Romania NIS2 Implementation
Comprehensive framework addressing Black Sea regional security concerns and EU digital single market integration.
| Jurisdiction | Romania |
|---|---|
| Category | Cybersecurity |
| Status | Active |
| Latest development |
Analysis
Romania has implemented the NIS2 Directive through Government Emergency Ordinance (GEO/OUG) 155/2024 and Law 124/2025, with enforcement led by the National Cybersecurity Directorate (DNSC) and additional secondary legislation (DNSC Orders 1/2025 and 2/2025). Cybersecurity: Romania transposes the NIS2 Directive. What's next? Romania expands NIS2 scope under Law No. 124/2025 NIS2 in Romania: What GEO 155/2024 and Law 124/2025
Key Requirements
Primary legal framework
- Transposition of NIS2 into Romanian law
- Romania transposed Directive (EU) 2022/2555 (NIS2) via GEO 155/2024 on measures for a high common level of cybersecurity across the Union. Cybersecurity: Romania transposes the NIS2 Directive. What's next? Romania expands NIS2 scope under Law No. 124/2025 NIS2 in Romania: What GEO 155/2024 and Law 124/2025
- Competent authority and sector regulators
- The National Cybersecurity Directorate (DNSC) is designated as the primary authority for NIS2 supervision, incident reporting, and sanctions, working in parallel with sector regulators (e.g., ANRE for energy, ANCOM for electronic communications, ASF for financial services). NIS2 Romania Compliance | Timelines, Fines, and Roadmap – Copla #No.23 Edition – AROBS (LinkedIn) Cybersecurity: Romania transposes the NIS2 Directive. What's next?
- Scope: essential vs. important entities
- Romanian NIS2 rules classify in‑scope organizations into essential and important entities, following NIS2 criteria and national additions in Annex 1 and Annex 2 of GEO 155/2024, which cover highly critical sectors and important services. Cybersecurity: Romania transposes the NIS2 Directive. What's next? Romania expands NIS2 scope under Law No. 124/2025 NIS2 in Romania: What GEO 155/2024 and Law 124/2025
Core organizational and technical requirements
- Risk management and security measures
- Entities must implement appropriate and proportionate technical, operational, and organizational measures to manage cybersecurity risks and limit the impact of incidents, including risk assessments, data encryption, access controls, incident management plans, backup policies, and sector‑specific controls. Cybersecurity: Romania transposes the NIS2 Directive. What's next? NIS2 in Romania: What GEO 155/2024 and Law 124/2025 #No.23 Edition – AROBS (LinkedIn)
- Mandatory registration with DNSC
- In‑scope entities must register with DNSC under GEO 155/2024 and subsequent DNSC Orders; failure to register is explicitly sanctioned. Cybersecurity: Romania transposes the NIS2 Directive. What's next? Deadline approaches: NIS2 registration and risk evaluation in Romania NIS2 Romania Compliance | Timelines, Fines, and Roadmap – Copla
- Periodic risk assessment and audits
- Entities must perform periodic cybersecurity risk assessments and regular audits, communicate audit results to DNSC, and maintain documentation of analyses and implemented measures. Cybersecurity: Romania transposes the NIS2 Directive. What's next? NIS2 in Romania: What GEO 155/2024 and Law 124/2025 NIS2 Romania Compliance | Timelines, Fines, and Roadmap – Copla
- Governance, CISO/NIS2 officer, and management accountability
- Law 124/2025 introduces obligations to appoint a NIS2 officer (often a CISO‑type role), ensure ongoing cybersecurity training for management, and establish direct management responsibility and personal liability for compliance. NIS2 in Romania: What GEO 155/2024 and Law 124/2025 Romania expands NIS2 scope under Law No. 124/2025 #No.23 Edition – AROBS (LinkedIn)
- Incident reporting obligations
- Romanian NIS2 rules require structured, time‑bound incident notification: early warning within 24 hours, initial report within 72 hours, and final report within 30 days, with detailed impact and remediation information sent to DNSC. NIS2 in Romania: What GEO 155/2024 and Law 124/2025 #No.23 Edition – AROBS (LinkedIn) Cybersecurity: Romania transposes the NIS2 Directive. What's next?
