NIS2 transposition — status update; no Court of Justice referral announced this week

The European Commission sent reasoned opinions to 19 member states in May 2025 (per the EC NIS transposition page, last updated July 2025) with a two-month response window; non-compliant states face Court of Justice referral. The May-2025 reasoned opinions are now one year old without public Court of Justice referral announcements, indicating most have either completed transposition or are in active dialogue with the Commission. Polish NIS2 transposition (in force 3 April 2026, W19 item) is among the most recent completions. No Court of Justice referral was announced this week. The W19 ABW NIS2 essential-entity extension proposal has not gained additional public momentum this run (EC NIS transposition page).