NIS2 · ManufacturingGuide

    NIS2 for manufacturers

    Act No. 264/2025 Coll. does not regulate all manufacturing, only selected fields, and medium and large companies in them mostly fall in the lower-obligation regime. Below you'll find which fields are covered, what the lower regime asks of you, and how to approach it on the production network.

    Summary

    In short

    • The Act covers medium and large enterprises. A company is at least medium-sized with 50 or more employees, or when its annual turnover and its balance sheet both exceed EUR 10 million. Partner and linked enterprises count too.
    • The regulated fields are the manufacture of electronics, electrical equipment, machinery, vehicles and parts, other transport equipment, food, chemicals and medical devices, mostly in the lower-obligation regime. The higher regime includes, for example, series production of passenger cars and group-B sites under the major-accident prevention act.
    • You notify the service through the NÚKIB Portal within 60 days of meeting the criteria. From the delivery of the registration decision you have a year to put the measures in place.
    • Non-compliance in the lower regime carries fines up to CZK 175 million or 1.4% of worldwide turnover, whichever is higher; failing to notify the service, up to CZK 250 million or 2%.
    Scope

    Which manufacturing services the Act regulates

    The services in the annex to decree 408/2025 Coll. that concern manufacturing, food, chemicals, waste and medical devices. The regime is set by the specific service, and one organisation has one regime.

    Which manufacturing services the Act regulates
    ServiceRegimeCondition
    Manufacture of computers, electronic and optical products (CZ-NACE 26)LowerMedium or large enterprise
    Manufacture of electrical equipment (CZ-NACE 27)LowerMedium or large enterprise
    Manufacture of machinery and equipment (CZ-NACE 28)LowerMedium or large enterprise
    Series production of passenger cars (CZ-NACE 29)HigherNo size condition
    Other manufacture of motor vehicles, trailers, semi-trailers and parts (CZ-NACE 29)LowerMedium or large enterprise
    Manufacture of other transport equipment (CZ-NACE 30)LowerMedium or large enterprise
    Industrial production and processing of food, food wholesaleLowerMedium or large enterprise
    Manufacture and placing on the market of chemicals, and production of articles, under REACHLowerMedium or large enterprise
    Site under the major-accident prevention act, group BHigherMedium or large enterprise
    Site under the major-accident prevention act, group ALowerMedium or large enterprise
    Manufacture of medical devices and in vitro diagnosticsLowerMedium or large enterprise
    Waste facilities (except storage of one's own waste), trading, brokering and transportLowerMedium or large enterprise, and at least 5% of turnover from the service

    Manufacture of human medicines and active substances, and of medical devices on the critical list, is in the higher regime for large enterprises and the lower one for medium ones. Other fields, such as metalworking or plastics processing, are not among the regulated services unless the company provides another service from the annex. Check the classification in the annex to decree 408/2025 Coll. or with the calculator on the NÚKIB Portal.

    Duties

    What the lower-obligation regime asks of you

    Duties under the Act and decree 410/2025 Coll. The higher regime follows the stricter decree 409/2025 Coll.; the NIS2 page has the details.

    1. Notify the service

      Through the NÚKIB Portal within 60 days of meeting the criteria. NÚKIB then issues a registration decision; within 30 days of its delivery you report contact and supplementary details.

    2. Management and a responsible person

      Top management appoints a person responsible for cybersecurity, takes training itself, provides the resources and demonstrably follows how the measures are being met.

    3. Security measures

      13 measures under decree 410/2025 Coll., in place no later than 1 year after the registration decision is delivered.

    4. Continuity and backups

      Set the priority and order for restoring technical assets, name who is responsible, and back up data and configurations regularly.

    5. Incident reporting

      Only incidents with significant impact, and to the National CERT: an initial report within 24 hours, a notification within 72 hours, a final report within 30 days of that notification.

    6. Suppliers

      For suppliers delivering into the service's defined scope, assess their risks and put the requirements of Annex 2 to decree 410/2025 Coll. into the contracts.

