NIS 2 in Polish retail and e-commerce. There are 3 months left to register in the KSC List – how to prepare?

The amended Act on the National Cybersecurity System (KSC), which implements the NIS 2 Directive, entered into force on 3 April 2026. For many companies in the retail and online industries, this means completely new legal obligations.

The deadline for self-registration of companies in the KSC List is October 3, 2026. There are only three months left, and many retail chains and e-commerce platforms still do not know that the new regulations directly cover them. Ignoring this obligation can cost the company up to 10 million euros. Check how you need to prepare.

Highlights

• The amended KSC Act has been in force since 3 April 2026 and transfers the EU requirements of the NIS 2 Directive to the national soil.
• By 3 October 2026, entities that meet the criteria must be submitted to the KSC List.
• Retail itself, as a rule, is not included in the directive. However, the regulations cover companies involved in wholesale food distribution (many FMCG chains) and operators of medium and large marketplaces.
• Depending on the qualifications, failure to adapt the procedures may result in penalties: for important entities it is up to EUR 7 million (or 1.4% of turnover), and for key entities up to EUR 10 million (or 2% of turnover).
• Technology partners, i.e. Exorigo-Upos, help you go through the entire process – selected elements can be: audits and migrations to a secure cloud (Exorigo CLOUD), as well as the implementation of business continuity plans (BCPs).

What is NIS 2 and why does it affect stores and e-commerce?

The rapid growth of brick-and-mortar stores and e-commerce platforms has included integrated POS systems, extensive customer databases, loyalty programs, and cloud-connected supply chains. In the wake of this digitalisation, commerce has become one of the main targets of cybercriminals.

However, it is worth clarifying that classic retail trade itself is not subject to the new Act. The Act applies to specific categories of activity. The first is wholesale distribution and processing of food – many large retail chains (FMCG) that have their own distribution centres and operate at the wholesale level are subject to new obligations.

Secondly, online marketplaces. Operators of medium and large e-commerce platforms that connect buyers with sellers have been classified as important entities due to the scale of their digital operations and the data they process.

October 3, 2026 is the last time to register

Since the KSC Act came into force in April, the most important step for any company in the retail industry has been to complete the administrative formalities. Self-registration in the KSC List maintained by the relevant state authorities is a legal requirement.

There are only three months left until the deadline of 3 October 2026. The application should be preceded by a thorough verification, among others: 

• company and capital group structure,
• the industry in which the entity provides services,
• the IT systems used,
• supplier relationships.

The penalties for ignoring the regulations are severe and depend on the company’s status. For the so-called important entities, the maximum penalty is EUR 7 million or 1.4% of the company’s total annual turnover. However, if a company is classified as a key entity, the sanctions increase up to EUR 10 million or 2% of annual turnover.

How to prepare? Practical steps for the retail industry

It is best to approach the topic systematically and start by thoroughly examining the current state of security in the organisation.

1. Reliable cybersecurity audit and vulnerability analysis

The most sensible thing to do is to start with an independent check of your IT infrastructure. An audit allows you to detect weak points in cash register systems, online stores or internal databases before hackers exploit them. Experts at Exorigo-Upos help locate these threats and pinpoint specific areas for immediate improvement. It is worth extending the audit with a gap audit, which will indicate deficiencies in security areas in relation to legal requirements

2. Secure Cloud Environment (Exorigo CLOUD)

Keeping data on local servers is a huge risk today. The transition to modern, secure cloud solutions (such as Exorigo CLOUD) guarantees a high level of encryption, protection against leaks, and constant supervision of the flow of information, which is in line with the EU NIS 2 standards.

3. Business continuity and Maintenance 4.0 – 24/7 reliability

The KSC Act requires important entities to be fully resilient to failures and disruptions. In retail, every minute of downtime at cash registers or online stores translates into measurable financial losses and a decrease in customer confidence. To effectively secure your business, it is worth betting on a modern approach to system maintenance: Maintenance 4.0. It allows for constant monitoring of the infrastructure, quick detection of anomalies and prevention of failures before they occur. Read more about how to ensure business continuity around the clock in the Maintenance 4.0 article.

Meeting legal requirements and creating business continuity procedures requires expert support. If you want to go through this process without stress, avoid mistakes, and be sure that your network or e-shop meets all the criteria of the Act, check out Exorigo-Upos’ proposed solutions for NIS 2 compliance.

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