NIS2 Country Guide

NIS2 Lithuania: Kibernetinio saugumo įstatymas 2026

Lithuania transposed NIS2 through the Kibernetinio saugumo įstatymas (Law on Cyber Security), in force since 18 October 2024 and amended twice in 2026 - the consolidated text in force today dates from 4 July 2026. This page sets out who counts as a kibernetinio saugumo subjektai (cybersecurity entity), what the NKSC can fine you and on what scale, and the clocks that start the day you are registered in KSIS - which, for the 1,443 organisations registered in April 2025, reached their first deadline on 17 April 2026.

Lithuania In force: 18 October 2024 Consolidated text: 4 July 2026 Regulator: NKSC Last updated: 17 October 2026

Introduction: NIS2 Directive & the Lithuanian context

Lithuania already had a Law on Cyber Security before NIS2. What changed in 2024 was not the existence of the law but its reach: the Kibernetinio saugumo įstatymas was restated in full by amending act No. XIV-2902, adopted by the Seimas on 11 July 2024 and in force from 18 October 2024.

Two things about the Lithuanian regime catch organisations out, and both are on this page. First, your obligations do not begin when the law comes into force - they begin when you are registered, which means every deadline on this page is personal to your entity. For the first cohort, registered in April 2025, those personal deadlines have become dated ones: the organisational requirements fell due on 17 April 2026 and the technical ones fall due on 17 April 2027. Second, the headline fines everyone quotes are ceilings on ceilings: the Act sets a maximum, and then caps what share of that maximum a given breach can attract.

Currency: this page is written from the Act as consolidated from 4 July 2026 - laws No. XV-894 and No. XV-1076 were its 2026 amendments, and e-seimas shows no later version scheduled - and from Government Resolution No. 818 as in force in October 2026. The Resolution has been amended four times since November 2024 - including, in March 2026, a post-quantum cryptography timetable whose first duties start on 1 January 2027.
Quick link: New to NIS2? Start with our general guides “What is NIS2?” and “NIS vs NIS2”.

NIS2 implementation in Lithuania

Lithuania implemented NIS2 by restating the Kibernetinio saugumo įstatymas (Law on Cyber Security, No. XII-1428) through amending act No. XIV-2902, adopted by the Seimas on 11 July 2024, published in the Register of Legal Acts on 24 July 2024 and in force from 18 October 2024.

The detail sits in Government Resolution No. 818 of 13 August 2018, restated by Resolution No. 945 of 6 November 2024 (published 11 November, in force 12 November). It now carries seven instruments, and three of them govern most of what you have to do: the Kibernetinio saugumo reikalavimų aprašas (Description of Cybersecurity Requirements), which sets the controls and the 12 and 24-month deadlines; the national cyber incident management plan, which turns "significant" into numbers and sets the reporting routes and the deadlines for minor incidents; and the procedure for applying enforcement measures. The others are the methodology for identifying entities by special criteria, the list of users of the Secure State Data Network, that network's charging criteria and - added by Resolution No. 900 of 10 December 2025 - the list of EU acts treated as equivalent to the Act's requirements.

What the 2026 amendments changed. Law No. XV-894 (adopted 12 May 2026, applied from 30 June 2026) changed one provision: NKSC fine decisions are now enforced under the Law on Tax Administration as well as the Code of Civil Procedure. Law No. XV-1076 (adopted 25 June 2026, published 3 July, applied from 4 July 2026) amended articles 2, 11, 12, 13, 19, 23, 28, 30, 31 and 38 and annexes 2 and 3. The changes that matter most to entities are to scope - the size test now reads "headcount and/or both financial limits", where it used to require the headcount and the financial limits together, and headcount is now taken from state social insurance records - and to the main-establishment rule for digital providers; the rest updates KSIS membership, the competence community, state data centres and the wording of the enforcement articles. The fine ceilings and the severity bands are unchanged.

Supervision is centralised; identification is not. The Nacionalinis kibernetinio saugumo centras prie Krašto apsaugos ministerijos - the National Cyber Security Centre under the Ministry of National Defence, known as the NKSC - is the competent authority, the CSIRT and the single point of contact, and it is the body that inspects and imposes fines. Identifying entities is shared with the ministries named in the Act's annexes (Article 13(6)).

Status

Fully transposed and in force since 18 October 2024, ahead of most member states. The operative text today is the consolidated version of 4 July 2026.

Legal structure

Three layers. The Kibernetinio saugumo įstatymas sets scope, duties, supervisory powers and the fine ceilings. Resolution No. 818, as amended, carries the security requirements, the incident plan, the identification methodology and the enforcement procedure. NKSC director's orders set the working detail: training (No. 1-96), inspections (No. 1-23) and the audit methodology (No. 1-25).

Supervisory approach

Essential entities can be inspected on an annual plan or on any ground; important entities only on information suggesting a breach (Article 26(3)). The NKSC imposes fines itself - there is no separate sanctions commission and no court confirmation step.

Who is in scope

Lithuania follows the NIS2 split into essential (esminiai subjektai) and important (svarbūs subjektai) entities, known collectively as kibernetinio saugumo subjektai. The identification criteria are in Article 11, and they were amended as recently as 4 July 2026.

How many. The register opened in April 2025 with 1,443 organisations from 18 sectors - the 11 in Annex 1 and the 7 in Annex 2 - nearly five times the previous list, and mostly private-sector newcomers (NKSC, 23 April 2025). Entities identified under the special criteria are being added during 2026 (NKSC 2025 activity report).

