Since 13 April 2026 the KSC Register has been operational. In-scope organizations should already be confirming their registration route, preparing data for registration, assigning S46 roles, and launching KSC/NIS2 implementation work instead of waiting for the end of the adaptation window.
Submit data for assessment
This is a fast intake path. Share core company and contact data, and POLEGIS will perform an initial KSC qualification and explain which actions should start immediately under the amended KSC Act and NIS2 rollout.
Why act now?
- Since 13 April 2026 the KSC Register has been active, and real implementation windows have started for ex officio entries, self-registration, and S46 readiness.
- The self-registration window for entities not entered ex officio runs from 7 May to 3 October 2026, which leaves less time than most organizations assume for data gathering, qualification, and electronic-signature readiness.
- Requirements cover not only technical controls, but also governance, risk, continuity, and evidence traceability.
- Serious incidents are subject to short reporting windows, which requires ready processes and clear ownership.
- Assessment also covers ICT supply chain exposure and dependencies on external providers.
Key KSC deadlines for 2026-2028
Below is a practical implementation timeline based on the amended KSC Act. These dates are operational milestones that should already shape planning and execution.
The register of key and important entities is live. From this date organizations should confirm whether they will be entered ex officio or need to prepare self-registration.
During this period the register is populated ex officio for legacy key-service operators, trust-service providers, telecom operators, and public entities. Data accuracy and readiness for follow-up become critical.
Entities not entered ex officio must submit their own application through the dedicated KSC Register web application available at https://wykaz-ksc.gov.pl, using electronic filing and an electronic signature.
From this date newly in-scope entities may start using S46 for incident reporting and communication with competent authorities.
By this date entities that already met the statutory criteria when the amended law entered into force should be using S46 and should have implemented their core statutory duties, including ISMS-related controls and operational processes.
This is the deadline for the first security audit for key entities that were not previously legacy key-service operators. Entities already subject to the former audit cycle keep the recurring three-year rhythm.
Administrative fines may start only from this date, although prior warnings, information requests, and remediation expectations can be raised earlier.
What your company gets from this analysis
- An initial decision whether and to what extent the company is in KSC scope.
- A list of organizational and technical gaps to close before controls and audits.
- Implementation priorities to reduce regulatory and operational risk quickly.
- A practical roadmap to full readiness.
Assessment scope (KSC questionnaire)
- Governance and management accountability
- Cybersecurity risk management
- Technical and operational safeguards
- Incidents, reporting, and evidence trail
- Business continuity and service restoration
- ICT supply chain and vendor dependencies
What this means in practice
Organizations that may be in scope under the amended KSC Act and NIS2 should run legal, organizational, and technical preparation in parallel. The minimum launch package includes:
- checking whether the organization meets the criteria of a key or important entity under the statutory annexes and sector-specific qualification rules,
- determining whether the organization will be entered ex officio or must self-register during the 7 May - 3 October 2026 window,
- preparing entity data, contact persons, electronic-signature readiness, and an internal process for register updates,
- planning ISMS rollout, governance, asset inventory, risk analysis, business continuity, and ICT supply-chain controls,
- assigning roles for S46, incident handling, communication with the competent authority, and evidence retention,
- starting implementation now so that by 3 April 2027 the organization is not only registered and present in S46, but is actually operating under the amended regime.
Legal basis and timeline context
KSC contact form
After you submit the form, our team will contact you and present the next analysis steps.