Cybersecurity ยท Italy
Cybersecurity law & regulation in Italy (2026)
Italy shaded by its cybersecurity status
Cybersecurity in Italy: comprehensive law.
FrameworkLegislative Decree 138/2024 (transposing EU NIS2 Directive 2022/2555) and Law 90/2024 (national cybersecurity law), supervised by the Agenzia per la Cybersicurezza Nazionale (ACN) which also hosts CSIRT Italia; sectoral layers include DORA for financial entities (Banca d'Italia, CONSOB, IVASS) and GDPR enforcement by the Garante.
Italy operates a comprehensive, in-force cybersecurity regime. NIS2 was transposed through Legislative Decree 138/2024 (published 1 October 2024, entered into force 16 October 2024), making the National Cybersecurity Agency (ACN) the single competent authority and point of contact, with CSIRT Italia handling incident notifications. This is layered with Law 90/2024 on the National Cybersecurity Perimeter (public administrations and critical operators), sector regimes such as DORA for finance, and GDPR Article 33 breach notification duties.
NIS2 & cybersecurity law in Italy
In Italy, baseline cybersecurity obligations come from the EU NIS2 Directive, transposed into national law, which sets risk-management and incident-reporting duties for essential and important entities.
- Framework
- the NIS2 Directive (EU) 2022/2555, transposed into national law
- Approach
- cybersecurity risk-management measures plus mandatory incident reporting for in-scope entities
- Applies to
- medium and large entities in critical sectors: energy, transport, banking, health, water, digital infrastructure, ICT and public administration
- Incident reporting
- an early warning within 24 hours and a full notification within 72 hours to the national CSIRT
- Maximum fine
- up to โฌ10 million or 2% of global annual turnover for essential entities
- Oversight
- the national competent authority and CSIRT designated under NIS2
NIS2 is a directive, so Italy implements it through national law; exact scope and deadlines can vary slightly by transposition.
NIS2 in Italy: FAQ
Yes. As an EU member, Italy has transposed the NIS2 Directive (EU) 2022/2555 into national law, covering essential and important entities in critical sectors.
Medium and large organisations in sectors such as energy, transport, banking, health, water, digital infrastructure and public administration.
An early warning within 24 hours of becoming aware and a fuller incident notification within 72 hours to the national CSIRT.
Up to โฌ10 million or 2% of global annual turnover for essential entities, with lower ceilings for important entities.
Key points
Legislative Decree 138/2024 transposes NIS2 and entered into force on 16 October 2024. It covers roughly 18 sectors and over 80 entity types, classified as 'essential' or 'important', with scaled security, governance and reporting duties.
The Agenzia per la Cybersicurezza Nazionale (established by Decree-Law 82/2021) is the national NIS competent authority and single point of contact; CSIRT Italia, embedded in ACN, is the technical-operational hub for mandatory and voluntary incident notifications.
Essential and important entities under NIS2 must submit an early warning to CSIRT Italia within 24 hours of a significant incident, a full incident notification within 72 hours, and a final report within one month. Public bodies and perimeter entities under Law 90/2024 face parallel 24/72-hour duties.
In-scope entities had to register on the ACN national platform by 28 February 2025 (digital/cloud/MSSPs earlier, by 17 January 2025), update management-body information by 31 May 2025, implement baseline security measures by autumn 2026, with ACN inspections from October 2026.
Law 90/2024 (in force July 2024) strengthens duties for public administrations and perimeter operators, expanding mandatory incident notifications. ACN's Determina of 9 February 2026 (Gazzetta Ufficiale, 17 February 2026) formalised the incident taxonomy that triggers reporting.
Regulation (EU) 2022/2554 (DORA) applies to Italian financial entities since 17 January 2025. Banca d'Italia receives major ICT incident reports and significant cyber-threat notifications; Banca d'Italia, CONSOB and IVASS jointly supervise and run the TIBER-IT advanced testing framework.
Under Legislative Decree 138/2024, essential entities face administrative fines up to โฌ10 million or 2% of global annual turnover (whichever is higher); important entities up to โฌ7 million or 1.4% of global turnover.
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 โThe 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 โThe Garante concluded its ChatGPT investigation, fining OpenAI โฌ15 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 โItaly'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 โApproved 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 โACN 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 โฌ2.2 billion in funding. It established the strategic roadmap guiding all subsequent cyber policy.
ACN โAmid 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 โA 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 โDecree-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 โDecree-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 โItaly'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 โItaly - other topics
Cybersecurity in other countries
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