Poland · Compliance
NIS2 compliance in Poland
Achieve NIS2 compliance in Poland with Sterling: 8,100+ client engagements in 60+ countries, 20+ years.
- Compliance, end to end
- Frankfurt office team
- Effivity software included
- Academy training included
Who asks for NIS2 in Poland
Clients include
NIS2 compliance in Poland at a glance
Ustawa z dnia 23 stycznia 2026 r. o zmianie ustawy o krajowym systemie cyberbezpieczeństwa oraz niektórych innych ustaw (Dz. U. 2026 poz. 252) is the instrument itself: it applies to the organisations within its scope, and buyers and partners in Poland ask for evidence that you meet it.
Poland has a transposed NIS2 law on the statute book. The Act of 23 January 2026, published in the Dziennik Ustaw as item 252 on 2 March 2026 and listed by ISAP as in force, amends the National Cybersecurity System Act and states that it implements Directive (EU) 2022/2555. It sorts organisations into key entities and important entities, requires both to run an information security management system under Art. 8, obliges key entities to commission security audits, and lets the competent authority order an external audit. Competent authorities follow the sector: ministers for energy, transport, health and digital affairs among others, the Prezes Urzędu Komunikacji Elektronicznej for communications and postal services, and the Komisja Nadzoru Finansowego for banking. ISO/IEC 27001 is not named, so a certificate supports the evidence without proving compliance. Sterling's Frankfurt office runs scoping, gap assessment, supplier controls and reporting arrangements for Polish clients, with Effivity and Sterling Academy included.
Who needs NIS2 in Poland, and what happens without it
These are the organisations in Poland that most often need to show NIS2.
- Key entities (podmioty kluczowe) in the sectors the Act listsMust implement an information security management system under Art. 8, commission security audits and report incidents as the Act requires.
- Important entities (podmioty ważne)Carry the Art. 8 duties and can be ordered by the authority to commission an external audit after a serious incident.
- Banks and other financial entitiesThe KNF is the competent authority, and the Act cross-refers to DORA for financial entities.
- Suppliers to key and important entitiesSupply-chain security and continuity is one of the required measures, so customers pass requirements down.
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Take the free readiness checkNIS2 requirements in Poland
Strip away the vocabulary and NIS2 asks essential and important entities to comply in six areas of cyber risk management.
In Poland these six sit alongside the local laws and regulations listed under drivers below; one system can evidence both. The detail is on the global hub: NIS2 explained →
How to achieve NIS2 compliance in Poland
One team from the Frankfurt office carries the work from scoping to sign-off. Clients in Poland are served from Sterling's Frankfurt office, on-site where the work needs it and remotely otherwise.
- Discovery call and scopeEntities, locations, regulators and target date, agreed before any proposal.
- Gap assessment against NIS2 and the Polish requirements that apply to youControls you already run for your regulators and customers are reused, not rebuilt.
- Your system built with your team in EffivityRisks, controls, evidence, incidents and reviews in one live system the auditor can see.
- Internal audit, management review and corrective actionsYour internal auditors trained by Sterling; the evidence proven before any external review.
- Reviews by regulators, customers and auditorsSterling supports the reviews your regulators, customers and auditors run.
- End to end, from one team
- Effivity ISO & GRC software
- Preferential Sterling Academy access, with complimentary awareness training for your people
- Internal auditor training for your audit team, as applicable to your standard
- Vulnerability assessment on ISMS engagements
The Sterling Promise: 100% on-time completion, 100% success, 8,100+ client engagements.Sterling does not certify. Certification decisions stay with independent bodies.
How long does NIS2 compliance take in Poland?
There is no standard duration: it depends on your scope and on how much of the system already runs. In Poland these are the factors that set the timeline.
- Whether the entity is a key or an important entity
- Existing information security management system or ISO/IEC 27001 certification
- Supply-chain and supplier assessment
- Management training, incident handling and reporting arrangements
Sterling agrees a dated plan with you on the discovery call, once the scope is known.
How much does NIS2 compliance cost in Poland?
The cost has two parts: the consulting work to build and prove the system, and any external assessor’s fees, which are quoted separately. In Poland these factors move both.
- Size and number of entities in scope
- Control remediation across the regulated entity
- Security audit by an independent auditor where the Act requires it
- Tooling for continuous monitoring and incident handling
Sterling gives one customised, all-inclusive proposal after the discovery call, never before the scope is agreed.
NIS2 consultants and assessors in Poland
Two different organisations are involved. A consultant helps you build the system and prove it works; your regulators, customers and auditors then audits or assesses it and decides. Keeping the two separate is what makes the result credible to buyers and regulators.
