On Dec. 5, 2025, the German act implementing the EU NIS 2 Directive was published. The centerpiece of the German implementation is the newly revised Act on the Federal Office for Information Security (Gesetz über das Bundesamt für Sicherheit in der Informationstechnik – BSI Act, BSIG), which redefines security-related requirements for companies and public bodies across Germany and fundamentally modernizes the regulatory framework for IT security. The number of regulated entities may increase from approximately 4,500 to around 29,000. For these entities, the new requirements will generally apply from the day after publication in the Federal Law Gazette; there is no general transitional period. In practice, this means that cybersecurity may no longer be viewed primarily as a technical task for the IT department, but becomes an immediate, liability-exposed leadership responsibility of a company’s management body.

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Photo of Christoph Enaux Christoph Enaux

Christoph Enaux chairs the German Telecommunications Sector Group as well as the German Regulatory and Competition Practice Group.

Christoph advises on commercial and regulatory aspects of new business models in the TMT sector. His work covers the rollout and operation of both terrestrial…

Christoph Enaux chairs the German Telecommunications Sector Group as well as the German Regulatory and Competition Practice Group.

Christoph advises on commercial and regulatory aspects of new business models in the TMT sector. His work covers the rollout and operation of both terrestrial and satellite infrastructures and related regulatory matters.

In addition, he supports clients from various sectors on merger control, antitrust proceedings, foreign investment and export control law. His wide-ranging experience covers M&A and commercial contracts as well as administrative proceedings and regulatory and commercial litigation. As the head of the Digital Real Estate Focus Group, he also has a particular focus on the legal issues relating to the use of digital technologies in the real estate sector.

Prior to joining the firm, Christoph was a partner at Olswang in Berlin and worked in the Technology, Media and Telecommunications Group at Linklaters for five years.

Photo of Dr. Philip Radlanski Dr. Philip Radlanski

Philip Radlanski is a Local Partner in the IP & Technology Practice Group. He advises clients ranging from early-stage start-ups to large corporations on matters relating to artificial intelligence (AI), data privacy, and cybersecurity. His work focuses on complex and innovative data-heavy AI

Philip Radlanski is a Local Partner in the IP & Technology Practice Group. He advises clients ranging from early-stage start-ups to large corporations on matters relating to artificial intelligence (AI), data privacy, and cybersecurity. His work focuses on complex and innovative data-heavy AI projects, often with cross-border aspects. He also assists with addressing cybersecurity issues, including data breach incident management and response. He gained strong recognition throughout Europe for his representation in the first German trial against a GDPR fine, in which he was able to achieve a reduction of the multimillion-euro fine by more than 90 percent.

As a driving force behind the firm’s AI practice in Germany, he guides companies through the complex and rapidly evolving regulatory landscape surrounding artificial intelligence — from the EU AI Act and sector-specific requirements to the intersection with data protection and intellectual property law.

With a strong understanding of the technical underpinnings of AI and a practical, business-oriented mindset, Philip is regularly sought after by multinational companies, technology providers, and start-ups developing or deploying AI systems. He advises on all aspects of AI governance — from risk assessments and compliance strategies to drafting internal policies and representing clients before regulatory bodies. Philip also works closely with in-house legal, compliance, and technical teams to promote effective AI oversight, foster privacy-by-design, and drive responsible, future-proof adoption of transformative technologies.

Philip is known for his pragmatic approach, which he was able to further refine through several months of secondments to the legal departments of a leading German internet service provider and an internationally operating online marketplace for food delivery. A further one-year secondment to the Global Privacy & Data Security Group of an international law firm in New York shaped Philip’s understanding of the U.S. market and U.S. clients.

Prior to practicing as an attorney, Philip worked as a research assistant at the University of Regensburg, Germany, and as a visiting tutor at King’s College London, UK. He also worked with the German Federal Film Board, the cybercrime division of the Berlin District Attorney’s Office, and for different international law firms in Berlin, New York, and Sydney.

He is a member of the German Association for the Protection of Intellectual Property and Copyright (GRUR), the International Technology Law Association (ITechLaw), and the Bauhaus Archive.