The NIS 2 Directive in 2026: What Changes for Insurance Intermediaries and Their Digital Tools
2026 makes NIS 2 fully operational. Even agencies and brokers that do not fall directly within its scope are involved: through DORA on one side and the demands of corporate clients in critical sectors on the other.
A watershed year for Italian cybersecurity
2026 is the year the NIS 2 Directive stops being a conference-hall talking point and becomes concretely operational in Italy. Following its transposition through Legislative Decree 138/2024, which came into force on 16 October 2024, the first substantive deadlines have already arrived: since 1 January 2026 the obligation to report significant incidents has been active, in April the National Cybersecurity Agency published its model for categorising activities and services, and by October 2026 every entity on the NIS list must have adopted baseline security measures.
For many insurance intermediaries this phase has generated confusion. The recurring question is: does NIS 2 also apply to my agency? The short answer is "not directly, but yes, indirectly." And it is worth explaining why, because the impact on day-to-day operations — and on the software that manages them — is anything but negligible.
What NIS 2 is, in a few lines
NIS 2 is the new European cybersecurity framework. It replaces the first NIS Directive of 2016, radically widening its scope: the number of Italian organisations involved rises from around 400 to more than 10,000, spread across 18 sectors deemed critical to the economy and society — healthcare, energy, transport, public administration, digital infrastructure, but also high-complexity manufacturing, waste management, postal services and water supply.
The entities in scope are classified as "essential" or "important" depending on sector and size. The Italian reference authority is the National Cybersecurity Agency, which manages the registration platform, the operational guidelines and the inspections. To date, more than 30,000 organisations have registered on the ACN platform, and over 5,000 have been classified as essential entities.
The obligations set out are organised across three levels. The first is governance: management bodies are directly responsible for cybersecurity and can no longer delegate the matter entirely to IT. The second concerns technical and organisational measures: risk analysis, incident management, business continuity, supply-chain control, encryption, multi-factor authentication. The third is incident reporting: an early warning within 24 hours of the event, a formal notification within 72 hours, and a final report within one month.
The penalties are aligned with the GDPR: up to 10 million euros or 2% of global turnover for essential entities. But there is an even more relevant aspect for those not directly in scope: NIS 2 explicitly introduces supply-chain accountability. Entities within the scope must assess and monitor the security of their own suppliers — including software providers, consultants and the intermediaries that serve the company.
Why insurance intermediaries are not "outside" this game
Here comes the clarification that is often missing from the content circulating on the topic. Insurance intermediaries are not directly subject to NIS 2. The financial sector — banks, insurers, brokers, agents — is governed by a specific set of rules: DORA (Digital Operational Resilience Act), EU Regulation 2022/2554, fully applicable since 17 January 2025. DORA operates as "lex specialis" relative to NIS 2: where DORA applies, NIS 2 does not apply to the security of information systems.
This does not mean, however, that the issue does not concern intermediaries. They are involved on two fronts, and it is important to distinguish between them.
First front: DORA, which demands things very similar to NIS 2
The DORA regulation imposes on the financial sector the same pillars as NIS 2: ICT risk governance, incident management, monitoring of the technology supply chain, and operational resilience testing. In several respects it is even more stringent, because it goes into the operational detail of the controls. For a structured agency or a broker, cybersecurity is therefore a direct regulatory obligation, not an option.
Second front: the supply-chain effect of NIS 2 clients
If an intermediary distributes policies to clients operating in NIS sectors — a critical manufacturing company, a healthcare facility, a transport operator, a public administration body — those clients, as entities within the scope, must also assess their own service providers as part of their supply-chain risk. This translates into security questionnaires, requests for evidence, specific contractual clauses and periodic audits. A number of structured companies have already begun to ask their partners — agencies and brokers included — for concrete demonstrations of the security level of the systems they use.
The practical result is that the security standard demanded of intermediaries is rising from both sides, regardless of the specific regulatory acronym involved.
What this means, operationally, for management software
Translated into practice: the tools used by agencies must evolve. There is no need to turn the intermediary into an IT company, but certain technical capabilities have now become a prerequisite rather than an option. The points where the game is really won come down to four.
The first is the traceability of access and operations: knowing who did what, when, and from which workstation. This is not a matter of internal surveillance, but of being able to demonstrate, in the event of an inspection or an incident, that structured control is in place. A management system with native audit trails solves the problem without burdening day-to-day operations.
The second is multi-factor authentication and granular role management. A single password is no longer considered sufficient by any security framework. What is needed is a second factor (app, SMS, physical token) and a permissions map that assigns each user only the functions required by their role. It is a modest organisational change, but one with a significant impact on reducing risk.
The third is integrated incident management. When something happens — an anomalous login, an irregularity on a policy, a phishing report from the team — who does what, within what timeframe, and with what documentation? Having the workflow built into the management system, with the timelines required by the regulations already integrated, avoids having to improvise at precisely the critical moments.
The fourth is automated documentation for compliance. For the more structured intermediaries, automatically generating the evidence required by audits, DPOs, insurers and corporate clients is what separates sustainable management from a constant state of emergency built on spreadsheets, emails and manual searches.
The problem we see concretely in the market is that few "off-the-shelf" management systems cover these aspects natively. They are often external add-ons, laborious integrations, parallel tools that live alongside the main management system. All of this increases operating costs and — paradoxically — the overall level of risk too, because it fragments control.
The A126 approach
The advantage of software built around the organisation, rather than the other way round, emerges precisely in scenarios like this. When cybersecurity has to become part of the daily operational flow — and not an additional layer to be managed separately — bespoke management software makes it possible to integrate controls exactly where they are needed, without weighing down those who do the work.
For A126 this translates into a clear working method. We start from an analysis of the agency's real operational flow in order to understand where traceability is needed, where more robust authentication should be introduced, and where the incident workflow should be integrated. We intervene in a targeted way on the management systems already in use, because a full migration is not always the most sustainable answer. We produce the technical documentation that the intermediary needs to be able to present in response to the compliance questionnaires of corporate clients, mandating insurers and — where applicable — the competent authorities.
A126 does not sell certifications or pre-packaged "compliance bundles." What it does is design tools that enable the intermediary to respond to the new regulatory demands without having to overturn the way they work.
Conclusion
2026 is consolidating a truth the sector should have anticipated: cybersecurity is no longer a technical matter delegated to IT, but an operational, contractual and reputational asset. For insurance intermediaries — directly through DORA, indirectly through the NIS 2 obligations of their corporate clients — this means that the quality of the digital tools they use increasingly determines the very sustainability of their business.
Investing in software that natively integrates security requirements is not merely a compliance exercise: it is the way to reduce management complexity, lighten the daily workload and stand out from competitors still anchored to generalist tools that do not speak to the market's new demands.
If you want to understand how to adapt your digital tools to the new regulatory context without overturning the way your agency is organised, get in touch for an analysis of your current operational flow.
A126 Corporate Advisors — bespoke management software for insurance intermediaries ready for the new security standard.