The EU’s NIS2 directive takes effect in October 2024 and massively tightens cybersecurity requirements. But does it also affect Swiss companies? The answer is more complex than a simple yes or no.
This guide explains what NIS2 is, which companies are affected, what Switzerland’s position is, and what practical consequences Swiss companies with EU activities face.
What Is NIS2?
The Basics
NIS2 = Network and Information Security Directive 2
Predecessor: NIS1 directive (2016), the first EU-wide cybersecurity regulation.
Why NIS2? NIS1 was too weak, too many gaps, too little harmonisation between member states. Cyber threats have increased massively.
Goal of NIS2:
- Higher cybersecurity level in the EU
- Harmonization between member states
- More companies covered
- Harsher penalties for non-compliance
Core Elements
1. Extended Sector Coverage
NIS1: 7 sectors (energy, transport, banking, etc.)
NIS2: 18 sectors, including:
- Energy (electricity, gas, oil, hydrogen)
- Transport (air, rail, water, road)
- Banking & financial market infrastructure
- Healthcare
- Drinking water & wastewater
- Digital infrastructure (cloud, DNS, TLD)
- ICT service management (managed services)
- Public administration
- Space
- Chemicals
- Food
- Production of critical products (medical devices, etc.)
- Postal & courier services
- Waste management
- Research
- Digital providers (online marketplaces, search engines, social media)
2. Size Thresholds
Essential Entities:
- Medium to large companies
-
50 employees OR
-
EUR 10 million annual turnover
Important Entities:
- Smaller companies in critical sectors
-
50 employees OR
-
EUR 10 million annual turnover
Exceptions:
- Micro-enterprises (<10 employees and <EUR 2 million turnover) mostly exempt
- But: Critical services may still be covered
3. Cybersecurity Requirements
Companies must:
- Implement risk management
- Ensure business continuity (backup, disaster recovery)
- Supply chain security (supplier risks)
- Security in development & operations
- Vulnerability management
- Incident response processes
- Use cryptography & encryption
- Security awareness training
- Multi-factor authentication (MFA)
- Zero-trust principles where possible
4. Reporting Obligations
For cybersecurity incidents:
First report: Within 24 hours of discovery (early warning)
Second report: Within 72 hours (detailed information)
Final report: Within 1 month (final analysis)
To: National cybersecurity authority (different in each EU country)
5. Sanctions
Essential entities: Fines up to EUR 10 million OR 2% of global annual turnover (whichever is higher)
Important entities: Fines up to EUR 7 million OR 1.4% of global annual turnover
Personal liability: Management can be held personally liable.
Timeline
January 18, 2023: NIS2 directive entered into force (at EU level)
October 17, 2024: Deadline for member states to transpose NIS2 into national law
From October 2024: NIS2 becomes effective in EU countries (depending on national implementation status)
Status today (2025): Most EU countries have implemented NIS2, some with delays.
Does NIS2 Affect Swiss Companies?
The Complex Answer
Directly: No. Switzerland is not an EU member, so NIS2 does not apply directly to Swiss companies.
Indirectly: Yes, under certain conditions.
When Swiss Companies Are Affected
Scenario 1: Subsidiaries in the EU
If: Your Swiss company has a branch, subsidiary, or office in an EU country.
Then: This EU entity is subject to NIS2 if:
- It operates in a covered sector
- It meets the size thresholds (>50 employees or >EUR 10 million turnover)
Real example: Swiss IT Service Provider
Situation: Swiss IT company (headquarters Zurich, 80 employees) has subsidiary in Germany (30 employees).
NIS2 relevance:
- German subsidiary is subject to NIS2 (sector: ICT service management)
- Must meet cybersecurity requirements
- Must report incidents
- Must be compliant by October 2024
Practical consequence: Swiss parent company must support German subsidiary (often shared IT systems).
Scenario 2: Critical Services in the EU
If: Your Swiss company provides critical services to EU customers.
Examples:
- Cloud services for EU companies (IaaS, PaaS, SaaS)
- Managed security services for EU companies
- DNS services
- Content delivery networks (CDN)
- Digital services (online marketplaces, search engines)
Then: You may be considered a “service provider for essential entities” and must meet NIS2 requirements.
