delayed again. While 1 January 2025 was previously mentioned as the start date, the second quarter of 2026 is now considered almost certain. The NCSC has confirmed this delay, despite the growing urgency surrounding cybersecurity.

New Timeline Provides Breathing Space, but Inaction Is Not an Option

This additional time is seen as a final opportunity for companies to complete their internal preparations. Supplier management and agreements within the supply chain, in particular, require significant effort. Many organisations are still behind schedule, and this postponement offers them a chance to catch up.

Why Q2 2026 Is Almost Certain

  1. Political Will to Move Forward

    • The legislative proposal has been finalised; the consultation took place in 2023.

    • The law mainly involves the transposition of European obligations, leaving little political resistance.

  2. Increasing Pressure from Europe

    • The original deadline (October 2024) has long passed.

    • The Netherlands is lagging behind other EU countries and risks legal proceedings.

    • Other member states have already implemented NIS2, increasing pressure on the Netherlands.

  3. Businesses Already Preparing for Implementation

    • Companies in many sectors are already actively preparing.

    • Demand for audits, certifications and practical support is rapidly growing.

    • Many organisations are already working with Q2 2026 as their target date.

  4. Supervision and Implementation Structures Largely in Place

    • Government bodies and regulators have largely set up reporting points, systems and awareness campaigns.

    • The NIS2 Quality Mark now also provides a practical standard, particularly for SMEs and suppliers.

Conclusion: Law Almost Certainly in Force by 2026

It is highly likely that NIS2 will officially come into force in the second quarter of 2026. Formal completion is still ongoing, but the legal text is ready, external pressure is increasing, and most companies and regulators are already taking action.

Advice: use this time to truly get your preparations in order.