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NIS2 Implementation in the EU

Sweden

(Europe) Firm Advokatfirman Vinge KB

Contributors Lisa Bourghardt

Updated 29 Jan 2026
Status of the legislative process

Enacted

Status of the NIS2 Implementation Act

On 11 December, the Swedish government adopted a new Cybersecurity Act (Sw. cybersäkerhetslag) implementing NIS2, replacing the prior NIS Act, and decided on a new cybersecurity regulation (Sw. cybersäkerhetsförordning). All legislative amendments came into force on 15 January 2026. Sweden's implementation of the NIS2 Directive through a new Cybersecurity Act consolidates the core requirements of the directive, including the scope, risk-based security measures, incident reporting, supervision, and sanctions.

Significant deviations of the National Implementation Act from the NIS2 Directive, if any
  • Sweden’s Cybersecurity Act is substantively aligned with the NIS2 Directive, with really no material deviations. The Swedish choices in the Cybersecurity Act mainly introduce clarifications rather than departures. Examples include: 
    • Terminology refinement: The Swedish Cybersecurity Act generally mirrors NIS2 Article 6 definitions but replaces “entity” with the established Swedish term operator (Sw. verksamhetsutövare), which is explained and justified by the fact that it is a more established concept in Sweden.
    • Scope clarification (entire operator once in scope): In the NIS2 Directive, this assessment is left open to interpretation. In Sweden, once the criteria are met, the Swedish Cybersecurity Act applies to the operator’s organization as a whole to avoid perimeter gaps. The Swedish government reads the NIS2 Directive as supporting this interpretation.
    • Administrative sanctions rather than criminal penalties: Leveraging NIS2’s flexibility, Sweden opts for administrative enforcement rather than criminal penalties, citing effectiveness against legal persons and alignment with enforcement aims. 
Date of entry into force of the Implementation Act
  • The Swedish Cybersecurity Act and related legislative amendments entered into force on 15 January 2026.
  • The repealed Swedish NIS‑law framework continues to apply only for infringements that occurred before that date. 

NIS2 Implementation in the EU

Sweden

(Europe) Firm Advokatfirman Vinge KB

Contributors Lisa Bourghardt

Updated 29 Jan 2026