Real example: Swiss Cloud Provider
Situation: Swiss cloud provider, 40% customers in EU, offers IaaS.
NIS2 relevance:
- Digital infrastructure (cloud) is NIS2 sector
- Services for EU customers → affected
- Must meet cybersecurity standards
- Incident reporting obligation for EU-related incidents
Practically: Compliance needed to avoid losing EU customers.
Scenario 3: Supplier for NIS2-Obligated Companies
If: Your Swiss company is a supplier to EU companies that fall under NIS2.
NIS2 requirement: Supply chain security, companies must manage risks at suppliers.
Practical consequence: EU customers will require from you:
- Evidence of cybersecurity measures
- Certifications (ISO 27001, etc.)
- Contractual security clauses
- Incident notification obligations
Not directly NIS2-obligated, but: Commercial pressure to retain EU customers.
Real example: Swiss Software Manufacturer
Situation: Swiss SaaS provider, sells HR software to EU companies (e.g., hospitals, administrations).
Impact:
- EU customers (hospitals = NIS2-obligated) check suppliers
- Require ISO 27001, SOC 2, NIS2-like controls
- Contract includes security audits, incident notification
Without compliance: Risk of losing EU contracts.
Scenario 4: Cross-border Activities
If: Your Swiss company operates physically in EU (e.g., transport, energy, critical infrastructure).
Example:
- Swiss transport company drives in EU
- Swiss energy company operates facilities in EU border region
Then: EU activities are subject to local regulation including NIS2.
Summary: Are You Affected?
Checklist:
- Do you have a branch/subsidiary in EU?
- Do you offer critical services to EU customers (cloud, DNS, managed services)?
- Are you a supplier to NIS2-obligated EU companies?
- Do you operate physically in EU (transport, energy, infrastructure)?
- Are you active in a NIS2 sector (see list above)?
- Do you meet size criteria (>50 employees or >EUR 10 million turnover)?
If multiple answers are “Yes”: NIS2 probably affects you indirectly.
Switzerland’s Position on NIS2
Official Stance
Switzerland is not an EU member: NIS2 does not apply directly in Switzerland.
But: Switzerland recognises the importance of cybersecurity and is working on its own regulations.
Swiss Cybersecurity Regulation
Current Status (2025)
National Strategy for Protecting Switzerland from Cyber Risks (NCS):
- Strategic framework
- No binding regulation like NIS2
- Voluntary measures
Information Security Act (ISG):
- Applies to federal administration
- Not to private sector
Critical Infrastructures:
- Some sectors have special regulations (banks, energy)
- No thorough cybersecurity obligation like NIS2
FINMA (Financial Sector):
- Banks & insurance: Regulated IT risks (FINMA Circular 2008/21)
- Cybersecurity requirements similar to NIS2
Energy Sector:
- Electricity Supply Act (StromVG): Security requirements for critical infrastructure
- Similar to NIS2 energy sector
Healthcare:
- Varies by canton
- No national cybersecurity obligation (unlike NIS2)
Future Developments
Option 1: Swiss NIS Equivalent
Discussions ongoing: Federal Council is examining whether Switzerland needs its own NIS law.
Arguments for:
- Swiss companies in EU business need clarity
- Raise cybersecurity level in CH
- International compatibility (e.g., for data exchange with EU)
Arguments against:
- Regulatory burden for SMEs
- Swiss autonomy
- Existing sectoral regulation sufficient
Status: No decision yet (as of 2025).
Option 2: Sectoral Approaches
More likely: Switzerland expands existing sectoral regulation:
- Energy: Extended cybersecurity obligations
- Health: National standards
- ICT: Voluntary standards (e.g., via industry associations)
Option 3: Equivalence Agreement with EU
If: Switzerland and EU negotiate equivalence (Swiss standards recognised as equivalent).
Advantage: Swiss companies would have easier EU market access.
Status: No concrete plans (as of 2025).