Who is in scope?

  • Annex 1 sectors (energy, transport, banking, financial market infrastructure, health, drinking water, waste water, digital infrastructure, ICT service management, public administration, space): large entities are essential and medium-sized ones important (Articles 11(3)(1) and 11(4)(2)).
  • Annex 2 sectors (postal, waste management, chemicals, food, manufacturing, digital providers, research): entities above small-enterprise size are important - provided the revenue test below is met (Article 11(4)(1)).
  • Size is not written as a flat figure. Article 11 refers across to the Law on the Development of Small and Medium-sized Business: an entity counts where it exceeds the headcount and/or both financial thresholds. Since 4 July 2026 headcount is taken from the State Social Insurance Fund's records of insured persons, and turnover and balance sheet from filed annual accounts or tax data; where your own headcount, calculated under the SME law, differs from the insurance figure, yours is used (Article 11(8)-(9)).
  • Essential whatever their size: entities recognised as critical under the Crisis Management and Civil Protection Act; central, regional and municipal public administration bodies; managers of critical or important state information resources; and enterprises important to national security, or whose systems appear on the national-security assets list (Article 11(3)(4)-(7)).
  • In digital infrastructure, qualified trust service providers, top-level domain registries and DNS providers are essential regardless of size (root name server operators excepted); public electronic communications providers are essential from medium size and important below it. Non-qualified trust service providers are important at any size short of large; domain name registration services and hosting providers are important with no size condition at all, and so is any entity that manages state information resources (Article 11(4)(3)-(7)).
  • Outside the Act: intelligence institutions, and credit unions unless they run their systems independently of their central credit union (Article 1(2)).

Core obligations

  • Meet the Description of Cybersecurity Requirements - or, for DNS, top-level domain, cloud, data centre, content delivery, managed service, managed security service, marketplace, search, social network and trust service providers, Commission Implementing Regulation (EU) 2024/2690 instead (Article 14(1) and (4)).
  • The head approves a network and information security policy, reviewed at least once a year, and a risk assessment at least once a year, after major change and after any significant incident; the approval details go into KSIS within 5 working days (Description, points 4-13).
  • Report significant and minor incidents - see incident reporting.
  • Manage supply-chain security, including your relationships with direct suppliers and service providers (Article 14(5)(5)).
  • Management body members, the head and any authorised person train at least every 2 years, and all staff take cyber-hygiene training at least once a year (Article 14(7); Description, point 52).

A revenue test most guides miss

For an Annex 2 activity, Article 11(4)(1) adds a condition: the revenue from that activity must exceed 50% of the entity's total annual revenue. An organisation with a small qualifying sideline therefore sits outside the regime on that limb - unless it is caught under the special criteria.

Financial entities under DORA. Resolution No. 900 lists Regulation (EU) 2022/2554 and four of its technical standards as equivalent, so DORA-covered financial entities follow DORA rather than the Act's risk-management, responsible-person and significant-incident rules (Article 1(3)-(5)).
The staged compliance window is real, and it is set out below - see your 12 and 24-month clocks. It runs from your registration date, not from the date the law came into force.

Registration in KSIS, and when your duties actually start

This is the provision that reorders everything else. Article 11(2): a cybersecurity entity acquires the obligations of a cybersecurity entity only from the moment it is registered in the Kibernetinio saugumo informacinė sistema - the Cybersecurity Information System, known as KSIS. Until then, the duties in Articles 14, 15 and 18 do not bite.

Who files

Both sides act. The NKSC built the register from state records - the statutory deadline for the first sweep was 17 April 2025 - and the ministries named in the Act's annexes confirm the entries for their sectors (Article 13(6)); the NKSC said it would notify each organisation it entered by email. But Article 13(4) also puts a duty on the entity: an organisation meeting the Article 11 criteria submits its own data, in the form set by the KSIS Regulations of the Minister of National Defence.

What the register holds

Name, legal-entity code, legal form and economic activity; head-office address; contact details; the services that meet the criteria; the states where you provide them; the networks and information systems significant to them; the Annex 1 or 2 sector and subsector - and the IP addresses you use. Members keep these, with their IP ranges and websites, current in the KSIS organisation profile.

If you are not established in the EU

Article 12(3): DNS, top-level domain, domain registration, cloud, data centre, content delivery, managed service, managed security service, marketplace, search and social network providers that serve Lithuania from outside the EU must designate a representative in an EU state where they offer services. Designating one in Lithuania, or none at all, brings them under Lithuanian jurisdiction. The representative's details go into the register, and these providers - with trust service providers - also list the addresses of their other EU establishments.

Identified under the special criteria? The ministry responsible for your sector writes to you, and you have 10 working days to confirm or correct the data - silence counts as agreement, and one 10-day extension is available (special-criteria methodology, point 9). Criterion 6 reaches suppliers: an organisation whose contract of more than 12 months leases systems to an essential entity, or gives access to its systems, can itself be identified as essential, and one that maintains those systems as important.
Practical consequence: if you believe you are in scope and have not been contacted, do not wait - Article 13(4) puts the filing duty on you, and registration is what starts your clocks. The NKSC's online register check has been switched off; its register team answers by email, at the address on the NKSC Act page. Once you no longer meet the criteria you are removed within 20 working days, and your duties end on removal (Article 13(8) and (10)).

Your 12 and 24-month clocks

Lithuania's implementation deadlines are relative, not calendar: they run from the day your entity was registered in KSIS. For the first cohort - the organisations registered in April 2025 - that has produced two national dates, and the first has passed.

