NIS2 Romania Compliance Guide: Romanian Cybersecurity Law and ANSI Requirements for 2026

Romania is among the EU Member States working to transpose NIS2 into national law through amendments to its existing Legea nr. 361/2018 privind măsurile pentru asigurarea unui nivel comun ridicat de securitate a rețelelor și sistemelor informatice (Law on Measures for a High Common Level of Security of Networks and Information Systems). Romania’s approach builds on cybersecurity infrastructure established under NIS1, but significant enhancements are required to meet NIS2’s expanded scope and stricter requirements.

This guide covers Romania’s NIS2 transposition status, the role of ANSI (Autoritatea Națională pentru Securitatea Informațiilor — National Authority for Information Security), STS coordination, which entities are affected, sector-specific requirements, penalties under Romanian law, and practical steps for compliance.

Romania’s NIS2 Transposition: Where Things Stand

The Legal Framework

Romania’s NIS2 implementation comes through amendments to Legea 361/2018 alongside complementary legislation:

• Legea 361/2018 (original): Implemented the original NIS Directive (NIS1), establishing the national cybersecurity framework, CSIRT structures, and operator obligations
• OUG (Government Emergency Ordinance) amendments: Proposed to expand scope to NIS2 sectors, strengthen incident reporting, introduce personal liability for management, and increase penalties
• National Cybersecurity Strategy 2024-2027: Sets broader strategic objectives aligned with NIS2 principles

Key Dates and Timeline

Milestone	Status
NIS2 Directive adopted	January 2023
NIS2 transposition deadline	October 17, 2024
Romanian draft amendments published	2024
Parliamentary process	In progress (early 2026)
Expected entry into force	Mid-2026
Full enforcement begins	12 months after entry into force

Important: While Romania missed the October 2024 EU transposition deadline (like several Member States), the European Commission has initiated infringement proceedings. Romanian entities should not wait for final legislation — the NIS2 Directive creates obligations that national law will enforce retroactively in many areas.

Comparison with Other EU Countries

Romania’s approach is comparable to other EU states in our country guide series:

• France (ANSSI): Used ordonnance fast-track transposition, already enforcing
• Germany (BSI): Amended BSI Gesetz, conducting supervisory visits
• Italy (ACN): Established AgID/ACN framework, sector-specific decrees
• Spain (INCIBE): Amended Ley de Ciberseguridad, designated INCIBE as coordinator
• Poland (NCSA): Amending UKSC, similar timeline to Romania
• Hungary (NBSH): Regional neighbor, comparable approach

Key Regulatory Bodies

ANSI — Autoritatea Națională pentru Securitatea Informațiilor

ANSI serves as Romania’s national cybersecurity competent authority under NIS2. Its responsibilities include:

• Supervision and enforcement of cybersecurity requirements for essential and important entities
• Risk assessment and advisory for critical sectors
• Incident coordination with national CSIRT infrastructure
• Audit and inspection powers for compliance verification
• Guidelines and standards development for Romanian entities

STS — Serviciul de Telecomunicații Speciale

The STS plays a coordinating role in Romania’s national cybersecurity architecture:

• Operates CERT-RO (Computer Emergency Response Team Romania) — the national CSIRT
• Coordinates incident response across government and critical infrastructure
• Provides threat intelligence sharing with EU counterparts via the CSIRTs Network
• Manages the national cybersecurity incident reporting platform

Other Relevant Authorities

Authority	Role
ANCOM (National Authority for Management and Regulation in Communications)	Electronic communications sector oversight
ANRE (National Energy Regulatory Authority)	Energy sector cybersecurity
CNAS (National Health Insurance House)	Healthcare sector coordination
BNR (National Bank of Romania)	Financial sector supervision (overlaps with DORA)
SRI (Romanian Intelligence Service)	National security-level cyber threats

Which Entities Are Affected?