What This Means for Swiss Companies
Short-term (2024-2026):
- No direct Swiss NIS2 obligation
- But: EU activities affected (see scenarios above)
- Voluntary cybersecurity standards recommended
Medium-term (2026-2028):
- Possibly Swiss regulation
- Alignment with EU standards likely
- Early preparation pays off
Long-term (2028+):
- Swiss NIS equivalent conceivable
- International cybersecurity standards become standard
NIS2 Requirements in Detail
What Must Affected Companies Do?
1. Risk Management & Governance
Requirement:
- Identify, assess, treat security risks
- Documented processes
- Regular reviews (at least annually)
- Management responsibility (not just IT)
Practically:
- Conduct risk assessment
- Build risk register
- Define treatment measures
- Involve board/management
Tools:
- ISO 27005 (Risk Management)
- NIST Cybersecurity Framework
- BSI IT-Grundschutz
2. Business Continuity & Disaster Recovery
Requirement:
- Backup strategy (tested!)
- Disaster recovery plan
- Recovery time objectives (RTO/RPO)
- Regular tests (at least annually)
Practically:
- 3-2-1 backup rule (3 copies, 2 media, 1 offsite)
- Offline backups (protection from ransomware)
- Document DR tests
- Written recovery procedures
Costs: CHF 10,000-50,000 (depending on size)
3. Supply Chain Security
Requirement:
- Assess cybersecurity risks at suppliers
- Contractual security requirements
- Monitor critical suppliers
- Incident notification from suppliers
Practically:
- Supplier assessment (questionnaire)
- Identify critical suppliers
- Security clauses in contracts
- Require ISO 27001 from suppliers (where critical)
Example clause: “Supplier must report cybersecurity incidents within 24h.”
4. Security by Design
Requirement:
- Integrate security in development & operations
- Secure Software Development Lifecycle (SSDLC)
- Regular security tests
Practically:
- Code reviews with security focus
- Penetration testing (at least annually)
- Vulnerability scanning (continuous)
- Secure coding guidelines
For the penetration testing and red team assessments NIS2 envisions, Swiss-based RedTeam Partners can help companies demonstrate compliance through CREST-certified testing that aligns with EU expectations.
Especially relevant for software developers.
5. Vulnerability Management
Requirement:
- Fix known vulnerabilities promptly
- Patch management process
- Vulnerability disclosure policy
Practically:
- Deploy vulnerability scanner
- Patch schedule (critical patches: 48h)
- Inventory of all assets (what needs patching?)
- Emergency patches for zero-days
Tools:
- Qualys, Tenable Nessus, Rapid7
6. Incident Response
Requirement:
- Incident response plan
- Defined processes & responsibilities
- 24/7 availability
- Documentation & lessons learned
Practically:
- Create IR playbooks
- Define incident response team
- Prepare external support (forensics, legal)
- Incident response exercises (tabletop)
Costs: CHF 15,000-40,000 (setup + training)
7. Cryptography & Encryption
Requirement:
- Encrypt data (in transit & at rest)
- Modern crypto standards
- Key management
Practically:
- TLS 1.3 for data transmission
- AES-256 for data-at-rest
- Encrypted backups
- Hardware Security Modules (HSM) for keys (if highly critical)
Minimum:
- HTTPS everywhere
- Encrypted drives/storage
- Encrypted emails (where sensitive)
8. Security Awareness Training
Requirement:
- Regular training (at least annually)
- All employees
- Phishing awareness
- Documentation
Practically:
- Annual security training (1-2h)
- Phishing simulations (quarterly)
- Security newsletter (monthly)
- Onboarding security training
Costs: CHF 50-150 per employee/year
9. Multi-Factor Authentication (MFA)
Requirement:
- MFA for all privileged access
- MFA for remote access
- Modern MFA methods (not just SMS)
Practically:
- MFA for VPN, admin accounts, cloud services
- Authenticator apps (Google, Microsoft, etc.)
- Hardware tokens (YubiKey) for highest security
- Conditional access (risk-based)
Costs: CHF 20-50 per user/year (software) CHF 40-80 per user (hardware token)
10. Reporting Obligations
Requirement:
- Report cybersecurity incidents (see timeline above)
- To national authority (e.g., in DE: BSI, in FR: ANSSI)
- Structured information (use template)
Practically:
- Define process (who reports when?)
- Establish contact with authority (before incident!)