- Check that the body’s accreditation or approval covers NIS2 and your sector, and that its certificates can be verified online.
- Ask the consultant how the local requirements in Poland are mapped into the same system, so nothing runs twice.
- Ask for client references in your sector; Sterling’s client letters are available on request.
- Agree who owns the evidence and the tool after the engagement; with Sterling the system stays yours, in Effivity.
Laws and regulations that drive NIS2 in Poland (4)
| Instrument | How it treats the standard |
|---|---|
| Ustawa z dnia 23 stycznia 2026 r. o zmianie ustawy o krajowym systemie cyberbezpieczeństwa oraz niektórych innych ustaw (Dz. U. 2026 poz. 252) | The instrument itself States that it implements Directive (EU) 2022/2555 (NIS 2); published in the Dziennik Ustaw on 2 March 2026 and shown by ISAP as in force. |
| National Cybersecurity System Act, Art. 8 as amended | The instrument itself A key or important entity implements an information security management system with systematic risk assessment and the listed technical and organisational measures, including supply-chain security and business continuity plans; ISO/IEC 27001 is not named. |
| National Cybersecurity System Act, Art. 15 as amended (audit) | The instrument itself A key entity carries out a security audit of its information system at its own cost at the interval the Act sets, and the competent authority can order an external audit. |
| National Cybersecurity System Act, Art. 41 as amended (competent authorities) | The instrument itself Competent authorities are named by sector: ministers for energy, transport, health, water, digital affairs, economy, agriculture and climate, the Prezes Urzędu Komunikacji Elektronicznej for electronic communications and postal services, and the Komisja Nadzoru Finansowego for banking and financial market infrastructure. |
Accreditation, audit language and remote audits in Poland
Compliance, not certification: there is no NIS2 certificate. Entities implement the Art. 8 information security management system, document their measures, have key entities audited and report incidents as the Act requires. ISO/IEC 27001 certification by an accredited body can support the evidence but is not named in the Act and does not by itself prove compliance. Edition and transition details: NIS2 hub →
Audit language
Competent authorities work in Polish; reports and registrations are filed in Polish. Internal documentation can be kept in Polish or English.
Remote and on-site
Gap assessment and documentation can be remote or on-site; audits of key entities follow the Act and the authority's requirements.
NIS2 in Poland: questions clients ask
Is the Polish NIS2 law in force?
Yes. The Act of 23 January 2026 amending the National Cybersecurity System Act, which states that it implements Directive (EU) 2022/2555, was published in the Dziennik Ustaw on 2 March 2026 as item 252, and the official ISAP system lists it as in force. Transitional provisions apply to existing operators, so confirm your timetable with counsel.
Which authority supervises my sector under the Polish NIS2 law?
It depends on the sector. Art. 41 names ministers for energy, transport, health, water, digital affairs, economy and other sectors, the Prezes Urzędu Komunikacji Elektronicznej for electronic communications and postal services, and the Komisja Nadzoru Finansowego for banking and financial market infrastructure. Identify your sector in the Act's annexes and check with counsel which authority applies.
Does ISO 27001 certification satisfy the Polish NIS2 duties?
Not automatically. Art. 8 requires an information security management system with systematic risk assessment and a listed set of measures, and the Act does not name ISO/IEC 27001. A certified system is good supporting evidence, but your competent authority decides what is enough, so map the certificate to the Act's list of measures.
Do key entities have to commission security audits?
Yes. Art. 15 as amended requires a key entity to carry out a security audit of the information system used to provide its service, at its own cost, at the interval the Act sets. The competent authority can also order an external audit, including of an important entity after a serious incident. Confirm timing with counsel.
More on NIS2 for Polish organisations
Other standards Polish businesses ask Sterling for
Organisations in Poland often combine NIS2 with one of these, under one management system where the scopes allow.
Start with a free discovery call from the Frankfurt office
A Sterling consultant goes through your entities, your regulators and your target date with you. No proposal until the scope is agreed.
Sources
- Ustawa z dnia 23 stycznia 2026 r. o zmianie ustawy o krajowym systemie cyberbezpieczeństwa oraz niektórych innych ustaw (Dz. U. 2026 poz. 252) — api.sejm.gov.pl (accessed 7 Oct 2026)
- National Cybersecurity System Act, Art. 8 as amended — api.sejm.gov.pl (accessed 7 Oct 2026)
- National Cybersecurity System Act, Art. 15 as amended (audit) — api.sejm.gov.pl (accessed 7 Oct 2026)
- National Cybersecurity System Act, Art. 41 as amended (competent authorities) — api.sejm.gov.pl (accessed 7 Oct 2026)
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