If you run a company or sole proprietorship in the Netherlands, a message like this may reach you: "Please complete the attached security questionnaire about your practices." The sender is often in a sector the state treats as important, such as energy, transport, healthcare, food or IT services.
The background is the Dutch cybersecurity law, the Cyberbeveiligingswet (Cbw), in force since 15 August 2026. It transposes the EU's NIS2 Directive into Dutch law and requires covered organisations to take security measures, register with NCSC and report incidents.
The confusing part is this: you may be out of scope and still be asked for requirements by an in-scope client. The legal duty rests with the in-scope organisation. But that organisation must also secure its supply chain (toeleveringsketen, pronounced roughly "too-LAY-fer-ings-kay-tuh"). Whoever looks after a client's website or hosting can end up doing part of that checking.
This article uses primary sources (NCSC, KVK, RVO, the official gazette) checked on 31 October 2026, together with press reports, to cover three things:
- the status and dates of enforcement, including why they may still shift
- a two-step check for whether you are directly in scope: sector and size
- what in-scope clients may ask of you, and what to prepare for your site and hosting
DevNJ is a web studio, not a law firm. What follows is general information, not legal advice.
Main sources used
- NCSC's Cyberbeveiligingswet (NIS2) pages (effective date, registration, the 10 zorgplicht measures, supervision, FAQ)
- NCSC: "Valt mijn organisatie onder de Cyberbeveiligingswet (NIS2)?" (sector and size tests)
- KVK (Chamber of Commerce): examples of what suppliers may be asked
- RVO: "Mijn cyberweerbare zaak (MCZ)" (small-business subsidy; websites excluded)
- Staatsblad 2026, 187 (the act) and reports from Security Management, Accountant.nl, SRA and Consultancy.nl
| What you want to know | Short answer |
|---|---|
| When did it start | In force since 15 August 2026 (checked 31 Oct 2026) |
| Am I in scope | Two steps: sector (annexes 1 and 2) and size (50 FTE or more, etc.) |
| If out of scope, can I ignore it | No legal duty, but in-scope clients may set requirements |
| What to prepare for the site | Software inventory, update and backup records, contacts, hosting contract |
| Is there financial help | MCZ subsidy (up to EUR 1,250), but website measures are excluded |
1. What is happening now: in force since 15 August 2026
Dates matter in this area, and the start date moved several times. It is settled now, but treat operational details as subject to change.
How it got here
The NIS2 Directive (2022/2555) asked member states to transpose it by 17 October 2024. The Netherlands missed that date, according to Security Management's timeline. Later targets included Q3 2025, 1 January 2026 and Q2 2026, and the last plan was 1 July 2026.
The lower house (Tweede Kamer) passed the bill (36.764) on 15 April 2026, and the Senate committees reported on 2 June. A government memorandum then moved the start from 1 July to 15 August. The act is dated 8 July 2026 and published as Stb. 2026, 187, with the commencement decision as Stb. 2026, 189 (per the gazette listing).
The grey dot marks a missed deadline; the orange dots are confirmed dates. In table form:
| Date | Event | Source |
|---|---|---|
| 17 Oct 2024 | EU transposition deadline; Netherlands not ready | Security Management |
| 15 Apr 2026 | Lower house passes the bill | Security Management |
| 2 Jun 2026 | Senate committees report | Security Management |
| 8 Jul 2026 | Date of the act (Stb. 2026, 187) | NJB (gazette listing) |
| 15 Aug 2026 | In force; replaces the Wbni | NCSC |
The start date is now fixed, but the road there shows how often plans moved. Operational details such as how supervision works could shift in the same way.
Where things stand after the start
NCSC says the law took effect on 15 August 2026 and puts the number of organisations at over 8,000. Accountant.nl reported in August that roughly 3,200 of the 8,000-plus had entered the register so far.
NCSC's FAQ says, in essence, that how supervision will work is still being developed. NCSC's explanatory pages also give no fine amounts. For reference, the NIS2 Directive requires member states to set maximum fines of at least the following (European Commission NIS2 FAQ, checked 31 October 2026): EUR 10 million or 2% of worldwide annual turnover for essential entities, and EUR 7 million or 1.4% for important entities, whichever is higher. These are the levels the Directive requires; the actual amounts in Dutch law were not checked for this article.