What By when Source
The cybersecurity requirements generally 12 months from registration in KSIS - for the April 2025 cohort, 17 April 2026 Description of Cybersecurity Requirements, point 71
The technical requirements set out in points 26, 31, 47, 57, 60, 64 and 69 of the Description 24 months from registration in KSIS - for the April 2025 cohort, 17 April 2027 Description, point 72
Configure your event and incident management systems so that incidents are registered automatically in the National Cyber Incident Management Platform 12 months from registration, extendable once by up to 12 further months by the NKSC on a reasoned request Resolution No. 818, point 3
Essential entities: cryptography inventory, list of high quantum-risk systems and a post-quantum migration plan 1 May 2027, whatever the registration date Resolution No. 185, point 3.2

The Act itself sets only a floor: Article 14(2) requires the Government to allow a period of not less than 12 months from registration. The 12 and 24-month figures are the Government's, in the Description of Cybersecurity Requirements - which is why they cannot be found by reading the Law on Cyber Security alone. The digital providers that follow Regulation (EU) 2024/2690 are outside points 71 and 72 altogether (Article 14(4)).

The April 2026 date is the Government's own reading: the NKSC's account of the Prime Minister's meeting with it, published on 4 June 2026, gives 17 April 2026 for the organisational measures and 17 April 2027 for the technical ones. At that point 74 public-sector bodies had either not started or were judged to be making insufficient progress - 27 had taken no step at all - and they were given until 31 August 2026 to appoint responsible persons, join KSIS, assess risk and adopt a risk-management plan.

The extension is narrower than it looks. Resolution No. 818 lets the NKSC extend once, by up to twelve months, on a reasoned request - but only for the automatic incident-registration requirement in its point 3. Points 71 and 72 of the Description carry no extension.

The cybersecurity manager and the security officer

Article 15 requires two appointments, not one, and it sets statutory qualification requirements for both. Breaching the appointment duties sits in the middle severity band - up to half the maximum fine.

Kibernetinio saugumo vadovas

The cybersecurity manager, appointed by the entity's head, directly accountable to that head, and responsible for the entity's compliance with Articles 14 and 18 - the risk-management measures and the incident reporting.

Saugos įgaliotinis

The security officer, responsible for the compliance of a specific network and information system. Where a system has a separate processor, the system's controller may require that processor to appoint one.

One person, several roles, or bought in - with one limit

The cybersecurity manager may also perform the security officer's functions, and either role may cover several entities or several systems. Article 15(4) expressly permits buying these functions in from a supplier, provided compliance with Articles 14 and 18 is still ensured. But neither role may be combined with administering the networks or systems (Description, point 19), and the people running the security operations centre function may not be those responsible for operating the same systems, whether staff or a supplier's (incident plan, point 3).

Article 15(5) sets who may hold the role. The person must meet the impeccable reputation standard that applies to civil servants; must not have had an administrative penalty for breaches in networks and information systems or in data protection and privacy imposed less than one year ago; and must satisfy one of four alternatives -

  • at least 2 years' experience in IT, cybersecurity or networks and information systems; or
  • a higher-education diploma confirming qualification in those fields; or
  • an internationally recognised qualification certificate; or
  • completion of NKSC-set training and a pass in the cybersecurity manager examination.

The fourth route is defined by NKSC Director's Order No. 1-96 (in force 4 December 2025, amended 26 January 2026): a manager or officer who meets none of the other routes completes at least 10 academic hours on twelve set topics - from security policy and risk analysis to cryptography and supply-chain security - and then passes the cybersecurity manager examination. The NKSC offers both free on its training platform, and the certificate is uploaded to KSIS (Order No. 1-96, points 5, 6 and 10). The entity must also tell the NKSC through KSIS whom it has appointed (Description, point 17).

The carry-over runs only to 18 October 2026. Security officers appointed under the former Article 22 before 18 October 2024 kept their posts, and the Article 15(5)(3) qualification limb is disapplied to them for the first two years from that date (XIV-2902, Article 2(6)). From 19 October 2026 every security officer must meet one of the four routes above - for an incumbent with none of the experience, diploma or certificate, that means the NKSC course and examination. The carry-over never covered the reputation and prior-penalty conditions, or the cybersecurity manager. Where the entity is a natural person, Article 15 does not apply at all.

Authorities, CSIRT and who supervises you

Lithuania is centralised for supervision - one regulator inspects, handles incidents and fines - but identification is shared with the sectoral ministries, and the Act names other bodies with real roles.

