Poland NIS2: after the KSC register deadline, obligations apply from 3 April 2027

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Poland's amended KSC Act has applied since 3 April 2026. The register deadline passed on 3 October 2026; the obligations apply from 3 April 2027.

Poland transposed NIS2 by amending its Act on the national cybersecurity system (KSC). The amending Act of 23 January 2026 was published in the Journal of Laws on 2 March 2026 (Dz.U. 2026 poz. 252) and, according to the Ministry of Digital Affairs, has applied since 3 April 2026. The first deadline, registration, passed on 3 October 2026. The next one is 3 April 2027.

Who is covered

The Act applies to key and important entities in the sectors listed in its annexes. Each organisation has to check for itself whether it meets the criteria, in particular Article 5 and Annexes 1 and 2. Public entities, telecoms operators, trust service providers and former operators of essential services are entered in the register (Wykaz KSC) ex officio. All others had to apply for entry through the Wykaz KSC application by 3 October 2026.

Key dates

These dates apply to entities that met the criteria on 3 April 2026.

Reporting and fines

A serious incident needs an early warning within 24 hours of detection, a notification within 72 hours and a final report within one month of the notification. Fines reach EUR 10 million or 2% of revenue, whichever is higher, for key entities, and EUR 7 million or 1.4% of revenue for important entities. For most obligations, the Ministry notes that fines can only be imposed after 3 April 2028.

What to do now

If you are covered and have not applied for entry, do it now. Then use the five months to 3 April 2027 to set up the information security management system, the measures and the incident procedure.

Dazr Compliance turns the NIS2 measures of Article 21 into recurring tasks with owners and evidence, includes ISO 27001 for the management system, and its incident register counts down the 24-hour, 72-hour and one-month milestones. The interface is available in Polish.

Sources

For information only, not legal advice. Last updated 7 November 2026.

Topics: NIS2, Poland, KSC

Also available in: Polski

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