What already applies
- Since 17 February 2026 the obligations apply to every organisation in scope.
- Up to and including 1 June 2026 sanctions were halved (Section 51). After that date they apply in full.
- A significant incident is reported to the sector CSIRT (computer security incident response team): an early warning within 24 hours, a notification within 72 hours and a final report within one month (Art. 23(5)).
- Changes to the organisation's data are reported to the authority within two weeks.
- Certain digital providers submit their own data to the authority within two months.
What is still coming
- A Council of Ministers decision on the competent authorities and the designation methodology (Section 47(1)). The statutory deadline was six months from entry into force, around mid-August 2026. Up to issue 94 of 13 October 2026 no methodology for designating essential and important entities had been published.
- Designation of essential and important entities by the authorities within five months of that decision (Section 48). This deadline is for the authorities, not a date businesses can wait for.
- A new ordinance on minimum measures under Art. 3. The statutory deadline is eight months, around mid-October 2026. Up to issue 94 of 13 October 2026 no new ordinance had been published, so the 2019 ordinance applies.
- A national strategy: the statutory deadline is nine months.
Recurring deadlines
- Management training every two years.
- An annual internal audit under the ordinance.
- A review of the risk assessment and measures after material changes.
What to do now
Do not wait for a designation letter. Check whether you are in scope, approve the measures with a management decision and prepare the incident-reporting process. The quick assessment shows where to start in 10 working days.