ZKS / NIS2

Is your organisation obliged under the Cybersecurity Act? Check in 30 seconds.

Cybersecurity Act (ZKS, State Gazette No. 55 of 16 June 2026) – the transposition of NIS2. See who is in scope, what the sanctions are and who carries out inspections.

up to EUR 10,000,000 – essentialup to EUR 7,000,000 – important
Section I

Essential entities under Art. 4a ZKS

Sanctions of up to EUR 10,000,000 or 2% of annual turnover. Automatically subject to scheduled inspections by the MIDT.

CategoryExamplesLegal basis
MunicipalitiesAll 265 municipalities in BulgariaArt. 4a(4) ZKS
EnergyCEZ, EVN, ENVIAArt. 4a(2) ZKS
Transport – railBDZ, NRICArt. 4a(3) ZKS
Transport – aviationAirports, airlinesArt. 4a(3) ZKS
Transport – maritimePublic transport ports, passenger ferriesArt. 4a(3) ZKS
Water utilitiesWater supply and sewerage operatorsArt. 4a(5) ZKS
HealthcareHospitals, National Health Insurance FundArt. 4a(6) ZKS
Digital infrastructureDNS, cloud providers, data centresArt. 4a(8) ZKS
Section II

Important entities under Art. 4a(2)

Sanctions of up to EUR 7,000,000 or 1.4% of annual turnover.

CategoryExamplesLegal basis
Postal servicesCourier companiesArt. 4a(2) ZKS
Waste managementMunicipal and private operatorsArt. 4a(2) ZKS
Marinas>50 employees or >EUR 10 million turnoverArt. 4a(2) ZKS
Food industryProducers and distributorsArt. 4a(2) ZKS
Digital providersOnline platforms, search enginesArt. 4a(2) ZKS

⚓ Ports and marinas – are you in scope?

Public transport ports (passenger and cargo) are essential entities under Art. 4a(3) ZKS – automatically, with no thresholds.

Marinas and yacht harbours are important entities if they have more than 50 staff, an annual turnover above EUR 10 million, or are expressly designated by the MIDT (Art. 4a(1)).

If in doubt, run a free AI scan of your infrastructure or contact us.

Supervision

Who carries out inspections?

Four authorities, four different sets of powers.

MIDT

Supervisory authority under the ZKS. Scheduled and unscheduled inspections of all entities. Can impose sanctions and publish violations.

CPDP

Oversees GDPR violations – personal data, cookie policies, DPO obligations.

SANS

Critical infrastructure and national security. Coordination of high-priority incidents.

SERIKS (CERT-BG)

Receives incident reports: 24 h early warning → 72 h notification → final report within 1 month.

Are you in scope of ZKS/NIS2? Essential and important entities