    OT

    The production network and control systems

    The Act does not distinguish IT from OT; it speaks of the assets a regulated service runs on, and in manufacturing those often include the lines and control systems. Even in the lower regime, decree 410/2025 Coll. explicitly asks for network segmentation, limited remote connections and configuration backups, and the higher regime has a separate measure for industrial and control assets. Here is our recommendation on where to start.

    1. An asset register that includes production

      Control systems, operator stations and production network devices belong in it when the service stands or falls with them.

    2. A separate production network

      The production network separated from the office one, with defined crossings, so ransomware that reaches the office does not reach the machines.

    3. Supplier access to machines

      Machine builders' service access through a controlled, time-limited and logged channel instead of standing remote connections. The decree asks for remote connections to be limited to what is necessary and for a record of who uses them.

    4. Configuration backups

      Backups of control-system programs and configurations, with restores that have been tested. They decide how fast production restarts.

    5. Detection at the IT/OT boundary

      Monitoring of the crossing between office and production, where attacks usually spill over, so a significant incident is reported inside the statutory window.

    FAQ

    Frequently asked questions

    Straight answers to what clients ask us most.

    Yes, if the company is a medium or large enterprise, meaning 50 or more employees, or annual turnover and balance sheet both above EUR 10 million. Manufacture of machinery and equipment (CZ-NACE 28) is in the lower-obligation regime under the annex to decree 408/2025 Coll. The company notifies the service through the NÚKIB Portal within 60 days of meeting the criteria and, from the delivery of the registration decision, has a year to put the 13 measures of decree 410/2025 Coll. in place.

    No. Within manufacturing, the Act regulates electronics, electrical equipment, machinery, motor vehicles and parts, and other transport equipment (CZ-NACE 26 to 30), plus industrial food production, chemicals under REACH, medicines and medical devices. Metalworking, plastics processing or furniture making are not among the regulated services unless the company provides another service from the annex to decree 408/2025 Coll.

    Series production of passenger cars is in the higher-obligation regime. The rest of CZ-NACE division 29, meaning trucks, buses, trailers, semi-trailers and parts for car makers, is in the lower regime for medium and large enterprises. Manufacture and distribution of chemicals under REACH is in the lower regime. Operators of sites under the major-accident prevention act that are medium or large enterprises are in the higher regime with a group-B site and in the lower one with a group-A site. One organisation has one regime, so a single service in the higher regime moves the whole organisation into it.

    Yes. The Act covers waste-facility operators, waste traders, brokers and carriers that are medium or large enterprises and earned at least 5% of their turnover from that service in the last accounting period. Storing waste from the operator's own activity does not count. All of these services are in the lower-obligation regime, so they report incidents with significant impact to the National CERT and implement the measures of decree 410/2025 Coll.

    The Act does not distinguish IT from OT; it speaks of the assets a regulated service runs on. Even in the lower regime, decree 410/2025 Coll. explicitly requires network segmentation, limited remote connections and backups of technical-asset configurations, and the higher regime has a separate measure for industrial and control assets. Where production runs on control systems, we recommend including them in the asset register, the recovery plans and monitoring.

    It can still be in scope, but only if its annual turnover and its balance sheet both exceed EUR 10 million; turnover alone is not enough. Partner and linked enterprises count, typically the parent and sister companies, except those whose technical assets are fully separated (Section 7 of the Act). Staff are counted in annual work units, roughly full-time equivalents, and a change of size takes effect only after two consecutive accounting periods.

    In the lower-obligation regime, to the National CERT, and only incidents with significant impact: an initial report within 24 hours of detection, a notification within 72 hours and a final report within 30 days of that notification. A manufacturer in the higher regime, such as series production of passenger cars, reports to NÚKIB. The reporting duty applies no later than one year after the registration decision is delivered.

    Verify

    Sources

    We checked these facts on 29 September 2026 directly in the Act, the decrees and with NÚKIB.

    This page is not legal advice. Check your service's classification in the annex to decree 408/2025 Coll. or with NÚKIB.

    Is your production in scope of NIS2?

    We'll go through the classification, the deadlines and the state of your production network with you, and propose a plan that fits in the year.