Do group companies count toward the NIS2 size?

Yes, by default. NIS2 uses the EU definition of SMEs, which adds the figures of linked and partner companies. Austria, Czechia, Estonia, Germany, Poland and Sweden make an exception for a company whose IT is independent of the group. In Denmark and Italy, the authority decides.

Group 320 staff, EUR 70m Your company 35 staff, EUR 5m Runs its own IT Default: the group figures count Own figures count, by law, in AT CZ EE DE PL SE

The national exceptions

In the last column: a cloud software company with 35 staff and EUR 5m turnover. Its group has 320 staff and EUR 70m turnover. The company runs its own IT, separate from the group. Checked 2026-11-03.

CountryRuleExample result
Austria § 25 NISG 2026 Partner and linked company figures are not added when your network and information systems are organisationally, technically and operationally independent. Out of scope
Own figures
Czechia § 7(c) Cybersecurity Act Partner and linked enterprise figures do not count when their technical assets are fully separate from the assets that the entity uses for the regulated service. Out of scope
Own figures
Denmark Explanatory notes to § 4-5 NIS 2 Act The ministry says an entity can fall outside the Act when its partner and linked companies would lift it over the medium-size ceilings but the entity is independent. The test uses the independence of its systems and services. The authority decides. Check with the authority
The authority decides
Estonia § 3(7) KüTS Partner and linked company figures are not added when your systems for the services are independent of the partner or linked company. Out of scope
Own figures
Germany § 28(4) BSIG Partner and linked company figures are not added when your IT systems and processes are independent of the group. Out of scope
Own figures
Italy Art. 3(4) D.Lgs. 138/2024 ACN can leave out partner and linked company figures. It looks at how independent your IT and your services are. The authority decides. Also Art. 3(10) D.Lgs. 138/2024: A group company is in scope at any size when it decides on the security measures of an NIS entity of the group, runs systems that entity depends on, runs its security operations, or provides it ICT or security services. Check with the authority
The authority decides
Poland Art. 5(6)-(7) KSC Act Partner and linked company figures do not count when your information system is independent of the group's systems, or when you do not provide services jointly with the group. Out of scope
Own figures
Sweden MCFFS 2026:1, 3 kap. 1 § A partner or linked enterprise that meets the size test only through its group is out of scope. This needs an independent production environment and a high degree of independence from the group. Out of scope
Own figures
Belgium No exception found in the national law. Group figures count. Essential entity
Group figures
Bulgaria No exception found in the national law. Group figures count. Essential entity
Group figures
Croatia No exception found in the national law. Group figures count. Essential entity
Group figures
Cyprus No exception found in the national law. Group figures count. Essential entity
Group figures
Finland No exception found in the national law. Group figures count. Essential entity
Group figures
Greece No exception found in the national law. Group figures count. Essential entity
Group figures
Hungary No exception found in the national law. Group figures count. Essential entity
Group figures
Latvia No exception found in the national law. Group figures count. Essential entity
Group figures
Lithuania No exception found in the national law. Group figures count. Essential entity
Group figures
Luxembourg No exception found in the national law. Group figures count. Essential entity
Group figures
Malta No exception found in the national law. Group figures count. Essential entity
Group figures
Netherlands No exception found in the national law. Group figures count. Essential entity
Group figures
Portugal No exception found in the national law. Group figures count. Essential entity
Group figures
Romania No exception found in the national law. Group figures count. Essential entity
Group figures
Slovakia No exception found in the national law. Group figures count. Essential entity
Group figures
Slovenia No exception found in the national law. Group figures count. Essential entity
Group figures

The EU SME rules in short

Autonomous
No other company holds 25% or more of you, and you hold less than 25% of any other. Use your own figures.
Partner
A holding of 25% or more, without control. Add the partner's staff and financial figures in proportion to the holding.
Linked
One company controls the other, for example with a majority of the voting rights. Add 100% of the linked company's figures.

A small subsidiary of a large group is therefore usually large for NIS2.