Feedback on Inception Impact Assessment NIS Directive
Henceforth, ▪
… in the context of school education, digital literacy should be taught from the first grade onwards. In addition to the experienced handling of common devices, operating systems and applications, this includes in particular the basics of IT security and the responsible and secure handling of data, also with regard to social media. Thus, even primary school pupils should experience an IT education that teaches them data and system security.
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Digital content, e.g. concerning the safe usage of digital technologies (hardware and software), must be more firmly anchored in vocational education and training, universities and lifelong learning. In consultation with the economic and social partners, the corresponding content has already been developed and introduced into the federal government's initial and continuing training regulations.
Germany’s go-alone: Towards an IT-Security Law 2.0 Germany’s current grand coalition agreed in their coalition agreement in 2018 on revising the German IT-Security Law. On May 7, 2020, the draft for the IT-Security Law 2.0 was leaked. Especially considering the EU Commission’s intention to review the EU’s Network and Information Security Directive by the end of 2020, German industry takes a rather critical view of the German go-alone. While unambiguous and supplier-neutral security requirements for 5G components are urgently needed, a national goalone – as foreseen in the leaked draft of the IT-Security Law 2.0 – on new OES sectors, definitions of critical components, the introduction of the category “companies of special public interest” as well as a catalogue of fines should be avoided. According to German industry’ perspective, the following three aspects to be introduced by the German IT-Security Law should be considered when conducting the NIS review: ▪
New sectors of essential services /critical infrastructures: The German government is planning to introduce the new critical infrastructure sector “waste disposal”. The introduction of the new sector “waste disposal” does make sense, especially in view of the latest developments in the course of the corona pandemic. However, German industry would appreciate if an extension of the scope of the OES / critical infrastructure was done at European level. When including “waste disposal” as an essential services sector, it would
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