NIS2 e DORA – enhance cyber resilience across all sectors

The NIS2 Directive and the DORA Regulation are two fundamental components of the national cybersecurity strategy. Both regulations arise from the need to strengthen the capacity of public and private organisations to prevent, manage and respond effectively to cyber threats, which increasingly jeopardise business continuity and market confidence.

Italian cybersecurity context

3,541 serious cyber-attacks recorded globally (a 27% increase compared to 2023), of which 357 were recorded in Italy.
+27%

growth in global attacks compared to 2023

 

Source: Clusit, Report on Cybersecurity in Italy and Worldwide 2025 
 

10%

of global attacks occur in Italy

NIS2 Directive  

This is the new European regulatory framework that strengthens cybersecurity obligations for businesses and critical infrastructure. As a central component of the national cybersecurity strategy, it aims to raise the level of digital security in all Member States by standardizing rules, responsibilities and incident reporting procedures. Since 17 January 2023, the date of its entry into force, EU countries have begun the process of transposing it into their national legislation. Italy was among the first countries to implement the legislation through Legislative Decree 138/2024, demonstrating a proactive approach and a particular focus on cyber resilience. 

NIS2 has significantly expanded the number of entities concerned (from 400 under NIS to an estimated 10,000 in Italy alone with NIS2). Its scope covers a wide range of sectors (transport, energy, B2B services, etc.), distinguishing medium-sized and large enterprises as essential and important entities.

Since the text came into force, the legislation has established a framework of particularly important deadlines that is continuously updated. Most recently, on 3 October, the CSIRT contact person was designated, who must be appointed between 20 November and 31 December 2025.

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  • December 2026 – Deadline for designating the CSIRT contact point and establishing an incident notification mechanism
  • October 2026 – Deadline for adopting basic security measures

Failure to comply with the obligations imposed within the respective deadlines exposes organisations to significant and diverse consequences. In addition to the risk of penalties (up to 10 million Euro or 2% of turnover), inadequate security management can result in reputational loss, operational disruptions and serious damage to trust among customers and stakeholders. For this reason, NIS2 identifies several key pillars: from governance liability to ICT incident management, through the adoption of advanced technical and organizational measures, to the ability to constantly monitor suppliers throughout the digital supply chain.

Digital Operational Resilience Act (DORA)

It complements the regulatory framework by specifically targeting the financial sector. The regulation introduces a comprehensive set of rules aimed at ensuring the digital operational soundness of financial institutions and entities operating in the sector, imposing uniform standards that are directly applicable in all Member States. From 17 January 2025, DORA will be fully effective: banks, insurance companies, investment firms, payment infrastructure providers and other operators (most recently, also financial intermediaries pursuant to Article 106 of TUB – Italian consolidated banking act) must be ready to demonstrate that they have taken appropriate measures to protect and manage ICT risk.

Key milestones

NIS2 and DORA share a common vision:

to promote a secure, resilient and transparent digital ecosystem by establishing a governance vision based on several key points.
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  • Direct liability of the management
  • Incident management
  • Introduction of specific security measures
  • Analysis and coverage of risks from the supply chain
  • Governance built on security policies and procedures for ICT equipment
  • Continuous monitoring and testing of systems