A note on names. The Act designates the regulator only by its full legal name, Nacionalinis kibernetinio saugumo centras, which appears more than 140 times in its various grammatical forms; the acronym NKSC appears nowhere in it, though the institution uses that acronym itself. The English form "NCSC" is best avoided - it is the acronym of the United Kingdom's agency.
Role Authority Notes
Competent authority, CSIRT and Single Point of Contact Nacionalinis kibernetinio saugumo centras prie Krašto apsaugos ministerijos (NKSC) An institution under the Ministry of National Defence (Article 7(1)). Builds and operates the register, receives incident reports, inspects, orders audits, applies the enforcement measures and imposes the fines. Since 17 April 2026 it has been running active monitoring of entities' KSIS submissions.
Identification of entities in each sector The ministries named in Annexes 1 and 2 Energy (energy, electrical equipment); Transport and Communications (transport, internet exchange points, public electronic communications, post, vehicles and other transport equipment); Economy and Innovation (DNS, top-level domains, cloud, data centres, content delivery, trust services, space, electronics, marketplaces, search, social networks, hosting); Finance (banking, market infrastructure); Health (health, medical devices); Environment (drinking water, waste water, waste, chemicals); Agriculture (food); the Interior (public administration); Education, Science and Sport (research). They confirm register entries for their sectors and run the special-criteria identification (Article 13(6)).
Policy formation Ministry of National Defence (Krašto apsaugos ministerija) Forms cybersecurity policy and organises, controls and coordinates its implementation (Article 4(2)). The Ministry of Foreign Affairs participates to the extent diplomatic responses to cyber threats are concerned.
Policy implementation alongside the NKSC Lietuvos policija and the Valstybinė duomenų apsaugos inspekcija Named in Article 4(3) as implementing bodies, with their own powers under Articles 9 and 10. The NKSC must inform the data protection inspectorate within 36 hours where GDPR Article 33(3) circumstances are identified.
Trust service providers and electronic communications Ryšių reguliavimo tarnyba (Communications Regulatory Authority) Article 20: cooperates with the NKSC on cybersecurity audits of trust service providers, and must be informed by the NKSC within 24 hours of incident notifications received from them. It is also told, by the next working day, of any 48-hour restriction order the NKSC gives electronic communications providers (Article 7(2)(6)).
Financial sector Lietuvos bankas (Bank of Lithuania) The financial-market supervisor, and since July 2025 the first market regulator connected to the National Cyber Incident Management Platform. The NKSC must consult the European Central Bank before inspecting or sanctioning the Bank of Lithuania itself (Article 20(2)(8)).

Incident reporting: 24h / 72h / one month

Article 18 sets two duties: a four-stage chain for significant incidents, and a separate duty to report incidents that do not meet the significance threshold. Both are filed through the National Cyber Incident Management Platform in KSIS, live since spring 2025; a form on the platform, the NKSC website, the NKSC's email address or a phone call are the fallbacks (incident plan, points 10-11).

Stage Deadline What it must contain
Early warning
ankstyvasis perspėjimas
24 hours from becoming aware Whether the incident is suspected to have been caused by unlawful or malicious acts, and whether it could have cross-border impact.
Incident notification 72 hours from becoming aware Updates the early warning, adds an initial assessment of severity and impact, and indicators of compromise where there are any.
Interim report On NKSC request, by the deadline it sets Updated status information.
Final report One month - see the note below Full description including severity and impact; the threat or root cause; mitigation measures applied; and any cross-border effect.
Progress report Where the incident is still running when the final report falls due The final report is then due one month from the day the incident was contained.
Monthly update Where the incident lasts longer than one month The notification content, refreshed every month (incident plan, point 15).
Read the trigger, not just the duration. Article 18(4)(4) runs the one-month clock from the day you submitted the notification referred to in point 1 of that paragraph - and point 1 is the 24-hour early warning, not the 72-hour notification. As drafted, the final report is due one month from first knowledge. We state it as the Act states it.

When an incident is significant

Article 18(2) speaks of serious disruption, financial loss and substantial damage to others. Unless a Commission implementing act says more - as Regulation (EU) 2024/2690 does for the digital providers it covers - point 9 of the incident plan turns that into numbers. An incident is significant where it causes or may cause serious disruption to your services and meets at least one of these:

Test Threshold
Reach Services disrupted across the whole of Lithuania and/or in at least one EU or NATO country
Duration The network and information system is disrupted for 2 hours or more
Users 1,000 service recipients or workstations affected, or 25% of them, whichever is lower
Data Personal or other data of 1,000 recipients, or 25% of them, whichever is lower
Legal You can no longer meet the legal requirements that apply to your activity
Secrets Trade secrets or classified information lost or disclosed
Recurrence More than one analogous incident within 6 months, with the same root cause and losses reaching the financial threshold below

An incident is also significant on loss alone - EUR 500,000 or 5% of the previous financial year's turnover, whichever is lower - or where others suffer or may suffer material damage of 400 basic social benefits or more, non-material damage of EUR 10,000 or more, or harm to anyone's health or life (incident plan, points 9.2-9.3).

Minor incidents have their own clock. Article 18(1)(2) and point 13 of the plan: a notification within 72 hours of becoming aware - there is no early warning - and a final report within one month of the notification being registered, which can be skipped if the notification already contained everything. The NKSC can reclassify a minor incident as significant and must tell you within 24 hours (point 21). Failing to report a minor incident is an infringement in its own right - in the lowest severity band, but an infringement.

NIS2 timeline & key dates (Lithuania)

