KSC 2.0 Takes Effect: Register by Oct 3, 2026

3 April 2026 Poland Radar 0 Comments

KSC 2.0 requires thousands of Polish firms to register by Oct 3, 2026, or face heavy fines from April 2028. KSC 2.0 expands scope and penalties.

The government enacted KSC 2.0 on 3 April 2026, and the law now takes effect. Companies have until 3 October 2026 to register, and heavy fines start in April 2028.

Table of Contents

What KSC 2.0 changes and why it matters

The parliament passed the amendment on 23 January 2026. Consequently, the law implements the EU NIS 2 directive and the 5G toolbox. Moreover, the government broadened the definition of covered entities. Previously, only a narrow list of critical operators needed to comply. Now, the law reaches tens of thousands of organisations. In addition, the law includes food, chemicals, postal and waste sectors. Therefore, many medium-size companies may find themselves inside the new scope. The law does not name firms. Instead, it uses sector and size criteria. As a result, each organisation must self-assess its status.

Deadlines, registration and penalties

The ministry opens the register on 7 May 2026 through the S46 online system. Firms must file an entry request by 3 October 2026. Furthermore, entities that qualify must implement an information security management system by 3 April 2027. Also, the law requires continuous monitoring and risk assessment. The government will set up a national Cybersecurity Operations Hub to share alerts. Meanwhile, sectoral CSIRT teams must form within 18 months. Audits for key entities must occur by 3 April 2028. After that date, supervisors can fine non-compliant organisations. The fines are steep. For key entities, the law allows up to EUR 10 million or 2% of annual revenue. For important entities, fines can reach EUR 7 million or 1.4% of revenue. In extreme cases, officials can impose penalties of up to PLN 100 million for threats to defence, lives or major property losses. Therefore, the two-year grace period until April 2028 gives time to adapt. However, firms cannot wait until the last minute. Building capabilities and training staff takes months and money.

What expats and foreign-managed firms should do

If you run a company in Poland, check whether the law covers your activity. First, use the ministry Q&A on gov.pl to guide your self-assessment. Second, prepare to file in S46 once the register opens on 7 May. Third, allocate resources for an information security management system and staff training. In addition, plan for audits and incident reporting. If you employ contractors, review supply-chain risks. Consequently, you should budget for possible hardware or software changes. Note that the president referred parts of the law to the Constitutional Tribunal. The referral concerns rules that force firms to replace equipment at their own cost. Nevertheless, the rest of the law still applies.

💡 GOOD TO KNOW: If you are an expat running or advising a business in Poland, act now. Check whether your firm meets sector and size criteria. Use the Q&A on gov.pl and prepare to submit the S46 registration by 3 October 2026. Remember that Polish institutions use terms like ZUS (social insurance office), NFZ (public health insurer), PESEL (national ID number) and mandat (fine). Therefore, keep corporate records ready and train staff on incident reporting. Also, budget for audits and possible changes to equipment or suppliers.

Source: Read original article