- Prepare reporting forms
- Involve legal counsel
Attention: Not every incident is reportable, only those with “significant impact.”
What is “significant”?
- Service interruption >X hours
- Data loss
- Financial damage
- Danger to health/safety
(National regulation defines thresholds)
Compliance Checklist
Technical measures:
- Firewall & network segmentation
- Endpoint protection (EDR)
- Security monitoring (SIEM/SOC)
- Vulnerability scanning
- Patch management
- Backup & recovery (tested)
- Encryption (data-at-rest & in-transit)
- MFA for all critical systems
- Access control (least privilege)
Organisational measures:
- Security policies documented
- Risk assessment conducted
- Incident response plan available
- Business continuity plan
- Supply chain security process
- Security awareness training
- Management reporting (quarterly)
Compliance:
- Reporting process defined (incidents)
- Contact with national authority
- Documentation (audits)
- Contractual arrangements (suppliers)
Practical Impact for Swiss Companies
Impact 1: Compliance Costs
For affected Swiss companies:
Initial costs (setup):
- Gap assessment: CHF 10,000-30,000
- Technical measures: CHF 30,000-150,000 (depending on size)
- Organisational measures: CHF 20,000-60,000
- External consulting: CHF 30,000-100,000
- Total setup: CHF 90,000-340,000
Ongoing costs (annually):
- Security monitoring (SOC): CHF 40,000-120,000
- Vulnerability management: CHF 10,000-30,000
- Training: CHF 5,000-20,000
- Audits & compliance: CHF 15,000-40,000
- Tool licences: CHF 20,000-60,000
- Total annually: CHF 90,000-270,000
For SMEs (50-100 employees): CHF 100,000-200,000 (setup) + CHF 50,000-100,000/year
For mid-sized (200-500 employees): CHF 200,000-400,000 (setup) + CHF 150,000-300,000/year
Impact 2: Competitive Advantage
Positive side:
Swiss companies that are NIS2-compliant:
- More attractive to EU customers
- Higher trust
- Competitive advantage over non-compliant providers
- Premium pricing possible (“NIS2-ready”)
Marketing: “Our service meets EU NIS2 standards, your data is secure.”
Real example: Swiss cloud provider advertises NIS2 compliance, wins EU hospital as customer (they are NIS2-obligated and need secure suppliers).
Impact 3: Supplier Selection
EU customers become more critical:
If you are a Swiss provider:
- EU customers check your cybersecurity
- Require certificates (ISO 27001, SOC 2)
- Contract clauses (security audits, incident notification)
Without compliance:
- Risk of losing EU tenders
- “Not EU-compliant” = exclusion criterion
Preparation pays off.
Impact 4: Cyber Insurance
Insurers adapt policies:
NIS2 compliance:
- Can reduce premiums
- Better conditions
- Higher coverage amounts
Non-compliance:
- Higher premiums
- Exclusions (e.g., no coverage for gross negligence)
- Regulatory fines not insured
Insurers ask: “Do you meet NIS2?” (even for Swiss companies)
Impact 5: M&A and Due Diligence
During company acquisitions:
NIS2 compliance is checked:
- Swiss company buys EU company → NIS2 liabilities
- EU company buys Swiss company → wants NIS2 compliance
Due diligence:
- Cybersecurity audit
- Compliance status
- Potential fines (if non-compliant)
Impact on company value: Non-compliance = risk discount (5-15% possible)
Industry-Specific Considerations
Financial Sector
Swiss banks & insurance:
Already heavily regulated:
- FINMA requirements similar to NIS2
- ISO 27001 often already in place
- Incident reporting obligations exist
NIS2 impact:
- EU activities: NIS2 compliance additionally
- Harmonization possible (FINMA ≈ NIS2)
- Additional effort limited
Recommendation: Gap assessment between FINMA and NIS2.
Healthcare
Swiss hospitals, clinics, pharma:
Currently:
- Regulated differently by canton
- No national cybersecurity obligation
NIS2 impact:
- EU business (e.g., clinical trials in EU): affected
- Suppliers to EU hospitals: indirectly affected
- Pressure for higher cybersecurity
Special feature: Patient data = particularly sensitive → NIS2 + GDPR.
