With the NIS-2 Directive, the Cyber Resilience Act, and eIDAS 2.0 including the European Digital Identity Wallet (EUDI Wallet), digital security in Europe becomes binding. From 2026 onward, these regulatory frameworks fully apply in operational practice – no longer as guidelines, but as enforceable requirements.

For companies, this means: from 2026, sanctions, liability risks, and personal responsibility of executive management apply without restriction. Supervisory authorities will then be able to sanction violations directly, impose fines, and formally challenge organizational deficiencies. Digital security thus becomes a central business and regulatory control variable rather than a purely technical concern.

The European mid-sized business sector is particularly affected. Companies that were not previously classified as operators of critical infrastructure will fall clearly and verifiably under the scope of the NIS-2 Directive from 2026 onward. For these organizations, the question is no longer whether action is required, but how regulatory requirements can be implemented permanently, in a technically robust manner, and in a way that can be demonstrated to supervisory authorities. Transitional solutions, informal processes, and purely documentation-based approaches lose their protective effect from 2026 onward.

NIS-2: From a marginal topic to a management responsibility

The NIS-2 Directive has been in force since the end of 2024. From 2026 onward, violations will no longer merely be noted, but actively sanctioned. The directive significantly expands the group of obligated companies while simultaneously tightening requirements for governance, risk management, and demonstrability.

In Germany alone, more than 30,000 companies newly or explicitly fall under NIS-2. Affected are mid-sized companies with approximately 50 or more employees in sectors such as energy, water, waste management, manufacturing, logistics, food production, healthcare, digital services, and certain industrial supplier segments.

What is new is not only the scope, but the regulatory logic itself.

NIS-2 requires transparent, verifiable, and documentable measures. Companies must be able to demonstrate at any time:

·       who has access to which systems,

·       on what basis authorizations were granted,

·       how incidents are detected, reported, and handled,

·       and how organizational responsibility is defined.

This brings into focus an area that has long been underestimated: digital identities and access control.

Why identities become the key to NIS-2 compliance

In traditional IT security models, networks, firewalls, and perimeter protection dominated. In hybrid infrastructures with cloud services, mobile devices, external service providers, and remote work structures, these models no longer suffice.

NIS-2 reflects this reality. The directive explicitly requires:

·       controlled access rights,

·       minimization of privileges,

·       clear responsibilities,

·       traceability and reporting obligations,

·       protection against misuse of internal and external access.

In practice, this can only be implemented through identity and access management structures. Digital identities thus become the central control point of regulatory security. Organizations that do not properly manage identities cannot comply with NIS-2.

Structural deficits are particularly evident in mid-sized companies. Many organizations operate with historically grown user accounts, shared credentials, missing offboarding processes, or unclear role models. Such structures were long tolerated – but under NIS-2 they become an immediate liability risk.

The NIS-2 SMB market

The so-called “NIS 2 SMB market” is one of the most underestimated areas of European cyber and security regulation.

At the beginning of 2026, a large proportion of affected companies still do not know:

·       that they fall under NIS-2,

·       which concrete obligations arise from it,

·       which technical measures are required,

·       or how these can be implemented economically.

At the same time, there is a lack of standardized, practical solutions. Many offerings are either designed for large enterprises or remain limited to consulting, audits, and documentation. But NIS-2 cannot be “consulted away.” Without technical implementation, compliance remains formal, but not resilient.

This is precisely where new application areas emerge for integrated security and identity solutions.

Regulation requires technology – not just processes

A central misconception among many companies is to treat NIS-2 primarily as a documentation and organizational task. In reality, the directive requires technical enforcement.

Compliance is not achieved through policies alone, but through systems that:

·       enforce access,

·       technically restrict authorizations,

·       automatically capture events,

·       generate audit trails,

·       and support reporting processes.

Without such systems, neither internal controls nor external audits can be conducted reliably. For executive management, this means: responsibility cannot be delegated if the technical foundation is missing.

KOBIL products in the context of NIS-2 implementation

For decades, KOBIL has been developing security and identity solutions with the goal of implementing regulatory requirements technically—not merely fulfilling them formally. All KOBIL products comply with European data protection and security standards and are aligned with regulatory requirements such as GDPR, NIS-2, and eIDAS 2.0.

KOBIL SuperApp: Digital identity as a sovereign trust layer

The KOBIL SuperApp combines digital identity, secure communication, authentication, and transactional processes within a unified architecture. For companies affected by NIS-2, it enables a clear assignment of identities, roles, and access rights across organizational and system boundaries. Identity-based access control thus becomes a central control layer rather than an isolated solution.

KOBIL mPower: Controlled digital workplace

KOBIL mPower provides the foundation for a sovereign digital workplace in which identity, applications, documents, and approval processes are centrally integrated. For the NIS-2 mid-market, integrated traceability is particularly relevant: accesses, approvals, and changes are systematically recorded and made auditable. Security and compliance are embedded in the architecture from the outset.

KOBIL AppShield: Protecting mobile applications under regulatory requirements

Mobile applications are increasingly part of critical business processes—often without adequate protection. KOBIL AppShield addresses this risk. The solution protects existing mobile apps at the binary level without code changes, enabling compliant use even under NIS-2 conditions. Attacks, manipulation, and misuse are mitigated and detected in a traceable manner.

Together, these solutions address a core regulatory requirement: technically enforceable control.

Outlook 2026: From compliance to operational resilience

NIS-2 is not a one-time project, but the entry point into a permanently tightened security and liability regime. Additional regulations such as the Cyber Resilience Act will further reinforce this development. Companies that implement only the minimum requirements today will need to retrofit again in the near future.

The sustainable approach is to treat security, identity, and access control as strategic infrastructure – comparable to financial or production systems. Those who master this control not only meet regulatory requirements, but also gain operational stability and strategic flexibility.

Key Facts: NIS-2 and the European SMB market in 2026

·       From 2026 onward, the NIS-2 Directive affects more than 30,000 mid-sized companies in Germany alone.

·       Sanctions, liability risks, and personal responsibility of executive management apply in full.

·       Digital identities and access control are central technical requirements of the directive.

·       Documentation alone is insufficient – NIS-2 requires verifiable technical implementation.

·       Many affected companies are still unaware that they are regulated.

·       Demand for integrated, practical security and identity solutions is high.

·        KOBIL products address NIS-2 requirements through identity, access control, traceability, and mobile security.

·        2026 marks the transition from formal compliance to operational digital resilience.