The digital landscape in Italy just got a significant upgrade, and if you’re leading a medium or large organization (and some smaller entities in critical roles), you’re likely feeling the pressure. Italy formally transposed the European Union’s Network and Information Security Directive (NIS2) into national law to bolster our collective resilience against cyber threats.
This isn’t just another paperwork exercise; it is a fundamental shift in how we handle risk, report incidents, and hold leadership accountable.
I’ll break this down for you: Italy didn’t just copy-paste the EU requirements. The implementing decree expands the scope via national provisions and annexes, while the National Cybersecurity Agency (ACN), or Agenzia per la Cybersicurezza Nazionale, is rolling out the implementation specifics in phases.
Let me explain the details below.
TL;DR: The Essentials
Italy is officially in the NIS2 Directive era, having replaced the old NIS1 rules with Legislative Decree No. 138/2024. If you operate in critical sectors such as energy, health, or certain manufacturing areas, you are likely in scope and must register with the ACN.
While the law is active now, full technical compliance is phased and, for many organizations, will be due within 18 months of ACN’s formal notification of inclusion (often landing in late 2026 for the first cohort). I recommend starting your risk assessments immediately, as the fines for violating these rules are high enough to make any CFO sweat.
Timelines and Legislative Milestones
Italy was remarkably punctual with this rollout. Parliament delegated authority via Law 21 February 2024, No. 15 (Art. 3), and the main implementing measure, Legislative Decree 4 September 2024, No. 138 (‘Italian NIS2 Decree’), was published on 1 October 2024 and entered into force on 16 October 2024.”
This decree effectively retired the old 2018 rules. However, the government knows you can’t overhaul your entire security architecture overnight, so they have created a staged approach. While the “what” is defined in the law, the “how” (the technical specifics) is being released in waves by the ACN.
| Milestone Date | Action / Requirement |
| October 2024 | Decree 138/2024 takes effect; NIS1 repealed. |
| January/February 2025 | Registration deadlines for digital providers and other entities. |
| March/April 2025 | ACN notifies entities of their status (Essential vs. Important). |
| April 2025 | Deadline for ACN to define “Basic” security measures. |
| January 2026 | Full compliance with incident reporting obligations required. |
| April 2026 | Deadline for ACN to define “Comprehensive” security measures. |
| October 2026 | Final deadline for full implementation of all technical requirements. |
Structure and National Specificities of the Law
The Italy NIS2 implementation follows the EU’s distinction between “Essential” and “Important” entities. Essential entities face stricter oversight and higher fines, while Important entities have a slightly lighter (but still serious) regulatory burden.
What makes the Italian NIS2 directive unique is its expanded scope. Italy didn’t stop at the EU’s list; it added Annex III and Annex IV to the decree.
This means public administrations at the regional and local levels, cultural heritage institutions, and even local public transport operators are now in the crosshairs.
Essentially, if your organization keeps a piece of Italian society or the economy moving, you should assume you are covered.
The “Safeguard Clause”
A key Italian detail is the DPCM 9 December 2024, n. 221 (published 10 February 2025; in force 11 February 2025), which sets the criteria for applying the safeguard clause for groups.
If you have a small subsidiary that is technically part of a large in-scope group, you might be able to get an exemption if you can prove that its ICT systems are 100% independent.
This is the part most teams miss: you have to apply for this through the ACN platform; it isn’t automatic.
Compliance Requirements: The “Big Three”
The NIS2 Italy framework rests on three pillars: risk management, incident reporting, and governance. You won’t need a law degree for this, but you will need a solid plan.
1. Risk Management and Security Measures
You must implement “appropriate and proportionate” measures. This means conducting a real-world risk assessment of your technical, operational, and supply chain vulnerabilities. The ACN updated the National Framework for Cybersecurity and Data Protection to help you align with these goals.
2. Incident Reporting Timelines
The reporting window is tight. If you have a “significant” incident, you have to follow a 24/72/30 rule:
- 24 Hours: Initial “early warning” to CSIRT Italia.
- 72 Hours: A more detailed notification with an initial assessment.
- 1 Month: A final report with root-cause analysis.
3. Governance and Management Liability
This is where the rubber meets the road for leadership. Under Article 23 of Legislative Decree 138/2024, the administrative/management bodies (that’s you, CEOs, and Board members) must approve the implementation approach, oversee compliance, and are responsible for violations under the decree.
If things go wrong and you haven’t done your due diligence, you could be held personally liable.
Fines: The Price of Procrastination
Italy has adopted the maximum fine levels allowed by the EU. These are designed to be “dissuasive,” which is a polite way of saying “painful.”
| Entity Type | Serious Violation (Max Fine) | Administrative Violation (Max Fine) |
| Essential Entities | €10M or 2% of global turnover | 0.1% of global turnover |
| Important Entities | €7M or 1.4% of global turnover | 0.07% of global turnover |
| Public Entities | €25,000 to €125,000 | €10,000 to €50,000 |
Note
If you are a repeat offender within five years, these fines can be doubled.
Short Checklist: How to Prepare
I’ll break this down into four immediate steps you can take to stay ahead of the Italy NIS2 implementation curve.
- Determine Your Status: Perform a self-assessment to see if you are an “Essential” or “Important” entity. Use the ACN’s FAQ as your guide.
- Register on the ACN Portal: Ensure your contact details and IP ranges are up to date. This is a simple administrative task, but the fines for skipping it are based on turnover, which is a bit of an “ouch” moment.
- Audit Your Supply Chain: Start vetting your third-party ICT providers now. You are responsible for their security posture if they support your critical functions.
- Bridge the Gap with Automation: Maintaining audit readiness and visibility is a massive manual lift. This is where a tool like Copla comes in handy; it can help automate your compliance workflows and give you the real-time visibility needed to satisfy ACN auditors.
Make NIS2 Compliance a Calm, Continuous Operating System, Not a Last-Minute Audit Project
Copla is built for teams that need NIS2 compliance without burning out staff or blowing the budget. It combines an automation-first GRC platform with experienced CISO oversight. That gives you four clear advantages:
- Cuts compliance workload by up to 80%
- Automates key NIS2 tasks across controls, evidence, and registers
- Guides execution step by step with clear ownership and built-in prompts
- Gives you CISO-level leadership without hiring a full internal team
On top of that, teams typically save €60K+ per year versus adding in-house capacity for the same workload, while staying continuously audit-ready, not “ready when the audit starts.”
The only compliance management platform you’ll need
Copla brings together capabilities such as asset and risk registries, evidence mapping, audit verification, regulatory reporting, vulnerability management, awareness training, and incident tracking — all in one place.
Moving Forward with Confidence
The NIS2 Italy transposition is a heavy lift, but it is manageable if you treat it as a continuous program rather than a sprint. By following the ACN’s phased technical guidelines and involving your leadership early, you can turn a regulatory burden into a competitive advantage.
The days of “security by obscurity” are over. Now, it’s about resilience, transparency, and quick recovery. If you stay proactive, you’ll find that these requirements actually make your business more robust in the long run.