Essential Entities

Under NIS2, Romania must designate essential entities in these sectors:

Sectors without alternative legislation:

• Energy (electricity, hydrogen, district heating, petroleum, natural gas)
• Transport (air, rail, water, road)
• Banking
• Financial market infrastructure
• Health (hospitals, laboratories, medical device manufacturers)
• Drinking water supply and distribution
• Wastewater management
• Digital infrastructure (DNS, TLD registries, cloud, data centers, CDNs)
• ICT service management (managed security, managed IT)
• Public administration (central government, regional, judicial systems)

Sectors with alternative legislation (notably DORA for financial services):

• Entities already covered by DORA are excluded from NIS2 to avoid double regulation
• Banking entities supervised by BNR fall under DORA primarily

Important Entities

Romania must also identify important entities based on thresholds:

Criterion	Essential Entity	Important Entity
Employees (medium/large)	250+	50-249
Turnover (medium/large)	€50M+	€10M-€49.9M
OR: Designated by Romania	Yes (sector-specific)	Yes (sector-specific)
OR: Critical due to impact	Yes (case-by-case)	Yes (case-by-case)

Romanian entities in these additional sectors qualify as important:

• Postal and courier services
• Waste management
• Chemicals (production and distribution)
• Food production and distribution
• Manufacturing of critical products (pharmaceuticals, medical devices)
• Digital providers (online marketplaces, search engines, social networks)

Entity Registration

Romanian entities must register with ANSI through the national cybersecurity registry. The registration process includes:

1. Self-assessment of NIS2 scope (essential or important entity)
2. Submission to ANSI via the online portal
3. Verification by ANSI (may request additional documentation)
4. Confirmation of entity classification
5. Ongoing updates when significant changes occur (mergers, sector changes, threshold crossings)

Sector-Specific Requirements

Energy Sector

Romania’s energy sector is particularly significant given the country’s role in regional energy supply:

• Transelectrica (national transmission system operator) — critical infrastructure
• Hidroelectrica (largest hydropower producer) — essential entity
• Nuclearelectrica (nuclear power) — highest criticality tier
• OMV Petrom (oil and gas) — essential entity

Energy entities must implement ICS/SCADA security measures aligned with NIS2 Article 21 and Romanian energy regulator (ANRE) cybersecurity requirements.

Transport Sector

Romania’s strategic position as an EU gateway means transport cybersecurity is critical:

• Henri Coandă International Airport (OTP) — essential entity (air transport)
• CFR (Căile Ferate Române) — national railway operator
• Port of Constanța — largest Black Sea port, essential entity
• DN/Ring road infrastructure — intelligent transport systems

Healthcare Sector

Post-COVID healthcare digitization makes this sector a priority:

• Ministry of Health systems — essential entity
• Major hospital networks — essential entities (250+ employees)
• Laboratory networks (Synevo, etc.) — important entities
• Medical device manufacturers — important entities

Digital Infrastructure

Romania’s strong IT sector and growing data center presence:

• .ro TLD registry (RoTLD) — essential entity
• DNS providers operating in Romania — essential entities
• Cloud service providers — based on thresholds
• Data centers (Bucharest tech hub) — based on thresholds

Penalties and Enforcement

NIS2-Aligned Penalties

Romania must align penalties with NIS2 maximum thresholds:

Violation Type	Maximum Penalty
Essential entity — infringement of risk management measures	Up to €10,000,000 or 2% of total worldwide annual turnover
Important entity — infringement of risk management measures	Up to €7,000,000 or 1.4% of total worldwide annual turnover
Essential entity — infringement of incident reporting	Up to €10,000,000 or 2% of total worldwide annual turnover
Important entity — infringement of incident reporting	Up to €7,000,000 or 1.4% of total worldwide annual turnover

Personal Liability for Management

NIS2 requires Romania to hold management bodies personally liable for:

• Failure to approve and oversee cybersecurity risk management measures
• Failure to undergo cybersecurity training
• Failure to implement corrective actions following ANSI orders

Consequences for managers:

• Temporary prohibition from holding management positions
• Personal fines (amounts set in national law)
• Criminal liability in cases of gross negligence (under Romanian Criminal Code)

Enforcement Powers

ANSI has broad enforcement powers under NIS2:

• On-site and remote inspections without prior notice
• Requests for information and documentation
• Security audits by approved assessors
• Compliance orders with binding deadlines
• Warning letters for less severe violations
• Penalty notices for material breaches

Compliance Requirements

Article 21 Risk Management Measures

Romanian essential and important entities must implement measures covering:

