NIS2 Becomes National Law: What Does This Mean for the Logistics Sector?

The cybersecurity landscape is on high alert. With the transposition of the NIS2 Directive into national legislation—known in the Netherlands as the Cybersecurity Act (Cyberbeveiligingswet, Cbw)—companies in vital sectors will face far-reaching obligations in the area of digital resilience. For the logistics sector, which forms the backbone of our modern economy, this legislation will have significant consequences. Although the Cybersecurity Act is expected to enter into force in the second quarter of 2026, organizations would be wise to start preparing now.

What Is NIS2 and Why Is It Becoming National Law Now?

The Network and Information Security Directive 2 (NIS2) is European legislation that entered into force on 16 January 2023. It replaces the earlier NIS1 Directive from 2016 and imposes much stricter requirements on organizations operating in essential and important sectors. The goal is clear: to achieve a higher common level of cybersecurity across the EU and to strengthen the digital and economic resilience of its Member States.

EU Member States were required to transpose the NIS2 Directive into national law by 17 October 2024. The Netherlands has experienced delays in implementation, but it is now almost certain that the Cybersecurity Act (Cbw)—the Dutch implementation of NIS2—will enter into force in the second quarter of 2026. The Cbw will replace the current Security of Network and Information Systems Act (Wbni).

Why Does NIS2 Have Such a Major Impact on the Logistics Sector?

The logistics and transport sector plays a crucial role in the global economy. Modern logistics processes are deeply intertwined with digital systems: from Warehouse Management Systems (WMS) and Transport Management Systems (TMS) to supply chain platforms, IoT devices, and real-time tracking solutions. A cyberattack on these systems can have far-reaching consequences—not only for individual companies, but for entire supply chains and even the broader economy.

For this reason, the transport sector is classified as an essential sector under the NIS2 Directive. More specifically, this includes:

• Air transport (essential entities)
• Rail transport (essential entities)
• Water transport (essential entities)
• Road transport and logistics service providers (depending on size and critical role, possibly classified as important entities)

In addition to large transport companies, SMEs in the logistics sector will also be indirectly affected. Large “essential entities” are required to assess and ensure the cybersecurity of their suppliers and partners throughout the supply chain.

What Are the Concrete Obligations Under NIS2?

Organizations that fall within the scope of NIS2 face four core obligations:

Duty of Care: 10 Mandatory Security Measures

NIS2 prescribes ten concrete cybersecurity measures that organizations must implement:

1. Risk analysis and information security policies
2. Incident handling – procedures for detection, response, and recovery
3. Business continuity – backup management and disaster recovery plans
4. Supply chain security – security requirements for suppliers and service providers
5. Security in the acquisition, development, and maintenance of network and information systems
6. Policies and procedures for the use of cryptography and encryption
7. Personnel security, access control, and asset management
8. Multi-factor authentication (MFA) and secure communications
9. Cybersecurity awareness, education, and training for staff
10. Use of cybersecurity hygiene solutions and basic cybersecurity practices

Incident Reporting Obligation

Significant cyber incidents must be reported to the National Cyber Security Centre (NCSC) within 24 hours of discovery. This applies to incidents that have a substantial operational impact or threaten business continuity.

Registration Obligation

Organizations covered by the directive must register with the Dutch government. This enables supervisory authorities to determine which organizations fall under the legislation and how oversight should be applied.

Audits and Supervision

Organizations must be able to demonstrably comply with the requirements. This means documenting cybersecurity measures and being prepared for audits by supervisory authorities.

Supply Chain Responsibility: SMEs Are Also Affected

One of the most impactful aspects of NIS2 is the supply chain security requirement. Large logistics companies classified as “essential” or “important” entities must impose cybersecurity requirements on their suppliers, carriers, and IT partners.

This has direct consequences for SMEs in the logistics sector. Even if an organization does not formally fall under NIS2, large customers may still require demonstrable compliance with comparable cybersecurity standards. Failure to do so could result in lost contracts or removal from the supply chain.

What Are the Penalties for Non-Compliance?

The NIS2 Directive introduces GDPR-style fines based on global turnover:

• Essential entities: up to €10 million or 2% of global annual turnover (whichever is higher)
• Important entities: up to €7 million or 1.4% of global annual turnover

In addition to financial penalties, non-compliance can lead to reputational damage, loss of customers, and operational disruptions. For logistics companies that rely on contracts with government bodies or large multinationals, non-compliance may even result in exclusion from public tenders.

How Can Logistics Companies Prepare?

Although the Cybersecurity Act will not enter into force until 2026, it is crucial to take action now:

1. Determine Whether Your Organization Falls Under NIS2

Assess whether your company belongs to a sector classified as “essential” or “important.” Organizations with more than 50 employees or annual turnover above €10 million are more likely to fall within scope.

2. Conduct a Cyber Risk Assessment

Identify which IT systems, data, and processes are critical to your operations. Where are the vulnerabilities? Which threats are realistic? This analysis forms the foundation of your security strategy.

3. Implement the 10 Mandatory Measures

Start systematically implementing the ten duty-of-care measures, such as multi-factor authentication, encryption, incident response plans, and employee training.

4. Ensure Business Continuity with Escrow Solutions

A key element of NIS2 is ensuring business continuity, even in the event of failure of software suppliers or IT service providers. Consider your WMS, TMS, or supply chain management platforms. What happens if a supplier goes bankrupt or a serious incident occurs?

This is where digital escrow comes into play. With a solution such as Escrow4All, critical source code, data, and technical documentation can be securely stored and remain accessible—even if a supplier becomes unavailable. This not only supports compliance with NIS2 continuity requirements but also strengthens operational resilience in unforeseen circumstances.

5. Document and Test Regularly

Ensure you can demonstrate compliance with NIS2 requirements. Document policies, conduct penetration tests, and rehearse incident response scenarios. Regulators and customers will expect evidence.

6. Prepare Your Incident Reporting Processes

Know how to report incidents to the NCSC. Establish internal protocols to ensure reporting within the required 24-hour timeframe.

Conclusion: Don’t Wait—Take Action Now

The transposition of NIS2 into national legislation marks a turning point for the logistics sector. Digital resilience is no longer a “nice to have,” but a legal obligation with far-reaching consequences. For transport companies and logistics service providers, this means that cybersecurity must become an integral part of corporate strategy.

By taking action now—ranging from risk assessments to implementing continuity solutions such as digital escrow—organizations can not only comply with the law but also strengthen their competitive position. In a market where customers increasingly scrutinize digital reliability, proactive compliance offers a strategic advantage.

The message is clear: don’t wait until the legislation takes effect. Start strengthening your digital resilience today.