In brief: Despite around 10,000 fewer registrations than originally expected, the German federal government sees no coverage gap in the implementation of NIS2 in Germany.
Of roughly 30,000 originally estimated operators of critical infrastructure, around 10,000 fewer have registered so far. The federal government nevertheless does not consider this a registration gap in the implementation of the NIS2 Directive.
The federal government had originally assumed that almost 30,000 companies would need to register as operators of critical infrastructure as part of the NIS2 implementation. In fact, according to current figures, around 10,000 fewer companies have registered than initially calculated. The federal government does not attribute this difference to a lack of willingness to register or to a coverage gap, but rather traces it back to the original estimate, which was inherently subject to uncertainty from the outset.
For compliance officers at companies that potentially fall within the scope of NIS2, this discrepancy is relevant to their own risk assessment. Anyone who has so far been unsure whether a registration obligation applies should not base their own classification solely on the number of companies already registered. The federal government apparently now estimates the number of operators actually affected to be lower than originally assumed, but this does not change the fundamental obligation of individual companies to assess for themselves whether they are affected and, if applicable, to register in time.
For practical implementation, this means that companies must continue to independently assess whether they qualify as operators of critical infrastructure within the meaning of the national NIS2 implementation. The lower overall number of registrations should not be interpreted as an all-clear, since the federal government itself does not acknowledge any gap in the registration process, but instead attributes the lower number to the inaccuracy of the original estimate.
Source: www.golem.de · Published August 13, 2026
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