What the NIS2 Directive Means for Machinery Manufacturers

With the NIS2 Directive (Directive (EU) 2022/2555), the European Union has taken a major step to strengthen cybersecurity across the EU. NIS2 is the second directive on the security of network and information systems. The directive entered into force on January 16, 2023. It revises and extends the original NIS Directive and aims to make public and private entities considerably more resilient to cyber threats and better able to respond to them. For machinery manufacturers, whose sector increasingly depends on digital technology and connected systems, NIS2 brings particular challenges and opportunities.

Contents

1. Why NIS2 matters for machinery manufacturers
2. A wider scope: how machinery manufacturers are affected
3. Stricter security requirements: challenges for machine building
4. Reporting obligations and incident response: new processes
5. Impact on companies: opportunities and challenges
6. NIS2 and the Cyber Resilience Act: complementary approaches
7. Transposition and next steps for machinery manufacturers
8. Getting support with implementation
9. Outlook: NIS2 changes cybersecurity in machine building

Why NIS2 matters for machinery manufacturers

Digitalization has reached machine building. Industry 4.0, the Internet of Things (IoT), and cyber-physical systems are no longer visions of the future but a reality on many shop floors. As connectivity grows, so does exposure to cyberattacks. NIS2 aims to make companies considerably more resilient to such threats and better able to respond to them.

For machinery manufacturers, this means rethinking and adapting their cybersecurity strategies. The directive calls for a higher level of cybersecurity, harmonized security requirements across all EU Member States, and a culture of risk management. This is particularly relevant for machinery manufacturers, who are often part of complex international supply chains and whose products are increasingly connected and software-controlled.

A wider scope: how machinery manufacturers are affected

NIS2 considerably widens the scope and now affects many companies in machine building, directly or indirectly. Of particular relevance is the inclusion of sectors such as energy, transport, the manufacture of certain critical products, and digital infrastructure. Machinery manufacturers that supply components or systems to these sectors may now fall under the directive.

Machinery manufacturers that produce critical components for industrial plants, energy systems, or transport infrastructure are especially affected. The directive expects a higher level of cybersecurity from them, not only in their own processes but also in the products and services they offer.

Stricter security requirements: challenges for machine building

NIS2 introduces stricter cybersecurity requirements that pose particular challenges for machinery manufacturers. Implementing cybersecurity risk-management measures requires an end-to-end view of cybersecurity, from product development through to maintenance and support.

The requirement for supply chain security is especially relevant for machine building. In an industry that often relies on specialized suppliers and complex international supply chains, this means carefully reviewing and securing every interface. Machinery manufacturers must ensure that not only their own systems but also those of their suppliers and partners meet the higher security standards.

Introducing cyber hygiene policies and implementing encryption and multi-factor authentication is a technical and organizational challenge for many machinery manufacturers. Integrating cybersecurity measures into existing machine control systems and production systems in particular often requires considerable changes and investment.

Reporting obligations and incident response: new processes

NIS2 introduces clearer and stricter reporting obligations for cybersecurity incidents. Machinery manufacturers need effective processes to detect, respond to, and report security incidents. This requires technical solutions, organizational changes, and staff training.

For example, the requirement to submit an early warning within 24 hours and a more detailed notification within 72 hours of an incident is a logistical challenge for many companies. Machinery manufacturers should therefore revise their incident response plans and make sure they can respond to cybersecurity incidents quickly and effectively.

Impact on companies: opportunities and challenges

NIS2 has far-reaching effects on machinery manufacturers. On the one hand, it means higher compliance requirements and significant investment in cybersecurity. On the other hand, it creates opportunities for innovation and for developing more secure products and services.

Machinery manufacturers must review and adapt their risk management processes. This covers their own business processes and also the security of the products they develop throughout their lifecycle. Building security-by-design principles into the development process becomes a necessity.

Training staff and raising awareness of cybersecurity risks and practices become a central task. Machinery manufacturers need a cybersecurity culture that reaches every level of the company.

