Section 30 BSIG: 10 NIS2 Mandatory Measures for Companies Explained
TL;DR
- 10 mandatory measure areas under Section 30 (2) BSIG (in force since 06 December 2025)
- Risk-based + proportionate — no rigid minimum list, but each area must be addressed
- ISO 27001 covers 70-80% — but mapping gaps must be closed systematically
- Most frequent audit findings 2026: supply chain, effectiveness assessment, cyber hygiene
- Fines up to EUR 10 million / 2% of turnover — plus personal managing director liability under Section 38 (5)
1. Overview: What Section 30 BSIG Requires
Section 30 BSIG (German IT Security Act, in force since 06 December 2025 through the NIS2UmsuCG) obliges essential and important entities to implement appropriate and proportionate technical, operational, and organizational measures for managing cyber risks.
"The measures shall, taking into account the particularities of the essential or important entity, reflect the state of the art and comply with the relevant European and international standards." — Section 30 (1) sentence 2 BSIG
The regulation lists 10 measure areas that every affected entity must address — the depth of implementation scales with the risk.
2. Areas 1 + 2: Risk Analysis + Incidents
| Area | Obligation | Templates |
|---|---|---|
| 1. Risk analysis + security concepts | Methodology (e.g. ISO 27005), risk register, risk treatment plan | ISMS policy, risk register, RMP |
| 2. Handling of security incidents | Incident response policy, 24h/72h/30d notification templates, playbooks | IR policy, IR playbook, notification templates |
Practitioner note: The 24h early warning is mandatory within 24 hours of becoming aware — not from the start of the incident. 24/7 availability must be ensured.
3. Area 3: Business Continuity
"Maintenance of operations (backup management and recovery after an emergency, crisis management)" — Section 30 (2) no. 3 BSIG.
- Business Continuity Plan (BCP) with RTO/RPO per business process
- Backup strategy (3-2-1 principle or equivalent)
- Disaster Recovery Plan with tested recovery routine
- Crisis management plan + internal/external communication
4. Areas 4 + 5: Supply Chain + Secure Development
The most frequent audit finding in 2026 is Area 4. Mandatory contents:
- Supplier evaluation with risk classification
- Cybersecurity clauses in standard contracts
- Right-to-audit for critical suppliers
- Incident notification from suppliers to you as the principal (max. 24h)
Area 5: secure software development — typically OWASP-oriented + vulnerability management following the CVD process (Coordinated Vulnerability Disclosure).
5. Area 6: Effectiveness Assessment
Obligation to implement "concepts for assessing the effectiveness of the measures". In practice:
- KPIs per area (e.g. patch compliance rate, phishing click rate, recovery time)
- Quarterly reporting to management
- Annual penetration test (BSI recommendation)
- Internal audit + external audit every 2 years
6. Area 7: Cyber Hygiene
"Concepts and procedures in the area of cyber hygiene and training in the area of cybersecurity" — Section 30 (2) no. 7 BSIG.
- Quarterly phishing simulation with click-rate monitoring
- Annual training for all employees (with quiz)
- Onboarding training for new employees (mandatory within the first 4 weeks)
- Sector-specific deep dives (e.g. SCADA training in industry)
7. Area 8: Cryptography
| Application | Standard |
|---|---|
| Data in transit | TLS 1.3 (BSI TR-02102), HTTPS everywhere |
| Data at rest | AES-256 for storage media and backups |
| Email security | S/MIME or PGP for sensitive communication |
| Key management | HSM or equivalent Key Management System |
| Quantum cryptography | Post-Quantum preparation (NIST Standards 2024) |
8. Areas 9 + 10: Personnel Security + Authentication
| Area | Obligation |
|---|---|
| 9. Personnel security + access control | Authorization concept, need-to-know, regular review, onboarding/offboarding workflow, security screening where applicable |
| 10. MFA + secure communication | MFA for all admin and external access, secure voice/video/text communication, emergency communication |
9. ISO 27001 Mapping
| Section 30 Area | ISO 27001 Annex A | Gap probability |
|---|---|---|
| 1. Risk analysis | A.5, A.8 | low |
| 2. Incidents | A.16 | medium (NIS2 notification obligations 24/72/30 missing) |
| 3. BCP | A.17 | low |
| 4. Supply chain | A.15 | high (cybersecurity clauses often missing) |
| 5. Secure development | A.14 | low |
| 6. Effectiveness | A.18 | medium (KPI reporting to managing director missing) |
| 7. Cyber hygiene | A.7 | medium |
| 8. Cryptography | A.10 | low |
| 9. Personnel security | A.7, A.9 | low |
| 10. MFA | A.9 | medium |
10. Practitioner Checklist: 22 Templates for the 10 Areas
- ISMS policy
- Risk analysis methodology
- Risk register
- Risk treatment plan
- Incident response policy
- Incident playbook
- 24h/72h/30d notification templates (3 pieces)
- Business Continuity Plan
- Backup & recovery concept
- Disaster Recovery Plan
- Crisis management plan
- Supplier questionnaire
- Cybersecurity contract clauses
- Vulnerability management process
- Vulnerability Disclosure Policy
- Cyber hygiene training
- Phishing simulation concept
- Cryptography policy
- Authorization concept
- MFA policy
- Asset inventory
- Audit checklist + effectiveness measurement
Sources
- BSIG 2025 (consolidated version) — Sections 28–60 (as of: 02 May 2026)
- NIS2 Implementation Act — Federal Law Gazette 2025 I No. 301 (as of: 02 May 2026; in force 06 December 2025)
- Directive (EU) 2022/2555 (NIS2) — Art. 21 (EUR-Lex DE) (as of: 02 May 2026)
- BSI — NIS2 FAQ regulated companies
Sources
- BSIG 2025 (Section 30 cybersecurity measures) (As of: 2026-05-02)
- Directive (EU) 2022/2555 — NIS2 (As of: 2026-05-02)
- BSI — NIS-2 FAQ (as of: ongoing)