What the delays teach
Once in force, the duties apply even if the date moved. Security Management advised organisations to keep preparing, since the obligations themselves did not change with the delay. Clients may have started sending questionnaires before the start date.
2. What the law requires: three duties
The Cbw asks in-scope organisations for three things: registration, measures (zorgplicht) and reporting (meldplicht). NCSC's front page presents the same three. Knowing them helps you read what a client is worried about.
| Duty | Dutch term | Content | Where |
|---|---|---|---|
| Registration | registratie | Submit organisation and network details (IP, domains) | mijn.ncsc.nl |
| Measures | zorgplicht | Assess risk and take appropriate measures (10 measures) | In-house |
| Reporting | meldplicht | Report significant incidents; first report within 24 hours | CSIRT and the sector supervisor |
The duties fall on the in-scope organisation itself, not directly on suppliers. Because "securing the supply chain" is among the measures, requirements still reach suppliers indirectly.
Registration
Registration is done at mijn.ncsc.nl. Login uses eHerkenning (assurance level EH2 or higher, with authority tied to the KvK number) or SSOnRijk. There are five steps (organisation data, additional data, contact data, network data, summary and submit), and changes must be reported in MijnNCSC within 14 days, which is a legal duty (NCSC registration page).
Measures (zorgplicht)
NCSC lists 10 minimum measures. Organisations decide for themselves which are appropriate, with risk management as the basis. Management responsibility is described on NCSC's front page, and the FAQ says supervisory measures can, as a last resort, also affect individual directors.
Reporting (meldplicht)
Significant incidents go to both the CSIRT and the competent supervisor (gazette summary). The first report is due within 24 hours. Even when the cause is a supplier's website, the in-scope client may have to report, which is why clients care how fast a supplier gets in touch.
3. Are you directly in scope? Sector and size
You are directly in scope depending on two things in sequence: sector and size. NCSC frames them as two questions.
The figure shows the flow only; it is not a determination. Use NCSC's page and self-assessment tool for the real answer.
Checking the sector
According to NCSC, the law applies to sectors in annexes 1 and 2. Annex 1 includes energy, transport, banking, healthcare and government, plus Digitale infrastructuur (digital infrastructure) and Beheer van ICT-diensten (ICT service management). Agencies and hosting companies that maintain websites or servers for others may be directly in scope if they meet the size test, so check the definitions of those two sectors (gazette and NCTV page) against what you do. NCSC's page itself gives no detailed description of them. Annex 2 includes digital providers, food, research and manufacturing. Some sectors have specific criteria set by the responsible ministry, reachable through the NCTV page.
The size test
NCSC's page treats you as large enough if either of these holds.
| Condition | Content |
|---|---|
| A | 50 or more employees (FTE) |
| B | Fewer than 50 employees, but annual turnover and balance sheet total both above EUR 10 million |
Under B, turnover and balance sheet total must both exceed the threshold. KVK's page words it more briefly ("at least 50 employees and turnover above EUR 10 million"), which differs from NCSC. Since the two public pages differ, this article follows NCSC, which gives the fuller test.
How to count
NCSC says partner and linked enterprises (a parent or subsidiaries) are counted together when you work out employees, turnover and balance sheet total. A small company inside a group can therefore exceed the threshold.
In scope regardless of size
The size test does not apply to:
- DNS service providers (a hosting company or agency that runs DNS for its customers' domains itself may fit this regardless of headcount, so check with NCSC's self-assessment tool)
- providers of public electronic communications networks and services
- trust service providers
- top-level domain name registries
- government bodies
KVK likewise says trust service, DNS and domain registration providers are always covered. In addition, a competent minister can designate smaller organisations individually.
Out of scope means no registration
NCSC says that if the law does not apply to you, you do not need to register, while adding that keeping up security measures remains sensible.
4. Why out-of-scope companies still get asked
If the legal duty does not reach you, why the questionnaire? This is the core of the matter.
The duty is the client's; supply chain checks are part of it
In NCSC's zorgplicht page, "secure your supply chain" is one of the 10 measures. It means mapping direct suppliers, working through supply chain risks and talking with suppliers to raise their resilience. NCSC adds that you depend on your suppliers and service providers even if your own organisation is well secured.