Recommendation: Even without obligation, implement NIS2-like standards (reputation).
Energy & Critical Infrastructure
Swiss energy companies:
StromVG: Swiss electricity providers already have security obligations.
NIS2 impact:
- Cross-border networks (CH-EU): affected
- Export/import electricity: coordination needed
- Harmonise standards (StromVG & NIS2)
Recommendation: See NIS2 as complement to StromVG.
IT & Technology
Swiss IT service providers, SaaS, cloud:
High risk of being affected:
- Many EU customers
- Critical services (cloud = NIS2 sector)
- Supply chain (supplier to NIS2 companies)
NIS2 impact:
- Direct: EU branches
- Indirect: EU customers require compliance
- Competitive advantage through early compliance
Recommendation: ISO 27001 + NIS2 gap assessment start immediately.
Transport & Logistics
Swiss transport companies:
NIS2 covers:
- Air, rail, water, road (from certain size)
Switzerland-EU traffic:
- Cross-border → affected
- EU activities subject to NIS2
Special feature: Physical security + cybersecurity (e.g., air traffic control, rail control).
Recommendation: Don’t forget OT security (Operational Technology).
Production & Industry
Swiss industrial companies:
NIS2 sectors:
- Critical production (medical devices, chemicals, etc.)
Impact:
- EU plants: affected
- Supplier to EU industry: indirectly affected
- OT/ICS security (production facilities)
Recommendation: IEC 62443 (Industrial Security) + NIS2.
Implementation Recommendations for Swiss Companies
Phase 1: Clarification (1-2 months)
Step 1: Are we affected?
Questions:
- Do we have EU activities?
- Are we in NIS2 sector?
- Do we meet size criteria?
- Are we supplier to NIS2 companies?
Method:
- Internal analysis
- Or: External consulting (CHF 5,000-15,000)
Output: Clarity whether affected (direct/indirect/not).
Step 2: Gap assessment
If affected:
- Where are we today?
- What’s missing for NIS2 compliance?
- What measures needed?
Method:
- Self-assessment (NIS2 checklist)
- Or: External audit (CHF 10,000-30,000)
Output: Catalog of measures with prioritisation.
Phase 2: Planning (1-2 months)
Step 3: Create roadmap
Define:
- Which measures in what order?
- Timeline (NIS2 deadline: October 2024, if delayed possibly later)
- Budget (see costs above)
- Responsibilities
Prioritization:
- Critical gaps (high risk)
- Quick wins (easy to implement)
- Long-term projects (complex)
Step 4: Budget & resources
Clarify:
- Approve internal budget
- External support needed? (Consultants, MSSP)
- Personnel (dedicated role for compliance?)
Typical: CHF 100,000-300,000 for SMEs (see costs above).
Phase 3: Implementation (6-12 months)
Step 5: Technical measures
Example sequence:
- Activate MFA (weeks)
- Test backup & recovery (1-2 months)
- Deploy vulnerability scanning (1 month)
- Set up SIEM/SOC (2-4 months)
- Implement encryption (2-3 months)
Parallel: Organisational measures.
Step 6: Organisational measures
Example sequence:
- Document policies (1 month)
- Conduct risk assessment (1-2 months)
- Create incident response plan (1 month)
- Start security training (ongoing)
- Supply chain security process (2-3 months)
Step 7: Testing & documentation
Before go-live:
- Backup recovery test
- Incident response exercise (tabletop)
- Penetration test
- Complete documentation (for audit)
Duration: 1-2 months
Phase 4: Operations & Maintenance (ongoing)
Step 8: Monitoring & review
Ongoing:
- Security monitoring (24/7)
- Vulnerability management (weekly)
- Patch management (according to schedule)
- Incident response (as needed)
Regular:
- Risk review (quarterly)
- Management reporting (quarterly)
- Audits (annually)
- Training (annually)
Step 9: Continuous improvement
Annually:
- What worked?
- What needs improvement?
- New threats?
- Adjust measures
NIS2 is not a project, but a process.