23 May 2024 — The Government's bill (XIVP-3815) restating the Law on Cyber Security is registered in the Seimas.
11 July 2024 — Amended Law on Cyber Security adopted by the Seimas (Act No. XIV-2902, transposing NIS2).
18 October 2024 — Law on Cyber Security (as amended) enters into force, formally implementing NIS2.
12 November 2024 — Resolution No. 945 restates Resolution No. 818: requirements, incident plan, identification methodology and enforcement procedure.
17 April 2025 — Statutory deadline for the NKSC's first sweep (XIV-2902, Article 2(3)); the register opens with 1,443 organisations.
Spring 2025 — The National Cyber Incident Management Platform goes live.
4 December 2025 — NKSC Order No. 1-96 on mandatory training for heads, cybersecurity managers, security officers and auditors takes effect.
17 December 2025 — Resolution No. 900 adds the list of EU acts treated as equivalent - DORA and four of its technical standards.
23-24 February 2026 — The NKSC approves its inspection procedure (Order No. 1-23) and cybersecurity audit methodology (Order No. 1-25).
25 March 2026 — Resolution No. 185 sets Lithuania's post-quantum cryptography timetable.
17 April 2026 — The April 2025 cohort's 12-month deadline. The NKSC begins active monitoring of KSIS submissions; its compliance questionnaire is mandatory for essential entities.
30 June 2026 — Amending law No. XV-894 applies.
4 July 2026 — Amending law No. XV-1076 applies, changing the size test, the main-establishment rule and KSIS membership. This is the text in force today.
31 August 2026 — Deadline set for 74 lagging public-sector bodies to take the first required steps.
18 October 2026 — The two-year carry-over for security officers appointed before 18 October 2024 ends; from 19 October the Article 15(5)(3) test applies to all of them.
1 January 2027 — A cryptography inventory at least every three years, and identification of high quantum-risk systems, join the Description of Cybersecurity Requirements.
17 April 2027 — The April 2025 cohort's 24-month deadline for the seven listed technical requirements.
1 May 2027 — Essential entities complete the cryptography inventory, list their high quantum-risk systems and adopt a post-quantum migration plan (Resolution No. 185, point 3.2).
1 January 2029 — Deadline for the Ministry of National Defence to complete the statutory ex post evaluation of the Act's impact on cybersecurity entities.
1 January 2031 — Essential entities under the Description must use post-quantum or hybrid cryptography in high quantum-risk systems that rely on asymmetric cryptography.
1 January 2036 — Essential and important entities under the Description must use post-quantum algorithms in every system that relies on asymmetric cryptography.
Rolling, per entity — 12 months from your registration in KSIS for the requirements generally, 24 months for the seven listed technical requirements.

Sector-specific notes for Lithuania

  • Energy: Annex 1 covers electricity (supply, distribution, transmission, generation, nominated market operators, aggregation, storage and demand response, and electric-vehicle charging point operators), district heating and cooling, oil, gas and hydrogen. The Ministry of Energy identifies entities in all of them.
  • Digital infrastructure: only qualified trust service providers, top-level domain registries and DNS providers are essential regardless of size; cloud, data centres, content delivery networks and internet exchange points follow the general size test. DNS, top-level domain, cloud, data centre and content delivery providers, managed service and managed security service providers and trust service providers follow Regulation (EU) 2024/2690 instead of the national Description (Article 14(4)) - internet exchange points and electronic communications providers do not - and the NKSC is preparing a separate compliance questionnaire for them.
  • Healthcare: personal health care institutions, EU reference laboratories, pharmaceutical research and manufacture and makers of critical medical devices sit in Annex 1, with size deciding essential or important. The NKSC's 2025 national exercise, "Kibernetinis skydas - TrustEx", brought together 28 organisations from health and water.
  • Water: drinking water and waste water are both Annex 1 sectors, identified by the Ministry of Environment. A sector security operations centre set up with the water association "Vandens jėga" starts by monitoring five companies (NKSC, 17 November 2025).
  • Manufacturing: Annex 2 reaches medical devices and NACE divisions C26 to C30 - electronics, electrical equipment, machinery, motor vehicles and other transport equipment - each with its own identifying ministry, and the 50% revenue test applies.
  • Finance: DORA-covered entities follow DORA under Resolution No. 900's list. The Bank of Lithuania joined the national incident platform in July 2025, and the NKSC sends the financial sector a weekly threat report.
  • Public sector: central, regional and municipal administration bodies are essential (Article 11(3)(5)); territorial state administration bodies are caught under the special criteria where an outage could last more than 24 hours or affect more than 145,000 residents or a whole municipality. Public bodies are not exempt from fines - they are fined on a separate scale, set out under penalties. In June 2026, 74 of them were flagged as lagging. A EUR 17 million EU recovery-fund project to equip 44 security operations centres, mostly in public bodies, was due to finish in spring 2026.
  • Trust services: qualified trust service providers are essential regardless of size, and are the one group with a second regulator in the loop - the Ryšių reguliavimo tarnyba, which the NKSC must inform within 24 hours of any incident notification they file.

Penalties and fines

Article 30 sets four maximums, not two - and then Article 30(3) caps what proportion of that maximum any given breach can attract. Quoting "up to 10 million euro" describes the worst case for one class of breach by one class of entity.

Entity Maximum fine
Essential entity EUR 10,000,000 or 2% of total worldwide annual turnover in the preceding financial period, whichever is higher
Important entity EUR 7,000,000 or 1.4% of total worldwide annual turnover, whichever is higher
Budgetary institution that is an essential entity Up to 1% of its current-year budget and other gross annual income received in the previous year, but not more than EUR 60,000
Budgetary institution that is an important entity Up to 0.5% on the same base, capped at EUR 30,000

Lithuania fines public bodies. It does not exempt them, as some transpositions do - it applies a different base and a hard low cap.