KVK's section "Ik lever aan een Cbw-bedrijf" (I supply a Cbw company) says in-scope companies must secure the cybersecurity of their supply chain, so suppliers need to be able to show their own security. Even an out-of-scope small company may face strict requirements if a client is in scope.
The figure shows requirements flowing downward. A site owner sits in the middle: questions arrive from above, and the same questions go down to your providers.
What you may actually be asked
KVK gives examples of what suppliers may be asked by an in-scope client. Requirements differ by client, so KVK advises discussing them in advance.
| Possible question | In website terms |
|---|---|
| Do you follow a security standard (e.g. ISO 27001)? | Certified or not; if not, discuss records instead |
| Is your risk approach documented? | A one or two page operating policy |
| Two-factor authentication on all accounts? | CMS admin, hosting, domain, email |
| Security updates applied regularly? | Record of CMS, plugin and PHP updates |
| How fast do you tell clients about attacks or flaws? | Contact point and procedure |
| Are important data backed up? | Frequency, location, tested restore |
| Is there a business continuity plan? | Recovery steps after an outage |
| Is staff trained? | Phishing awareness for admins |
Most questions map onto how the site and hosting are run. Whether you must answer all of them depends on the client. The basic approach is to answer each item against your actual situation.
Government knows suppliers carry a load
In October 2024 Rijksoverheid published a survey of suppliers to companies bound by NIS2 (commissioned by the Digital Trust Center). The page says in-scope organisations are responsible for the security of their chain, so firms in the chain are expected to meet higher standards. This article could not confirm the survey's findings or sample.
5. NCSC's 10 measures, translated to site operations
Here are the measures that touch websites and hosting. The right-hand column is DevNJ's own mapping, not NCSC wording.
| Measure (NCSC) | In site operations (DevNJ's mapping) |
|---|---|
| 1. Risk analysis | List of assets (site, customer data, email) and threats |
| 2. Incident response | Written steps for who is called and who fixes |
| 3. Preparing for outage | Backups, recovery steps, practice |
| 4. Supply chain security | Inventory of hosting, agency and plugin providers |
| 5. Cyber hygiene | Basic habits and reminders to admins |
| 6. Securing network and information systems | Applying updates, switching off unused features, a vulnerability contact |
| 7. People, access and assets | Admin account review, separation of rights |
| 8. Passkeys and multi-factor authentication | 2FA on admin and hosting panels |
| 9. Cryptography policy | HTTPS and certificate expiry management |
| 10. Assessing effectiveness | Yearly review with a written record |
More than half of the ten measures connect directly to day-to-day site operations. Measures 3, 4, 6 and 8 are the areas questionnaires ask about most.
6. What to prepare for your site and hosting
Now the practical part. None of this is something the law directly demands of small suppliers; it is DevNJ's suggestion for being ready when a client asks.
An inventory of software in use
Start with a list of what you run: the CMS (such as WordPress), plugins, themes, PHP version, hosting provider, where the domain is managed, the email sending service and analytics tags. Without it, you cannot say whether a newly announced vulnerability affects you.
During the PHP vulnerability (PHP2Shell) in October 2026, the first question was "which PHP version is my site on?". The aftermath is covered in PHP2Shell: what happened next.
Update records
NCSC asks for a patch management policy so security updates are applied within a reasonable period. It adds that when choosing new systems you should check the supplier keeps providing updates.
A record is simple: one row per update in a table like this.
| Field | Example content |
|---|---|
| Date | Day of the update |
| Target | CMS, plugin name, PHP |
| Versions | 6.7.1 to 6.7.2 |
| Trigger | Routine, vulnerability notice, vendor advice |
| Checked by | Who verified the pages |
Five columns are enough. The aim is to answer "when, what and by whom" when someone asks.
Backups and tested restores
NCSC wants you to plan for outage: a backup policy that fixes frequency, storage location and test timing.
- Frequency: daily for busy sites, on each change for static ones; match the site
- Location: not only on the same server; also at another host or storage
- Restore test: try restoring regularly and write down the result
Having backups is not enough for a questionnaire. A record of a successful restore makes your answer concrete.
Handling vulnerabilities
NCSC also lists a clear contact point where researchers can report vulnerabilities safely. Even a small site benefits from one address for security reports, separate from the general contact form.
Also set your own update deadline, for example how many days after an announcement a critical fix is applied. One written line is already a policy. Choose the number according to the site's importance and how hard updates are.