Frequently Asked Questions (FAQ)
1. Must I report NIS2 incidents as a Swiss company?
Answer:
- If you have EU subsidiary: Yes (to EU authority)
- If you offer critical services in EU: Yes
- Purely Swiss operation: No (but possibly voluntarily sensible)
2. Is ISO 27001 sufficient for NIS2 compliance?
Answer: ISO 27001 is a good basis, but not sufficient.
NIS2 has additional requirements:
- Specific reporting obligations
- Supply chain security (more detailed)
- Business continuity (more concrete requirements)
Recommendation: ISO 27001 + NIS2 gap assessment.
3. Can I outsource NIS2 compliance?
Answer: Partially.
Can outsource:
- Security monitoring (MSSP)
- Incident response (retainer)
- Vulnerability management
- Compliance consulting
Cannot outsource:
- Responsibility (stays with you)
- Reporting obligations (you must do)
- Governance & policies
Hybrid model makes sense.
4. What happens with non-compliance?
In EU:
- Fines up to EUR 10 million or 2% turnover
- Management personally liable
- Reputational damage
For Swiss company:
- Direct: Only if EU subsidiary/branch
- Indirect: Loss of EU customers, competitive disadvantage
5. When does NIS2 come to Switzerland?
Answer: Unclear.
Possible scenarios:
- 2026-2028: Swiss equivalent (but uncertain)
- Or: Remains with sectoral regulations
- Or: Voluntary standards
Recommendation: Don’t wait, EU business requires compliance now.
6. What certification do I need for NIS2?
Answer: NIS2 does not require specific certification.
But helpful:
- ISO 27001 (basis)
- ISO 27002 (controls)
- SOC 2 (for cloud/SaaS)
- BSI IT-Grundschutz (recognised in DE)
NIS2 compliance is checked via audits (by national authorities).
7. How long does NIS2 compliance take?
Answer: Depends on starting point.
If already good security level: 6-12 months
If starting from zero: 12-18 months
Recommendation: Start early, don’t underestimate deadline.
Checklist: NIS2 Preparation for Swiss Companies
Immediately (Month 1-2)
- Clarify: Are we affected? (direct/indirect)
- Identify business activities in EU
- Check NIS2 sector membership
- Plan gap assessment (internal or external)
Short-term (Month 3-6)
- Conduct gap assessment
- Approve budget (CHF 100,000-300,000 for SMEs)
- Create roadmap (prioritise measures)
- Implement quick wins (MFA, backup tests)
- Evaluate external support (MSSP, consultants)
Medium-term (Month 6-12)
- Implement technical measures (see checklist above)
- Implement organisational measures
- Document policies & processes
- Test incident response plan
- Start security training
Ongoing (from Month 12+)
- Security monitoring 24/7
- Vulnerability management
- Patch management
- Quarterly risk review
- Annual audits
- Continuous improvement
Conclusion: What Swiss Companies Should Do Now
Key Messages
1. NIS2 affects more Swiss companies than expected Not directly, but indirectly through EU activities.
2. Compliance is complex and costly CHF 100,000-300,000 (setup) + ongoing costs.
3. Starting early pays off Competitive advantage, win EU customers.
4. Hybrid approach makes sense Internal + MSSP for operational security.
5. Even without obligation: Good cybersecurity pays off NIS2 standards are best practice, protect against cyberattacks.
Action Recommendation
Step 1: Clarify your situation (immediately)
- Affected or not?
- EU activities?
- Gap assessment
Step 2: Plan (Month 1-3)
- Roadmap
- Budget
- Resources
Step 3: Implement (Month 3-12)
- Technical + organisational
- Internal + external (MSSP)
Step 4: Operate (ongoing)
- Monitoring
- Reviews
- Continuous improvement
Golden Rules
Rule 1: Don’t wait NIS2 is already in force (EU), early compliance = competitive advantage.
Rule 2: Don’t underestimate Compliance is not a 2-month project, plan 6-12 months.
Rule 3: Get help External expertise (consultants, MSSP) accelerates compliance.
Rule 4: See it as opportunity Higher cybersecurity level protects your company, not just compliance.
Rule 5: Document Audits require evidence, document everything.
NIS2 is complex, but doable. With proper preparation, Swiss companies can not only be compliant but also more secure and competitive.
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