In brief: The Federal Government denies that the delayed NIS2 transposition has caused a registration gap for critical infrastructure.
The Federal Government disagrees with the assessment that the delayed national transposition of the NIS2 Directive has created a gap in the registration of critical infrastructure. For compliance officers, the question remains open as to when specific reporting and registration obligations will legally take effect.
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According to a report by Golem, the Federal Government has responded to allegations that a registration gap for critical infrastructure has arisen due to the still-pending German transposition of the EU NIS2 Directive. The government rejects this assessment and sees no such gap. Specific details on deadlines, affected sectors, or the number of entities already registered are not provided in the available source.
For compliance and security officers at companies that may fall within the scope of NIS2, this statement is relevant because it signals that the Federal Government is maintaining its previous position on the transposition, even though the national NIS2 implementation act is still pending. As long as no binding national regulation is in force, it remains unclear for affected operators which specific registration and reporting obligations already apply and which will only take effect once the implementation act enters into force.
Companies preparing for NIS2 should monitor further developments in the legislative process and continue their internal classification as an affected entity independently of the status of national transposition. No new timeline for the entry into force of the German NIS2 implementation act can be derived from the available report.
Source: news.google.com · Published August 13, 2026
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