What the act requires
Article 21 of the Dutch Cyberbeveiligingswet (Cbw) is the Dutch elaboration of NIS2 Article 21. The essential or important entity takes technical, operational and organisational measures for the systems it uses for its work or its services [1]. So it is not only about IT security in the narrow sense, but also about processes, people and the physical environment of the systems [3].
Appropriate and proportionate: what does that mean for an SME?
The act does not prescribe a fixed list of measures per company size. The measures must fit your risks. You take account of the state of the art and the costs, and, for proportionality, of your exposure to risks, your size and the likelihood and severity of incidents [2]. A medium-sized transport company therefore does not have to do the same as an airport, but must be able to substantiate its choices.
The ten topics
The measures cover at least [3]:
- policy for risk analysis and security of information systems
- incident handling
- business continuity, backups, recovery and crisis management
- security of the supply chain
- security in acquiring, developing and maintaining, including vulnerabilities
- assessing whether the measures work
- cyber hygiene and training
- cryptography and encryption
- personnel, access policy and asset management
- where appropriate, multi-factor authentication and secure communication
The Cyberbeveiligingsbesluit (Cbb) elaborates each topic in Articles 6 to 18. The ministerial regulation for your sector supplements this, among others with patch management and vulnerability scans [7], network segmentation [8] and policy for privileged accounts [9]; for transport and chemicals that is the Cyberbeveiligingsregeling IenW [6], for, among others, postal and courier services and food an equivalent regulation [10]. Every topic has its own question page in the overview of this knowledge base.
Since when and who signs
The Cbw and the Cbb have applied since 15 August 2026 [4]. There is no separate transitional period for the duty of care. The measures need the approval of the management body [5].