Does NIS2 apply to you? Find out in 3 minutes.

Romania’s OUG 155/2024 requires companies in certain sectors, above a certain size, to have real security measures, to prove them, and to report incidents. We get you ready, so that on audit day you have nothing to worry about.

The law
OUG 155/2024 and DNSC Order 1/2026
Levels
3, with 34, 133 or 218 controls
Deadlines
Chained, not a single date
Our role
Preparation. The audit belongs to an independent auditor.

The law, in 60 seconds

Who is in

Companies in 18 sectors (energy, transport, health, water, food, chemicals, manufacturing, IT, postal services, waste and others) that are at least medium-sized: 50 employees or more, or, below 50, with turnover and assets above 10 million euros. A few categories are in regardless of size: DNS, domain registries, trust services, electronic communications.

What it requires

Real security measures across ten areas: from policies and risk analysis to backup, access control, suppliers and multi-factor authentication. You declare them in a yearly self-assessment owned by management, you prove them, and you report serious incidents within 24 hours.

Who checks

DNSC, Romania’s National Cyber Security Directorate: it registers you by decision, validates your risk level, receives your self-assessment and can inspect you. The audit is done by a DNSC-certified auditor, independent from whoever prepared you.

What changed on 27 August 2026

DNSC Order 1/2026 arrived: the catalogue of controls on three levels (34, 133 or 218), each control with two scores from 1 to 5, for how it is written and for how it works, and a mandatory remediation plan when you miss the targets. Bought solutions are no longer enough: you have to show they work.

The NIS2 roadmap, in short

Eight stations, in order. Deadlines run from events in your company’s life, not from a calendar date.

Station 1. Are you in scope? , By when: Now

Sector, size and the special cases.

By when

Now

The final classification is made by DNSC through a decision, after you notify.

What to do now

  1. Enter your fiscal code; we pull the sector, headcount and turnover from ANAF data.
  2. Confirm the sectors you actually work in, not just the NACE code.
  3. Answer a few questions about the special cases: group, DNS, cloud, telecoms, DORA.

What you risk

Nothing yet. But if you are in and not registered, see station 2.

Legal basis

OUG 155/2024, art. 5–9 and Annexes 1–2; Law 346/2004, art. 4 (size).

Station 2. You register with DNSC , By when: 30 days from the day you fall in scope

The notification on the NIS2@RO platform, with a qualified signature.

By when

30 days from the day you fall in scope

The original deadline has passed; a late registration beats no registration.

What to do now

  1. Prepare the data and the legal representative’s qualified electronic signature.
  2. Submit the notification on NIS2@RO; it counts as received within 5 working days.
  3. Keep the confirmation. Any later change to the data must be reported within 2 weeks.

What you risk

Low tier: 1,000–300,000 lei for important entities, 1,500–500,000 lei for essential ones (art. 60 (1) o) and p)).

Legal basis

OUG 155/2024, art. 18 (2)–(3); DNSC Order 1/2025.

Station 3. The DNSC decision and your security officer , By when: 30 days from the decision

You get your ID, appoint the officer, management takes the course.

By when

The decision: 60 or 150 days from notification. The officer: 30 days from the decision. Their course: 12 months from appointment.

What to do now

  1. Choose the officer, in-house or designated, and notify DNSC.
  2. Enrol the administrator and directors in an accredited course; it is an obligation with a fine, not a formality.
  3. Budget the people, time and tools for what comes next.

What you risk

Management duties sit in the high tier: up to 7 million euros or 1.4% for important entities, 10 million or 2% for essential ones (art. 60 (1) g)–k)). Management is personally liable for breaches (art. 14 (1)).

Legal basis

OUG 155/2024, art. 18 (4)–(5) and art. 14 (2)–(4), as amended by Law 124/2025.

Station 4. Your risk level , By when: 60 days from the decision

The ENIRE score decides how many controls you have: 34, 133 or 218.

By when

60 days from the day the decision is communicated

What to do now

  1. Estimate your level here, in two minutes, from sector and size.
  2. Fill in ENIRE@RO with the standard values; if you change any, write the justification and send it with the report.
  3. Submit the signed PDF report and wait for validation.

What you risk

Low tier for missing the deadline: 1,000–300,000 lei for important entities, 1,500–500,000 lei for essential ones (art. 60 (1) q)).

Legal basis

OUG 155/2024, art. 18 (6); DNSC Order 2/2025; DNSC Order 1/2026, art. IV–V.

Station 5. The maturity self-assessment , By when: 60 days from the risk assessment, then yearly

Every control, two scores from 1 to 5, with evidence.

By when

60 days from submitting the risk assessment, then yearly

Yearly, with no fixed day: the sensible reference is the anniversary of the first self-assessment.

What to do now

  1. Take stock of what you have: policies, procedures, systems, evidence.
  2. Score every control honestly; a 3 on implementation means a formal, applied process with evidence for most activities.
  3. Collect the evidence for every score of 3 or more, in a single file.

What you risk

A late first self-assessment is in the low tier (art. 60 (1) r)). Skipping the yearly self-assessment is in the high tier: up to 7 or 10 million euros (e)).

Legal basis

OUG 155/2024, art. 18 (7) and art. 12 (4); DNSC Order 1/2026, art. III and Annex 2, art. 1–2.

Station 6. The remediation plan , By when: For essential entities, 30 days from the self-assessment

For every gap: an action, an owner, a deadline, a proof.