1. Risk analysis and information system security policies
2. Incident handling (detection, response, recovery)
3. Business continuity (crisis management, disaster recovery)
4. Supply chain security (vendor risk management)
5. Security in network and information systems (acquisition, development, maintenance)
6. Vulnerability handling and disclosure
7. Cryptography (encryption, key management)
8. Employee training and cybersecurity awareness
9. Access control and identity management
10. Physical security of premises and data centers

Incident Reporting Requirements

Romanian entities must report significant incidents through CERT-RO:

Reporting Stage	Timeline	Content
Early Warning	Within 24 hours	Initial assessment, severity indication, suspected cross-border impact
Incident Notification	Within 72 hours	Updated assessment, indicators of compromise, preliminary root cause
Final Report	Within 1 month	Full incident analysis, impact assessment, remediation measures, lessons learned

Supply Chain Security

NIS2 requires Romanian entities to assess and manage cybersecurity risks across their supply chain:

• Supplier audit rights in contracts
• Security requirements for critical vendors
• Concentration risk assessment (single-vendor dependencies)
• Supply chain incident reporting obligations

This aligns with our guide on NIS2 supply chain and third-party risk management.

Cyber Insurance Implications for Romanian Entities

Why Romanian Entities Need Cyber Insurance

NIS2 creates new liability exposure for Romanian organizations:

• Fines up to €10M for essential entities — insurance can cover defense costs
• Management personal liability — D&O insurance must be reviewed for cyber exclusions
• Business interruption from mandatory system shutdowns during incident response
• Third-party claims from customers affected by data breaches or service disruptions
• Regulatory investigation costs — legal fees, forensic investigations, compliance remediation

What Underwriters Should Ask About Romanian Entities

Cyber insurance underwriters assessing Romanian risks should ask:

1. Entity classification — Is the insured an essential or important entity under NIS2?
2. Registration status — Has the entity registered with ANSI?
3. Risk management measures — Which of the 10 Article 21 measures are implemented?
4. Incident history — Any incidents reported to CERT-RO in the past 3 years?
5. Supply chain audit program — Does the entity audit critical vendors?
6. Management training — Has leadership completed cybersecurity training?
7. Business continuity testing — When was the last BCP/DR test?

Coverage Considerations

For Romanian entities, ensure the policy covers:

• Regulatory investigation costs under NIS2 enforcement actions
• Business interruption during ANSI-mandated system reviews
• Notification costs for multi-stage incident reporting
• Crisis management and reputational harm
• Supply chain losses from vendor incidents (see supply chain attack loss scenarios)

Use our cyber insurance buying guide to compare coverage options and our coverage comparison tool for policy evaluation.

Implementation Roadmap for Romanian Entities

Phase 1: Assessment (Months 1-2)

• Determine entity classification (essential or important)
• Register with ANSI
• Conduct gap analysis against Article 21 requirements (see our NIS2 gap analysis guide)
• Map supply chain dependencies

Phase 2: Foundation (Months 3-6)

• Implement cybersecurity risk management framework
• Establish incident reporting procedures aligned with CERT-RO timelines
• Deploy baseline security controls (access management, encryption, logging)
• Begin management cybersecurity training

Phase 3: Maturity (Months 7-12)

• Complete supply chain security assessments
• Conduct business continuity and disaster recovery testing
• Implement vulnerability disclosure process
• Prepare for ANSI audit readiness (see our NIS2 audit preparation guide)

Phase 4: Ongoing Compliance

• Regular risk assessments (at least annually)
• Continuous incident detection and response capability
• Annual management training refresh
• Supply chain reassessment for new vendors and changed risk profiles

Key Takeaways

1. Romania is transposing NIS2 through amendments to Legea 361/2018 — expect full enforcement by mid-2027
2. ANSI is the primary competent authority with broad enforcement powers including on-site inspections
3. CERT-RO (operated by STS) handles incident reporting with strict 24-hour, 72-hour, and 1-month timelines
4. Penalties align with NIS2 maximums — up to €10M or 2% global turnover for essential entities
5. Management personal liability is a new requirement — Romanian executives must undergo cybersecurity training
6. Cyber insurance is essential for Romanian entities facing new NIS2 liability exposure
7. Supply chain security must be addressed proactively, especially for entities relying on cross-border vendors

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For more NIS2 compliance resources, explore our NIS2 compliance checklist, penalties guide, and technical measures requirements. Compare your country’s approach with our essential vs important entity classification guide.