Admin accounts and two-factor authentication
KVK's examples include whether all accounts use two-factor authentication. NCSC also recommends passkeys (FIDO2) and multi-factor authentication. Check four places first: the CMS admin, the hosting panel, the domain panel and the email admin. Review old accounts of people or agencies no longer involved.
Contracts with providers
If an agency or hosting company runs your site, that company is your supplier. The next chapter covers what to check in the contract.
7. What to check in contracts with hosting and agencies
Consultancy.nl writes that the Cbw pushes IT contracts to be revisited: older ones focus on service levels and price, with security clauses limited to generic phrases such as "appropriate measures". The table below adapts that article and NCSC's explanation to site operations.
| Check | Why |
|---|---|
| Incident notice deadline | The client's first report is due within 24 hours; a slow supplier cannot keep up |
| Disclosure of subcontractors | Requirements must reach cloud providers behind the supplier |
| Update and backup responsibility | Where the supplier's job ends and yours begins |
| Evidence on request | Can you receive update and backup records when needed |
| Exit and migration | Return of data and help moving |
The takeaway is to put responsibilities in writing. Assuming "the hosting company watches the server" or "the agency does the updates" is what hurts most when a questionnaire arrives.
Incident notice deadlines
Consultancy.nl describes reporting to NCSC as an early warning within 24 hours, an interim report within 72 hours and a final report within a month. It gives an example clause asking suppliers to notify within 8 to 12 hours. That figure is an illustration from the article, not a legal deadline.
Subcontractors
If your hosting company uses another cloud provider, the requirements need to reach that provider too. Ask for a list of subcontractors and notice of changes.
Exit
Will data be returned when you leave, in what format and by when? If the contract is silent, switching gets hard. Consultancy.nl also recommends planning how to switch to an alternative.
Contract wording has legal effect. The table is a checklist, not draft clauses. Have the actual wording reviewed by a lawyer or similar professional.
8. Cost and funding
DevNJ prices are not covered here. This chapter gives a way to think about cost and the public support that may be available.
Where the cost sits
Site-side preparation costs fall into three groups.
- First organisation: inventory, record templates, admin account review
- Ongoing operation: applying and recording updates, restore tests, a yearly review
- Contract review: agreeing responsibilities with hosting and agency (including advice)
Amounts vary widely with size and setup. No market rate is given here, because no public figure was found to support one. When getting quotes, compare along these three groups.
MCZ subsidy: usable, but websites are excluded
For small businesses there is the "Mijn cyberweerbare zaak (MCZ)" subsidy. Conditions on RVO's page:
| Item | Content |
|---|---|
| Application window | 7 Sep 2026 09:00 to 30 Nov 2026 17:00 |
| Rate | 50% of eligible costs |
| Cap | EUR 1,250 per application |
| Minimum | Eligible costs of at least EUR 400 |
| Who | Sole traders and small firms: up to 50 employees, last-year turnover under EUR 10 million, registered with KVK |
| Measures | 8 categories (Wi-Fi and firewalls, password managers, 2FA, patch management, antivirus, backups, risk assessment, training) |
| Excluded | Websites, webshops, online platforms, payment systems, cloud workplaces |
MCZ covers protecting internal business systems, so it cannot be used for website measures. It may apply to backups or two-factor authentication on office devices. Check RVO for the latest conditions; the window can close early if funds run out.
An industry framework
"Samen Digitaal Veilig", run by MKB-Nederland and VNO-NCW, aims to raise suppliers' digital resilience. According to MKB Servicedesk (updated 4 August 2025), SMEs can obtain a three-level certification matched to clients' requirements. The current scheme and its cost were not checked here. Keep it in mind if a client asks for a specific certificate.
9. Where people get tripped up
Practical pitfalls that the rules alone do not reveal.
| Pitfall | What happens | Remedy |
|---|---|---|
| "We are small, so it does not apply" | Cannot answer a client's questionnaire; business stalls | Prepare the inventory and records before asked |
| Self-judging scope | Group totals pushed you over the threshold | Use NCSC's self-assessment tool |
| "Hosting handles it" | Responsibility is unclear and nobody acts in an outage | Write down the split in contract and operations |
| Backups without restores | Restore fails and the outage drags on | Test a restore and record it |
| Old PHP or plugins left running | Vendor support ends, flaws remain | Note end-of-support dates in the inventory |
| Records kept verbally | Cannot show when an update was done | One line per update |
| Overstating answers | Later found untrue; trust lost | Write "in progress" for gaps |
The lesson is that honest answers beat polished ones. Questionnaire replies feed into contracts and trust. Reply with a target date for what is missing.