- Registration and risk evaluation procedure (DNSC Orders 1/2025 and 2/2025)
- DNSC Order 1/2025 and Order 2/2025 define mandatory registration forms, risk assessment criteria, and the process by which entities determine if they are essential or important under Annexes 1 and 2 of GEO 155/2024. Deadline approaches: NIS2 registration and risk evaluation in Romania NIS2 Romania Compliance | Timelines, Fines, and Roadmap – Copla #No.23 Edition – AROBS (LinkedIn)
- Sanctions and fines
- GEO 155/2024 provides administrative fines up to EUR 10 million or 2% of global annual turnover for essential entities, and EUR 7 million or 1.4% of turnover for important entities, with fines tied to specific breaches (e.g., non‑registration, lack of audits, failure to notify incidents). Cybersecurity: Romania transposes the NIS2 Directive. What's next? NIS2 Romania Compliance | Timelines, Fines, and Roadmap – Copla NIS2 in Romania: What GEO 155/2024 and Law 124/2025
Compliance Challenges
- Scope determination and sector classification
- Many organizations struggle to determine whether they qualify as essential or important entities, particularly in cross‑border or multi‑sector operations, due to detailed sector lists and size thresholds in Annexes 1–2 of GEO 155/2024. Cybersecurity: Romania transposes the NIS2 Directive. What's next? Romania expands NIS2 scope under Law No. 124/2025 Deadline approaches: NIS2 registration and risk evaluation in Romania
- Registration and timing issues
- The initial registration deadline under GEO 155/2024 elapsed on 30 January 2025, and entities covered by Law 124/2025 had to register by 19 September 2025, leading to non‑compliance for organizations that missed these windows. Cybersecurity: Romania transposes the NIS2 Directive. What's next? NIS2 in Romania: What GEO 155/2024 and Law 124/2025 #No.23 Edition – AROBS (LinkedIn)
- Governance and CISO/NIS2 officer staffing
- Organizations face difficulties in appointing a qualified NIS2 officer/CISO, ensuring independence from operational IT, and establishing clear board‑level responsibility and training programs on cyber risk. Cybersecurity: Romania transposes the NIS2 Directive. What's next? NIS2 in Romania: What GEO 155/2024 and Law 124/2025 #No.23 Edition – AROBS (LinkedIn)
- Incident response maturity and reporting
- The strict 24h/72h/30‑day reporting timeline requires mature incident detection, logging, and coordination; many organizations lack the ability to quickly assemble a comprehensive incident timeline, impact assessment, and remedial plan. NIS2 in Romania: What GEO 155/2024 and Law 124/2025 #No.23 Edition – AROBS (LinkedIn) NIS2 Romania Compliance | Timelines, Fines, and Roadmap – Copla
- Cost and resource burden of audits and controls
- Regular audits, risk analyses, and implementation of “appropriate and proportionate” measures often imply significant investment in cybersecurity tooling, personnel, and external expertise, especially for medium‑sized entities. Cybersecurity: Romania transposes the NIS2 Directive. What's next? NIS2 Romania Compliance | Timelines, Fines, and Roadmap – Copla NIS2 in Romania: What GEO 155/2024 and Law 124/2025
- Real examples / case‑style insights
- Legal and consulting analyses in Romania highlight that entities in energy, telecoms, and financial services have had to adjust existing security programs to meet NIS2’s governance and reporting requirements, often revealing gaps in board‑level visibility and central incident management. Cybersecurity: Romania transposes the NIS2 Directive. What's next? Deadline approaches: NIS2 registration and risk evaluation in Romania #No.23 Edition – AROBS (LinkedIn)
Implementation Best Practices
- Step 1 – Confirm applicability and classification
- Review Annex 1 and Annex 2 of GEO 155/2024 to determine if your organization is an essential or important entity, considering sector and size criteria; legal and advisory notes recommend this as the first implementation step. Deadline approaches: NIS2 registration and risk evaluation in Romania Cybersecurity: Romania transposes the NIS2 Directive. What's next? Romania expands NIS2 scope under Law No. 124/2025