The severity bands, and why they change the number

Article 30(3) allows only a share of the maximum above, according to how Article 29 classifies the breach:

Severity Share of the maximum Effective cap, essential entity Which duties
Dangerous
pavojingas
up to 100% EUR 10,000,000 or 2% of turnover Article 14(1) risk-management measures; Article 18(1)(1) - reporting a significant incident, at every stage of the 24-hour, 72-hour and one-month chain
Medium
vidutinio pavojingumo
up to 50% EUR 5,000,000 or 1% of turnover Article 7(2)(6)-(7), ignoring an NKSC order to restrict services for 48 hours or to block a domain; Article 14(6), the head's duty to ensure compliance; Article 14(8), the three-year audit; Article 15(1)-(3), the responsible persons; obstructing an inspection; Article 17 duties where breached by a top-level domain registry
Low
nedidelio pavojingumo
up to 10% EUR 1,000,000 or 0.2% of turnover Article 14(3), KSIS data on your measures; Article 14(7), management training; Article 18(1)(2) - reporting minor incidents; Article 19(4), notifying information-sharing arrangements within 20 working days; Article 17 duties where breached by a domain name registration service
The whole significant-incident chain sits in the top band. Article 29(2) lists Article 18(1)(1) - the duty to report a significant incident - as a dangerous breach, so a missed 24-hour early warning, 72-hour notification or one-month final report can attract up to the full maximum. The low band holds Article 18(1)(2), the duty to report minor incidents. The practical consequence: classification matters as much as the clock - if an incident you treated as minor met the plan's significance thresholds, the duty in play was Article 18(1)(1).

How a fine is actually imposed

  • The fine is imposed by the head of the NKSC or a person they authorise - no court confirmation, no separate sanctions commission.
  • The default is a written procedure with no hearing. An oral hearing happens on the entity's request or the NKSC's own initiative, with at least 10 working days' notice.
  • The hearing is public by default, closed only to protect state, official, professional or commercial secrets or personal data. It is held in Lithuanian, with a guaranteed right to an interpreter, and the audio recording serves as the minutes.
  • Decision within 20 working days; a copy is sent within 3 working days.
  • No fine is imposed where one has already been imposed for the same breach under Article 58(2)(i) of the GDPR.
  • Appeal lies to the administrative courts. The fine must be paid within 3 months of service, or of the court judgment upholding it.
  • A breach counts as repeated where the same breach is committed within 12 months of an enforcement decision taking effect.
  • No measure can be imposed more than 2 years after the breach - or, for a continuing breach, 2 years after it came to light (Article 28(7)).
  • A fine decision is an enforceable title, collected under the Law on Tax Administration and the Code of Civil Procedure (Article 31(13), as amended from 30 June 2026).
We do not state a statutory minimum fine, because Lithuania has none. It sets ceilings, severity shares and the Article 28 weighing factors only.

What the NKSC can do to you

Article 28 gives the NKSC eleven enforcement measures, and a fine can be combined with any of them. Two reach further than most readers expect.

  • Warnings that the entity is in breach.
  • Binding instructions to essential entities on the measures needed to prevent or contain an incident, with deadlines for implementing them and for reporting back.
  • Orders to stop conduct that breaches the Act and not to repeat it.
  • Orders to bring risk-management measures into line with Article 14(1), or to comply with the Article 18 reporting duty, in a specified way and within a specified period.
  • Orders to inform your own customers of a significant cyber threat, its nature, and what they can do about it.
  • Orders to implement the recommendations of a cybersecurity audit within a reasonable period.
  • Appointment of a monitoring officer (stebėsenos pareigūnas) with defined tasks, for a defined period, to supervise an essential entity's compliance with Articles 14 and 18.
  • An order to make aspects of the breach public, in a specified manner.
  • A fine under Articles 30 and 31, combinable with any of the above.
  • Initiation of a temporary suspension of the right to carry on part or all of an essential entity's activity, or to provide services (Article 32). A district court orders it, only for a dangerous breach, only where measures 1-4 and 6 have proved ineffective and after at least 10 working days' notice to put things right - for no more than 4 months, extendable by up to 2 months at a time.
  • Initiation of the temporary removal of an essential entity's chief executive (Article 33), on the same conditions, for no more than 6 months, extendable by up to 3 months at a time. Decisions taken by a suspended chief executive are void.
A carve-out worth noting. The power to remove a chief executive does not reach the heads of public administration bodies appointed by the Seimas, the Government or the President of the Republic. And under Article 28(2), applying any measure neither discharges the underlying duty nor releases managers and staff from civil, administrative or criminal liability.

In setting a measure the NKSC must weigh the circumstances, the severity band, the duration of the breach, any breaches in the previous 2 years, the material and non-material damage caused, the steps taken to prevent or reduce it, adherence to approved codes of conduct or certification schemes, cooperation with the NKSC, the scale of the breach, and whether it was intentional or negligent (Article 28(3)).

How inspections work

  • Essential entities face planned inspections under an annual plan the NKSC approves in the first half of each year and does not publish, plus unplanned inspections on any ground. Important entities face unplanned inspections only, on information suggesting a breach (Article 26; Order No. 1-23, points 7-10).
  • Selection weighs significant incidents and critical vulnerabilities in the past year, leaked-data findings, earlier results - and KSIS questionnaire scores showing less than 50% of the requirements in place (Order No. 1-23, points 11 and 13).
  • You get 10 working days' notice of a planned inspection, 20 working days (plus up to 10 on request) to complete the questionnaire and 5 working days to produce documents; missing those deadlines is itself recorded as non-compliance (points 15-19 and 61).
  • Documents submitted for an inspection must be in Lithuanian (point 59).
  • The seven 24-month technical requirements can be tested hands-on - logging, network segmentation, hardening, access control, cryptography, continuity - against a test plan agreed with you, and you may see the NKSC's tools and scripts first (points 42-43 and 60).
  • An inspection runs up to 4 months, extendable to 6 (Article 27). Inspectors can enter premises, take copies for up to 30 days, and order a targeted audit at your expense where risk analysis shows a high risk (Article 27(3)). You get 20 working days to answer the draft report (Order No. 1-23, point 50).
Enforcement so far. The NKSC's 2025 activity report records 9 partial and 6 full-scope compliance inspections and 19 significant incidents investigated, and mentions no fine. Since 17 April 2026 the NKSC has been monitoring entities' KSIS submissions, with its compliance questionnaire mandatory for essential entities. In June 2026, after an incident at the Ministry of the Interior, the Minister of National Defence said the ministry planned to assign supervision officers to institutions.

