For managing directors

NIS2 Roadmap for managing directors

The prioritised steps. Your personal time: ~3 hours per year — everything else is delegable.

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Check applicability

The roadmap

1

Check applicability

delegable

Check thresholds (employees, revenue, sector) to confirm whether your entity is classified as 'essential' or 'important'.

Legal basis:
§28 BSIG
Owner:
Managing director
Effort:
2 minutes
Deadline:
now
2

Register with your national NIS2 authority

delegable

You register with the NIS2 authority of every EU Member State you operate in — not only Germany. 'Operate in' means physical establishment: your own company, a branch, an office, or your own employees on the ground in that country. Cross-border sales alone do not count. Example: a German GmbH with a Vienna office registers with the BSI (DE) and the NIS-Stelle (AT).

Legal basis:
NIS2 Art. 27 · §33 BSIG (DE)
Owner:
IT lead files, managing director signs
Effort:
~1 hour per country + national identity setup (e.g. ELSTER in DE: 5–10 working days)
Deadline:
National deadlines apply — DE: 06.03.2026 passed; obligation continues
3

Complete the management training

personal · non-delegable

The one obligation that cannot be delegated. Demonstrate sufficient knowledge of cybersecurity risk management.

Legal basis:
§38(3) BSIG
Owner:
Managing director, personally
Effort:
~2 hours initial · annual refresh recommended
Deadline:
before first audit
4

Asset inventory and risk register

delegable

Complete list of the systems, applications, and data your operations depend on — and the risks against each. Both are the foundation for every other NIS2 obligation and the first thing an auditor asks to see. In the NISD2 platform, your IT lead and CISO build and maintain the inventory and risk register, and the incident reporting workflow (24h / 72h / 1 month under §32 BSIG) is wired in automatically.

Legal basis:
§30(2) BSIG · NIS2 Art. 21(2)(a)
Owner:
IT lead produces, managing director signs (§38(1) BSIG)
Effort:
~1 day initial pass · maintained ongoing, signed off yearly
Deadline:
Q1
5

Supplier inventory and supplier risk management

delegable

Inventory of your direct suppliers, linked to your asset register (which supplier runs which system). Continuous cybersecurity risk management — not a one-shot questionnaire: per-supplier security posture, incident notifications received via their supplier portal, risk scoring. The platform ships with the NIS2-anchored standard questionnaire (open source, MIT + CC BY 4.0) and maintains the inventory.

Legal basis:
§30(2)(4) BSIG · NIS2 Art. 21(2)(d)
Owner:
Procurement / IT produces, managing director signs
Effort:
~½ day initial pass · maintained ongoing
Deadline:
Q1–Q2
6

Implement the rest of NIS2

delegable

The ten measure areas under NIS2 Art. 21 — incident handling, business continuity (backups, recovery), training, access control, cryptography, vulnerability and patch management, network security, monitoring, supplier contracts, communications. The platform covers all ten with templates, automatic evidence capture, and a full audit trail; you sign off the annual summary.

Legal basis:
§30(2) Nr. 1–10 BSIG · NIS2 Art. 21
Owner:
IT lead / CISO implements, managing director signs off yearly
Effort:
ongoing, alongside normal IT work
Deadline:
Q2 onwards

Your personal minimum

  • 1× training (~2 hours, one-time)
  • 5× document sign-offs (~40 minutes total)
  • Annual refresh recommended

Total: ~3 hours per year.

Everything else is handled by your IT lead or CISO.

This page is structured guidance based on NIS2, BSIG, CIR 2024/2690, and ENISA TIG. It does not constitute legal advice. Your IT lead or CISO handles the operational work.

Sources and transparency
NIS2 Directive (EU) 2022/2555 · BSIG (as of 06.12.2025) · CIR 2024/2690 · ENISA Technical Implementation Guidance v1.0
Open-source tooling (MIT + CC BY 4.0) · Hosted in Germany · GDPR-compliant