Re-check "out of scope" over time
Size changes as you grow. Check again when you approach 50 FTE, join a group, or turnover and balance sheet total grow.
10. Japanese companies running sites for Europe
Some readers may run, or plan, a European-facing site from Japan. Here is what could be confirmed.
What this article did not verify
The Cbw is Dutch law. Which country's law applies to a non-EU business, or to one established in another member state, depends on where it is established and what it offers. This article did not confirm those criteria from primary sources. This is a point for a specialist.
The supplier side looks the same
If you deal with an in-scope Dutch company, you may be questioned as a supplier even from Japan. The questions (two-factor authentication, updates, backups) are common across countries.
| Your position | First thing to check |
|---|---|
| Company in the Netherlands | Whether NCSC's sector and size tests apply directly |
| Supplier in Japan to a European client | Whether the client is in scope; if so, ask for their requirement list first |
| Running a site for Europe | Hosting location and contract, data processing terms |
The first step depends on the position. If unsure, the quickest route is asking the client: "Are you in scope of the Cbw, and what do you require of suppliers?" KVK also recommends discussing requirements in advance.
11. Cases (all hypothetical)
The three cases below are hypothetical and show how answers differ by position. They are not real companies or people.
| Case | Situation | Directly in scope? | First steps |
|---|---|---|---|
| A: design studio | 6 staff; runs a regional food maker's site | Probably not (size) | Ask whether the client is in scope; set up update and backup records |
| B: webshop | 3 staff; sells to consumers; retail suppliers | Likely not | Self-assess sector and size; 2FA on payment and admin |
| C: manufacturer | 40 staff; turnover EUR 12M, balance total EUR 15M | Possibly, depending on sector | Use NCSC's self-assessment; if in scope, register and apply measures |
In case C, fewer than 50 FTE is not enough to exclude it: turnover and balance sheet total both exceed EUR 10 million, so the size test is met if the sector is listed. Cases A and B carry no direct legal duty, but their actions depend on their clients.
How case A would proceed
If the food maker is in scope, a questionnaire may arrive. Studio A would first prepare five things: (1) an inventory of software, (2) update records, (3) a tested backup restore, (4) two-factor authentication for admins, (5) the hosting contract's split of responsibilities. It would answer "yes" to what is done and "in progress, by month X" to what is not.
How case B would proceed
A webshop often leaves much to a payment provider or platform, so understanding its own scope of responsibility matters. MCZ excludes webshop measures, so it could apply only to office devices.
12. What not to do
| Do not | Why |
|---|---|
| Mark things "done" that are not | Breach of trust and possibly contract |
| Quote fines or deadlines unchecked | Dutch amounts were not confirmed even here; risk of misinformation |
| Assume "out of scope" without checking | Group totals or designation can bring you in |
| Keep backups only on the same server | A server failure takes both the site and the backup |
| Run unsupported versions | Once vendor updates stop, flaws stay |
| Sign contracts unread | Responsibility and incident notice stay vague |
| Settle legal questions from web articles alone | Individual cases need an adviser or NCSC's tool |
The safest approach is to say plainly when you do not know. This article likewise leaves out what it could not confirm: Dutch fine amounts, supervision details and treatment of foreign businesses.
13. Order of action and checklist
Steps you can start tomorrow.
Steps
- On NCSC's "Valt mijn organisatie onder de Cyberbeveiligingswet (NIS2)?", check sector and size; use the self-assessment tool if unsure
- Ask main clients whether they are in scope; if so, ask for their list of supplier requirements
- List software used by site and hosting (CMS, plugins, PHP, hosting, domain)
- Decide an update record format and start from the latest update
- Fix backup frequency and location, try one restore and record the result
- Check two-factor authentication on admin accounts and tidy unused ones
- Read the hosting and agency contracts; confirm responsibilities and notice deadlines; raise gaps
- Set a date for a review in one year
Checklist
- Checked whether you are directly in scope (sector and size)
- Asked main clients whether they are in scope
- Have an inventory of software in use
- Started recording updates
- Tested and recorded a backup restore
- Enabled two-factor authentication on admin accounts
- Chose a contact for vulnerability reports
- Wrote down the split of responsibility with hosting and agency
- Set a review date
14. Summary
- The Cbw took effect on 15 August 2026; it implements the EU NIS2 Directive and replaces the Wbni
- Direct scope is decided in two steps: sector (annexes 1 and 2) and size (50 FTE or more, etc.)