The three-year cybersecurity audit

Article 14(8) requires every cybersecurity entity to carry out a cybersecurity audit at least once every three years, to a methodology the NKSC approves. Omitting it is a medium severity breach - up to half the maximum fine.

Who may audit

Independent auditors, audit firms or other bodies certified by internationally recognised organisations, or persons who have completed training under the NKSC's procedure and passed a qualification examination (Article 14(8)). Under Order No. 1-96, auditors complete training on nine set topics and a qualification examination, and hold one of 14 listed certificates - among them ISACA CISA and CISM, ISC2 CISSP, GIAC GSNA and ISO/IEC 27001 Lead Auditor. No auditor may assess systems of the entity that employs them.

How the audit is run

NKSC Order No. 1-25 of 24 February 2026 sets the methodology: built on ISO 19011, covering the Act, the Description or Regulation (EU) 2024/2690 and your own policies, and scored from 1 to 3 - under 50%, 50-89% and 90% or more of the requirements met. The report goes to your management, and the NKSC can demand it within 5 working days.

The regulator can commission one too

Under Article 7(3) the NKSC may engage an independent auditor, audit firm or other body - meeting its own independence, impartiality and reputation requirements - to carry out an audit, and can then order you to implement the recommendations. During an inspection it can also order a targeted audit at your own expense (Article 27(3)(2)).

And in between

The Description requires regular vulnerability assessment and a full vulnerability scan of the network and information system at least every six months, a compliance self-assessment at least once a year, and - for essential entities - the NKSC's compliance questionnaire, filed in KSIS every year (points 45.8, 48.1 and 51).

How Lithuania differs from the Directive

Ten things in the Lithuanian regime are not obvious from reading NIS2, and each of them changes what a compliance programme has to do.

  • Your duties start on registration, not on the law. Article 11(2). Every deadline is personal to your entity - though for the April 2025 cohort they have become national dates: 17 April 2026 and 17 April 2027.
  • The fine ceiling is banded by severity. Article 30(3) caps a low-severity breach at 10% of the headline maximum. The headline number applies to two duties only: the risk-management measures and significant-incident reporting.
  • Public bodies are fined, on their own scale. Up to 1% or 0.5% of budget, capped at EUR 60,000 and EUR 30,000. Not exempt, and not on the commercial scale either.
  • Minor incidents are reportable. Article 18(1)(2) reaches incidents that do not meet the significance test: a notification within 72 hours and a final report within a month.
  • Two named roles, with a statutory qualification test. A kibernetinio saugumo vadovas and a saugos įgaliotinis, each subject to Article 15(5) - including, as one route to qualifying, the NKSC's course and cybersecurity manager examination. Most transpositions name one role, or none.
  • The regulator can switch services off for 48 hours. Article 7(2)(6) lets the NKSC order public electronic communications providers, online marketplaces, search engines, cloud providers and hosting providers to restrict provision for up to 48 hours to stop an incident's impact, and Article 7(2)(7) to block domains used for malware, phishing or attack coordination.
  • The regulator puts its own tools in your network. Article 16: the NKSC installs and runs technical cybersecurity measures in essential entities' systems, at its own cost, and essential entities must let it; important entities can ask for them to handle an incident.
  • Post-quantum cryptography is already law. Resolution No. 185 writes into the Description a cryptography inventory from 1 January 2027, post-quantum migration plans from essential entities by 1 May 2027, post-quantum or hybrid cryptography in their high quantum-risk systems from 2031, and post-quantum algorithms everywhere asymmetric cryptography is used from 2036.
  • Good-faith vulnerability research is lawful. Article 25 protects searching for vulnerabilities in cybersecurity entities' systems within set limits - no disruption, no password guessing, a report to the NKSC or the entity within 24 hours of starting - with public disclosure no earlier than 90 days after reporting, unless the NKSC sets a shorter period of at least 3 days.
  • Suppliers can be drawn in directly. Under the special criteria, a long-term supplier with access to an essential entity's systems can itself be identified as an essential or important entity.
What we deliberately do not state. No predicted enforcement figures and no fine totals. The NKSC's reports give inspection and incident counts, and we print those; we print nothing it has not published.