By when

Essential entities: 30 days from the self-assessment. Others: together with the self-assessment, no separate deadline.

What to do now

  1. List the gaps from the self-assessment, ordered by their impact on the score.
  2. Give each one an action, an owner and a deadline you can actually keep.
  3. Decide up front which proof closes each action.

What you risk

For essential entities, a missing plan is in the high tier (art. 60 (1) f)).

Legal basis

DNSC Order 1/2026, Annex 2, art. 3; OUG 155/2024, art. 12 (5).

Station 7. Every year, plus the audit , By when: Yearly; the audit, per the coming order

A yearly self-assessment and an audit by a certified, independent auditor.

By when

The self-assessment: yearly. The audit: per the order that will set the frequency.

What to do now

  1. Keep the evidence file current all year; do not rebuild it before the deadline.
  2. Track the remediation plan and close actions with evidence.
  3. Pick a certified auditor early, from the list DNSC publishes.

What you risk

Refusing the audit is in the high tier (art. 60 (1) b)).

Legal basis

OUG 155/2024, art. 12 (4), art. 11 (5), art. 46 (8)–(9), art. 57–58.

Station 8. Any time: incidents and changes , By when: When it happens

24 hours, 72 hours, one month; company data kept current.

By when

Incidents: 24 hours, 72 hours, one month (6 hours for cross-border impact). Data: 2 weeks or 3 months.

What to do now

  1. Have a written response plan: who calls whom, and how fast.
  2. Create the PNRISC account beforehand, not on the night of the incident.
  3. Keep a calendar of the data you have to update.

What you risk

Failing to report incidents is in the high tier (art. 60 (1) l)–m)); failing to report changes, in the low tier (s)).

Legal basis

OUG 155/2024, art. 15, art. 18 (8), art. 47 (5); DNSC Order 3/2025.

See the whole roadmap, with the articles

What “evidence” means, concretely

Every control gets two scores. One for documentation: there is a written rule, approved, reviewed. One for implementation: the rule is actually applied and you can show it. Three examples from the 34 basic controls.

Access to systems and multi-factor authentication

Documentation
An access control policy, approved by management, saying who gets which rights and how they are revoked.
Implementation
Two-step authentication is on for e-mail, VPN and every internet-facing system, for everyone, suppliers included.
Evidence at the audit
The admin console report with accounts and MFA status, and the access list reviewed when the last employee left.

The inventory of what you own

Documentation
A procedure saying who keeps the inventory of hardware, software and cloud services, and when it is updated.
Implementation
The inventory exists, is complete and was updated at the last change, not at the last audit.
Evidence at the audit
The export from the inventory tool, dated, and a new device picked at random that shows up in it.

Backup and recovery

Documentation
The backup and restore procedure: what is saved, how often, where, who restores and how fast.
Implementation
Backups run, one copy is isolated, and a restore was tested recently, not assumed.
Evidence at the audit
The record of the last restore test: what was restored, how long it took, what did not work.

A firewall, an antivirus or a purchased backup is not compliance. A 3 on implementation needs a formal, applied process with evidence for most activities and fewer than 10% exceptions. Below 3 on a key measure, you miss the target even at the basic level.

Why we only do preparation

The law requires the auditor to be independent from whoever helped you prepare: it cannot be the one advising you or running your systems (OUG 155/2024, art. 58 (3)). Of the two roles, we chose the first.

We stop at the audit’s door. Up to there, your file is complete, the scores are honestly justified and every gap has a plan. So that on audit day you have nothing to worry about.

What we do, concretely

  • We check together whether and how you fall under the law, and which level you will have.
  • We write policies that are actually applied, not paperwork for its own sake.
  • We build the asset inventory, the risk register and the evidence file.
  • We complete the self-assessment correctly, with justifications you can stand behind.
  • We write the remediation plan with owners, deadlines and closing evidence.

For our clients only

The NIS2 audit preparation platform

Alongside our advisory work, we have built a platform dedicated to NIS2 audit preparation. We use it together with our clients, all the way to the audit. If you want to see what preparation would look like for your company, we start with a call.

Access is available only as part of a preparation project with BitUp Technology.

Questions business owners ask us

I have fewer than 50 employees but a large turnover. Does it apply to me?

It depends on your assets. You are “medium” if you have 50 employees or more, or, below 50, if both turnover and total assets exceed 10 million euros. If you belong to a group, the figures may be added up. Check with the tool, using real data.

We registered in 2025 and did nothing since. What do we do first?

The next steps run from the DNSC decision: 60 days for the risk assessment, then 60 for the self-assessment. If the deadlines have passed, the best thing is to close them now. Delays are sanctioned in the low tier, and DNSC has said it applies the lower limits first.

I have a firewall, an antivirus, backups. Is that not enough?

No. Every control gets two scores: how it is written and how it works. A firewall with no policy, no documented rules and nobody looking at the logs scores low on documentation and, probably, on implementation too.

Who does the audit, and when?

A DNSC-certified auditor, chosen and paid by you, who has not advised you and does not run your systems. The frequency is not yet set by an order; DNSC can order an audit after an incident or a major change.

Does the data I send to DNSC become public?

No. The law says expressly that information given to DNSC is not public-interest information, and DNSC protects the company’s commercial and security interests (art. 3 (3)–(4), introduced by Law 124/2025).

All the questions

Let’s see where you stand

Thirty minutes, by phone or video: which sector, which size, what you already have and what is missing. You leave with a list, not with a quote.