NIS2 and the Cyber Resilience Act: complementary approaches

NIS2 focuses on the security of network and information systems. The Cyber Resilience Act (CRA), by contrast, specifically addresses the cybersecurity of products with digital elements. Machinery manufacturers should understand the differences and synergies between the two acts.

The CRA focuses on product security and requires manufacturers to address cybersecurity from the design phase. It introduces new conformity assessments for products and sets requirements for the entire supply chain. NIS2, in contrast, focuses more on the organizational aspects of cybersecurity and on the security of critical infrastructure.

As a machinery manufacturer, you therefore have to consider both the NIS2 requirements for your internal processes and systems and the product requirements of the CRA. Together, the two acts form a framework for cybersecurity that reaches from corporate strategy down to the individual product.

Transposition and next steps for machinery manufacturers

EU Member States officially had until October 17, 2024, to transpose NIS2 into national law. In practice, the process has proven more complex and uneven than it first appeared.

As with earlier EU directives, not all countries met the transposition deadline. In July 2026, the Commission referred Ireland, Spain, France, and the Netherlands to the Court of Justice of the EU. The delays in some Member States have led to a patchwork of rules. If you operate in several EU countries, you may face different timelines and requirements.

Some countries also extend or adapt the requirements of NIS2. Germany is one example: its NIS2 implementation act (NIS2UmsuCG) has applied since December 6, 2025. As a result, the requirements are not exactly the same in every EU country. Machinery manufacturers should pay close attention and follow the national transposition in each country where they operate.

Given this complexity, a flexible and proactive approach makes sense:

• Prepare early: Do not wait until every country has completed transposition. Where national laws already apply, as in Germany, your systems and processes must already be adapted.
• Monitor continuously: Follow developments in all relevant EU countries closely. This covers the transposition of NIS2 itself and any national extensions or adjustments.
• Use a flexible implementation strategy: Develop a strategy that lets you respond to different national requirements and timelines. This could mean prioritizing certain markets or building modular compliance approaches.
• Engage with industry associations: Take an active part in national and European industry associations, such as Orgalim, the European association of technology industries. This helps you stay informed and possibly influence national transposition.
• Align with the strictest requirements: To be on the safe side, it can make sense to follow the strictest requirements you expect. This makes compliance easier in all EU countries but may cost more.
• Review and adjust regularly: Because transposition develops differently from country to country, review and adjust your measures regularly.

This situation adds complexity for machinery manufacturers, but it is also a chance to lead on cybersecurity. Companies that act early and flexibly can gain a competitive advantage and establish themselves as trusted partners in an increasingly digital and security-conscious market.

For an overview of transposition across the EU, see the section on transposition and timeline on our NIS2 page.

Getting support with implementation

Given the complexity of NIS2 and its differing national transpositions, external expertise can be valuable for machinery manufacturers. Industry associations, specialized consultancies, and cybersecurity experts often provide useful support in interpreting the regulatory requirements and putting them into practice.

We also offer consulting services that help companies implement NIS2. They include analyzing your specific requirements, developing concrete implementation strategies, and supporting the technical implementation of cybersecurity measures. Whether external support makes sense depends on your needs and resources. For small and mid-sized machinery manufacturers in particular, it can be an efficient way to meet the challenges of NIS2 while drawing on industry expertise.

Whether or not you use external support, every machinery manufacturer needs a proactive approach to cybersecurity that covers the whole company. This means meeting regulatory requirements and also adapting continuously to new threats and technical developments.

Outlook: NIS2 changes cybersecurity in machine building

NIS2 marks the start of a new phase of cybersecurity in the EU and poses significant challenges for the machine building sector. It also creates opportunities for innovation and for more secure, more competitive products.

Machinery manufacturers should treat NIS2 not only as a regulatory obligation but as a strategic opportunity to improve their own cybersecurity and strengthen customer trust. In an increasingly connected industry, the ability to deliver resilient and secure systems becomes a competitive advantage.

Implementing NIS2 together with the requirements of the CRA will help create a more secure digital single market in the EU. For machine building, this means higher security standards and a chance to consolidate its position as a driver of innovation in a digital industry.