- Step 2 – Register with DNSC and maintain up‑to‑date data
- Follow the DNSC registration process as set out in Orders 1/2025 and 2/2025, ensuring accurate data on services, critical systems, and contacts; entities must register and update DNSC when major changes occur. Deadline approaches: NIS2 registration and risk evaluation in Romania NIS2 Romania Compliance | Timelines, Fines, and Roadmap – Copla NIS2 in Romania: What GEO 155/2024 and Law 124/2025
- Step 3 – Establish governance, NIS2 officer, and board oversight
- Implement clear roles and responsibilities, appoint a NIS2 officer / CISO, ensure their independence from operational IT, and set up board‑level cyber risk reporting with KPIs and documented risk‑acceptance decisions, as recommended by Romanian practitioners. [NIS2 in Romania: What GEO 155/2024
Recent developments
- — DNSC launched a public consultation on two draft secondary-legislation acts covering cyber risk management and board-level responsibilities for essential and important entities. The drafts are meant to operationalize Romania’s NIS2 obligations under Articles 21 and 22 and mark the next implementation phase. (source)
- — DNSC adopted two implementing orders: one on the procedure for notification and registration of entities subject to NIS2, and another on the methodology for assessing risk levels and service-disruption impact. These orders provide the detailed administrative framework for the national register and risk classification. (source)
- — Romania’s Parliament approved GEO 155/2024 as Law No. 124/2025, formally completing transposition of NIS2 into national law. The approval law broadened scope, added sector-specific entities, strengthened training and governance obligations, and clarified fine calculations. (source)
- — Law No. 124/2025 entered into force after publication in the Official Gazette, confirming and amending GEO 155/2024. Romania thereby finalized the national NIS2 framework after the initial emergency ordinance route. (source)
- — Legal commentary noted that GEO 155/2024 imposes broad registration, audit, and reporting duties for essential and important entities. It also highlighted heavy sanctions, including fines up to EUR 10 million or 2% of global turnover for essential entities, and personal liability for management. (source)
- — Industry-facing analysis emphasized that the registration deadline with DNSC had already elapsed on 2025-01-30, increasing urgency for in-scope organizations. This suggested a strong compliance push across sectors newly covered by the ordinance. (source)
- — Copla reported that the NIS2 transposition entered into force on 2025-01-02 through OUG 155/2024, replacing Law 362/2018. The article said DNSC became the lead authority and estimated the new framework covers roughly 12,000–15,000 entities, far more than under NIS1. (source)
- — The same update described a graduated enforcement model with warnings, corrective plans, periodic penalties, and possible domain suspension. This signaled a more aggressive enforcement posture for cybersecurity compliance in Romania. (source)
- — Romania adopted Government Emergency Ordinance No. 155/2024 on 2024-12-30 and it entered into force on 2024-12-31. The ordinance created the core legal framework for NIS2 implementation in Romania. (source)
Related regulations
- NYDFS Cybersecurity Regulation — New York, Active, effective 2025-11-01
- Law on Cybersecurity of Vietnam — Vietnam, Active
- Austria NIS2 Act — Austria, Upcoming
- Luxembourg NIS2 Transposition — Luxembourg, Active
- EU Cyber Resilience Act (CRA) — European Union, Phased, effective 2027-12-11
- EU Cyber Resilience Act - Vulnerability and Incident Reporting (11 Sep 2026) — European Union, Active, effective 2026-09-11
- Netherlands NIS2 Transposition (Cyberbeveiligingswet) — Netherlands, Active, effective 2026-08-15
- Belgium NIS2 Transposition — Belgium, Active, effective 2024-10-18
Put it into practice
- Generate the policy: NIS2 policy generator (generatepolicy.com)
- Buy the policy pack: NIS2 Compliance Policy (cyberpolicy.shop)
- Build it yourself: DORA + NIS2 EU Compliance Workbook (ciso.diy)
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