Cullen International’s latest Benchmark continues its analysis of NIS2 transposition across 18 EU countries, focusing on cybersecurity risk-management, incident reporting, and enforcement.
Most countries have not gone beyond NIS2 security obligations, however, additional requirements apply or could apply in six countries. Of the countries surveyed, some of them, for example Belgium, Germany, and Portugal, refer to technical standards (e.g. ISO 27000 series) or other national instruments to demonstrate compliance with NIS2.
In all countries covered, incidents reporting is in line with the NIS2 multi-step approach but in certain countries, such as in Portugal and Romania, additional notifications apply.
On enforcement, Cullen International’s research shows that in all the 18 EU countries surveyed, maximum fines are aligned with those set in NIS2. However, in Belgium and Italy, maximum fines can be doubled, or even tripled in Italy, for repeat violations.
In six countries, members of management bodies can be fined for non-compliance with their duties. Further, in nearly all countries surveyed, with few exceptions for example, Ireland and Spain, public authorities could be subject to fines similar to essential and important entities.
Five countries have also introduced additional penalties to strengthen compliance with NIS2.
For more information on the benchmark and Cullen International's complete NIS2 coverage, please click on “Access the full content” - or on “Request Access”, in case you are not subscribed to our European Digital Economy service.
more news
28 November 25
Global trends in countering online scams in 2025
Our latest Global Trends report highlights that several jurisdictions around the world adopted or proposed in 2025 new legislation and policies aimed at countering online scams. The focus of those initiatives regarded various aspects, ranging from prevention and enforcement aspects to mechanisms to compensate scam victims.
26 November 25
AI policy in the Americas is at a crossroads, as many countries adopt or discuss broad strategies or legislation
Our latest benchmark, which covers artificial intelligence strategies and regulation in the Americas, shows that AI policy has been a key issue for the region, with important decisions on the horizon.
19 November 25
Latest update on telecoms regulation from the Middle East and North Africa
Our latest MENA Telecoms Update details the most significant regulatory developments taking place in the region between 12 August and 30 October 2025.