How to prepare for NIS2 in Lithuania

  1. Check if you are likely in scope: review your sector, size and role against Annexes 1 and 2 and Article 11 - including the 50% revenue test, the no-size categories and the special criteria. The NKSC's online register check is switched off, so ask its register team directly.
  2. Establish your registration status in KSIS, and do it first: it determines whether you have any obligations at all and when your clocks started. If you meet the Article 11 criteria and are not registered, Article 13(4) puts the duty to submit your data on you.
  3. Run a gap assessment against the right text: the Description of Cybersecurity Requirements, or Regulation (EU) 2024/2690 if you are one of the digital providers. The NKSC's compliance questionnaire in KSIS is the yardstick its inspectors use, and essential entities must file it every year.
  4. Appoint your kibernetinio saugumo vadovas and saugos įgaliotinis: check the Article 15(5) test for each. The carry-over for incumbent security officers runs only to 18 October 2026; from 19 October, anyone without the experience, diploma or certificate needs the NKSC course and examination. Keep both roles separate from system administration; the functions can be bought in from a supplier.
  5. Plan against your own registration date: 12 months for the requirements generally and 24 for the seven listed technical requirements. For the April 2025 cohort that means 17 April 2026 has passed and 17 April 2027 is next - and there is no extension for either.
  6. Build classification into your incident plan: the incident plan's point 9 thresholds decide which chain applies. Every stage of the significant-incident chain is a dangerous-band duty; minor incidents need a 72-hour notification and a final report within a month. File through the national platform, and set up automatic registration within 12 months of registration.
  7. Review supply-chain risk: map critical suppliers and update contracts with explicit cybersecurity, audit and incident-notification clauses - and, if you supply an essential entity yourself on a long contract with access to its systems, check whether the special criteria reach you.
  8. Use frameworks, but test against the Description: the Description draws some of its definitions from LST EN ISO/IEC 27002, and the NKSC's December 2025 risk-assessment methodology builds on ISO/IEC 27005, NIST and BSI practice. ISO/IEC 27001 is a sound structure, but the Description's controls are what an inspection checks.
  9. Train the board: management body members, the head and any authorised person need at least 2 academic hours of training on ten set topics every two years, with the certificate uploaded to KSIS (Order No. 1-96).
  10. Start the cryptography inventory now: it becomes a requirement on 1 January 2027, and essential entities owe a post-quantum migration plan by 1 May 2027.

Official links & resources

FAQ: NIS2 in Lithuania

Has Lithuania fully transposed NIS2?
Yes, and early. The Kibernetinio saugumo įstatymas has been in force since 18 October 2024, with Government Resolution No. 945 of 6 November 2024 supplying the detail. The Act has since been amended twice, most recently with effect from 4 July 2026, and the implementing Resolution four times, most recently in June 2026.
How will we know if we are in scope?
The NKSC builds the register in KSIS with the sectoral ministries; the first sweep entered 1,443 organisations in April 2025, the NKSC said it would notify each by email, and special-criteria entities are being added during 2026. But do not treat silence as an answer: Article 13(4) requires an entity meeting the Article 11 criteria to submit its own data, and under Article 11(2) your obligations begin only once you are registered.
How long do we have to comply once registered?
12 months from registration in KSIS for the cybersecurity requirements generally, and 24 months for the technical requirements listed in points 26, 31, 47, 57, 60, 64 and 69 of the Description of Cybersecurity Requirements - for the April 2025 cohort, 17 April 2026 and 17 April 2027. Only the separate 12-month deadline for automatic incident registration can be extended, once, by up to a further 12 months, on a reasoned request.
Who is the NIS2 competent authority in Lithuania?
The Nacionalinis kibernetinio saugumo centras prie Krašto apsaugos ministerijos - the NKSC, an institution under the Ministry of National Defence. It is the competent authority, the CSIRT and the single point of contact, and it imposes the fines itself. The ministries named in the Act's annexes share the identification of entities in their sectors.
Is ISO 27001 certification mandatory?
No. What is mandatory is a cybersecurity audit at least once every three years under Article 14(8), carried out to the NKSC's methodology (Order No. 1-25) by certified auditors or persons trained under the NKSC's procedure. ISO/IEC 27001 is a common way to structure the underlying controls, but the Act requires the audit against the Description, not the certificate.
What is the maximum fine, really?
It depends on the breach, not just the entity. Article 30(2) sets the maximum at EUR 10,000,000 or 2% of worldwide turnover for essential entities and EUR 7,000,000 or 1.4% for important ones - but Article 30(3) then allows only 100%, 50% or 10% of that maximum depending on whether Article 29 classifies the breach as dangerous, medium or low severity. Every stage of reporting a significant incident - the 24-hour warning, the 72-hour notification and the final report - is in the dangerous band; failing to report a minor incident is low severity, capped at 10% of the maximum.
Do we have to report incidents that are not significant?
Yes. Article 18(1)(2) requires cybersecurity entities to report incidents affecting their qualifying services even where they do not meet the significance criteria in Article 18(2), within the deadlines and in the form set by the national cyber incident management plan: a notification within 72 hours and a final report within a month. This duty has no equivalent in most other member states.
What does 18 October 2026 mean for security officers?
It is the last day of the two-year carry-over. Security officers appointed before 18 October 2024 are exempt from the Article 15(5)(3) qualification limb until then; from 19 October 2026 they must show two years' relevant experience, a relevant degree, an internationally recognised certificate, or the NKSC course and cybersecurity manager examination (XIV-2902, Article 2(6); Order No. 1-96).
Does Lithuania require post-quantum cryptography?
Yes, on a timetable. From 1 January 2027 the Description of Cybersecurity Requirements makes every entity it covers inventory its cryptography at least every three years and identify high quantum-risk systems. All essential entities owe a migration plan by 1 May 2027; under the Description, essential entities must use post-quantum or hybrid cryptography in those systems from 2031, and from 2036 post-quantum algorithms apply wherever asymmetric cryptography is used, for essential and important entities alike (Resolution No. 185).
Information provided for general guidance and verified against the Kibernetinio saugumo įstatymas as consolidated on 4 July 2026 and Government Resolution No. 818 as in force in October 2026; always consult the official Lithuanian legislation, NKSC publications and legal counsel for definitive NIS2 compliance requirements.