- Out-of-scope companies carry no direct legal duty but may be asked by in-scope clients as part of supply chain checks
- Site-side preparation boils down to an inventory, update and backup records, contacts and provider contracts
- The MCZ subsidy (up to EUR 1,250) cannot be used for website measures
- Dutch fine amounts and supervision details could not be confirmed here; check with a specialist and the competent supervisor
- Dates and practice may change. This is a snapshot as of 31 October 2026 and not legal advice
If you want outside help organising updates, backups and contracts for your site, see our services and then get in touch with your situation. Including the items from a client's questionnaire makes the conversation faster. More articles are in the column.
Sources
All checked on 31 October 2026. Rules and dates change, so confirm on the official sites before acting.
Public bodies
- NCSC: Cyberbeveiligingswet (NIS2): effective date (15 August 2026), number of organisations
- NCSC: Cyberbeveiligingswet front page: the three duties, management responsibility
- NCSC: Does my organisation fall under the Cbw?: sector and size tests
- NCSC: Register your organisation: registration steps, change notices
- NCSC: Zorgplicht: the 10 measures, supply chain, backups, updates
- European Commission: NIS2 FAQ: fine ceilings required by the Directive
- NCSC: Supervision: supervisors by sector
- NCSC: FAQ: supervision still being developed
- KVK: New Cyberbeveiligingswet, are you ready?: examples of supplier requirements
- RVO: Mijn cyberweerbare zaak (MCZ): subsidy terms, websites excluded
- Rijksoverheid: flash survey on NIS2 among suppliers (16 October 2024): scope of the supplier survey
- NJB: Staatsblad 2026, 187 and 189: the act, dates, repeal of the Wbni
Press and commentary
- Security Management: why the 1 July start looked unfeasible: timeline
- Accountant.nl: Cbw in force, register still missing thousands: registration numbers
- SRA: the Cbw affects more organisations than you think: effect on business partners
- MKB Servicedesk: cyber rules and SMEs: Samen Digitaal Veilig
- Consultancy.nl: the Cbw and IT sourcing contracts: a contract-review perspective
Related article
- PHP2Shell: what happened next: checking PHP versions and applying updates
FAQ
- When did the Dutch Cyberbeveiligingswet (Cbw) take effect?
- On 15 August 2026. It implements the EU NIS2 Directive (2022/2555) in Dutch law and replaces the earlier Wbni. The act is dated 8 July 2026 (Stb. 2026, 187). The target had earlier been 1 July, so dates in this area have moved before.
- Does a company with only a few employees fall under the Cbw?
- Usually not directly. By NCSC's test a business must be in a covered sector and have 50 or more FTE, or fewer than 50 FTE but turnover and balance sheet total both above EUR 10 million. A minister can also designate smaller organisations individually.
- Why would a client send a security questionnaire if I am out of scope?
- In-scope organisations must also secure their supply chain (toeleveringsketen). The legal duty sits with them, but the checking work lands on suppliers and service providers. Typical questions cover updates, backups, two-factor authentication and incident notice.
- What should a site owner prepare first?
- Five things: an inventory of the software you run (CMS, plugins, PHP), a record of updates, backup frequency with a tested restore, two-factor authentication on admin accounts, and contact points at your hosting provider. Most questionnaires fit inside these.
- What are the fines for non-compliance?
- NCSC's pages give no amounts. The NIS2 Directive requires member states to allow maximum fines of at least EUR 10 million or 2% of worldwide turnover (essential entities) and EUR 7 million or 1.4% (important), whichever is higher. Dutch amounts were not checked; ask the supervisor.
- Is this article legal advice?
- No. It is general information compiled from primary sources checked on 31 October 2026. Whether you are in scope, and how contract wording should read, is for NCSC's self-assessment tool or a qualified adviser to decide.
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