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Germany KRITIS-DachG in force — public administration first time in critical-infrastructure scope; registration deadline 17 July 2026
From CTI Weekly Summary — 2026-W19 (May 04 – May 10, 2026) · published 2026-05-11
Germany's KRITIS-DachG (Act to Strengthen Physical Resilience of Critical Installations), implementing EU CER Directive 2022/2557, entered into force in late March 2026 following Bundesrat approval on 6 March 2026 (Luther Lawfirm, 2026-04-10 · Morrison Foerster European Digital Compliance, 2026-05-01). The Act establishes the first cross-sectoral physical and organisational resilience framework covering energy, transport, healthcare, water, finance, and — for the first time — municipal waste disposal and aspects of public administration. Registration deadline 17 July 2026 (or within three months of later qualification). Post-registration obligations cascade over nine–ten months: risk assessments every four years covering natural / technical / sabotage / cross-border scenarios, resilience plans, and 24-hour incident reporting to a joint BSI/BBK reporting point. Fines for non-compliance: up to €100,000 for registration/cooperation failures; up to €1,000,000 for concealing non-registration status; up to €200,000 for missing resilience evidence or plan. Key ambiguity: the BMI implementing ordinance defining which specific services and installations qualify as "critical" is not yet published, leaving scope uncertain for borderline operators. What defenders need to do differently: German public-sector and critical-sector organisations need to self-assess KRITIS-DachG applicability before 17 July; ISG-style 24-hour reporting obligation now applies to physical as well as cyber incidents; Swiss entities with German subsidiaries operating in scope sectors are directly affected. Cross-references NIS2 and BSI Act obligations — the three frameworks overlap operationally and require coordinated incident-response runbook design.