Cybersecurity · Italy
Cybersecurity regulation in Italy (2026)
Italy shaded by its cybersecurity status
Italy has a comprehensive, multi-layered cybersecurity regime overseen by the National Cybersecurity Agency (ACN). It transposed the EU NIS2 Directive through Legislative Decree 138/2024 (in force 16 October 2024), and complements it with the national Law 90/2024 strengthening public-sector cyber resilience and the pre-existing National Cybersecurity Perimeter (DL 105/2019) for entities performing essential State functions. Breach and incident reporting to CSIRT Italia is mandatory under a tiered 24-hour/72-hour model.
Key points
Legislative Decree 138/2024 (in force 16 October 2024) implements EU Directive 2022/2555, designating ACN as the national competent authority and single point of contact. Italy widened the EU scope via national annexes to cover regional/local public administration, cultural heritage bodies and local public transport operators.
ACN opened the NIS2 registration window 1 December 2024–28 February 2025 on its service portal; by 31 March 2025 it compiled the list of in-scope essential and important entities, notifying inclusion/exclusion by 15 April 2025, with security obligations phasing in across 2025–2026.
Law No. 90/2024 (in force 17 July 2024) strengthens national cybersecurity and toughens computer-crime provisions, imposing on public administrations duties to report incidents, appoint a cyber contact point, adopt at least 26 minimum protection measures and set up an internal cyber-risk structure.
The Perimetro di Sicurezza Nazionale Cibernetica (Decree-Law 105/2019, converted by Law 133/2019, with DPCM 131/2020 and DPCM 81/2021) covers public/private operators performing essential State functions across strategic sectors, requiring annual ICT asset lists, prescribed security measures and incident notification to CSIRT; fines reach up to €1.8 million.
Significant incidents must be reported to CSIRT Italia under a tiered timeline: an initial early-warning within 24 hours and a fuller notification within 72 hours (with a final report typically within 30 days under NIS2). Law 90/2024 entities follow the 24h/72h model, and personal-data breaches additionally fall under GDPR notification to the Garante.
ACN adopted a binding incident taxonomy via its Determina of 9 February 2026 (Official Gazette No. 39, 17 February 2026), with Allegato A defining notifiable incident codes (e.g., confidentiality loss IS-1, integrity loss IS-2, service-level violations IS-3), applicable from publication.
Timeline - major decisions & events
Following the Dec 2024–Feb 2025 registration window, Italy's National Cybersecurity Agency (ACN) compiled and notified the list of essential/important entities under the NIS2 decree and began defining baseline security obligations, with full compliance phased through October 2026. This operationalized Italy's largest-ever expansion of cybersecurity duties across the economy.
ACN ↗The Italian Data Protection Authority (Garante) ordered an immediate limitation on processing of Italian users' data by DeepSeek over transparency, legal-basis and cross-border (China) data-storage concerns, effectively blocking the service pending its inquiry. It underscored Italy's aggressive posture on data and AI-related security risks.
The Record ↗The Garante concluded its ChatGPT investigation, fining OpenAI €15 million for GDPR breaches including unlawful processing and inadequate transparency/age-verification. It is one of Europe's most significant enforcement actions against a generative-AI provider.
IAPP ↗Italy's Legislative Decree No. 138 of 4 September 2024 (published 1 Oct, in force 16 Oct) transposed the EU NIS2 Directive, repealing the 2018 NIS framework and vastly expanding sectoral scope, governance duties, incident reporting and ACN supervision over 'essential' and 'important' entities. It is the cornerstone of Italy's current cybersecurity obligations.
Digital Policy Alert ↗Approved 28 June and in force 17 July 2024, Law No. 90 widened mandatory incident-notification duties (24-hour reporting for public administrations), mandated cybersecurity contact points and cryptographic standards in the public sector, and raised criminal penalties for unauthorized access and interception. It tightened the domestic regime ahead of NIS2.
Cleary Gottlieb ↗ACN published Italy's first national cybersecurity strategy, setting 82 measures through 2026 around protection of strategic assets, threat/crisis response, and digital autonomy, backed by roughly €2.2 billion in funding. It established the strategic roadmap guiding all subsequent cyber policy.
ACN ↗Amid the Russia-Ukraine war, ACN issued guidance urging public administrations to diversify away from antivirus and software from Russia-linked vendors (notably Kaspersky), citing national-security risk from highly invasive software. The move signaled supply-chain/technological-sovereignty as a core security concern.
Decode39 ↗A RansomEXX attack on LazioCrea encrypted the region's datacenter and took down the COVID-19 vaccination booking portal for days, traced to compromised admin credentials. The high-profile incident exposed public-sector vulnerabilities and accelerated cyber-governance reforms.
Computer Weekly ↗Decree-Law No. 82 of 14 June 2021 created the Agenzia per la Cybersicurezza Nazionale, consolidating national cyber competencies, hosting the CSIRT Italia and serving as NIS authority; it began operations on 1 September 2021. ACN became the central pillar of Italy's cybersecurity architecture.
ACN ↗Decree-Law No. 105/2019 (converted by Law 133/2019) established the Perimetro di Sicurezza Nazionale Cibernetica, requiring designated public and private entities running critical functions to inventory strategic ICT assets, meet security measures, notify incidents and submit ICT procurement for vetting. It built Italy's regime for protecting the most critical systems.
ACN ↗Italy's first dedicated cybersecurity law implemented the EU NIS Directive, imposing security and incident-notification duties on operators of essential services and digital service providers, creating CSIRT Italia and mandating a national cyber strategy. It laid the foundation later superseded by NIS2.
DLA Piper ↗Italy - other topics
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