The era of extended "peace dividends" in Europe has all but ended. Germany, once a frontline state during the Cold War, has initiated a plan to reinvent its defense posture for the 21st century. At the heart of this shift is the Operational Plan for Germany (OPLAN) a 1,200-page strategic blueprint that is designed to transform the Federal Republic into NATO’s logistical "turntable."

For operators of critical infrastructure (KRITIS), this isn't just a high-level military document. Instead, it shares a clear and unambiguous mandate for a radical overhaul of cybersecurity and physical resilience. The document and the thought process behind it acknowledge the growing threats to KRITIS from all types of actors and a need to have a well etched strategy to deal with these threats.

In today’s blog post, the last one for the year 2025, we take a look at the cyber dimensions of OPLAN DEU or OPLAN for short. As always, before we move forward, don’t forget to check out our previous blog post on Unpacking the ransomware attack on Oltenia Energy Complex here.

The strategic pivot: Germany as the NATO hub

The Operational Plan for Germany (OPLAN) in many ways marks a fundamental shift. In a potential conflict with a state that lies in close proximity, Germany would not be the primary battlefield but the central logistics engine. The plan outlines how up to 800,000 NATO troops and 200,000 vehicles would transit through German territory to the Eastern Flank. This outlines a clear role for Germany (and its responsibilities) in that conflict.

In addition to the 1200 page document, a 24-page document called “light version” of the plan has also been prepared. This compressed document is designed to help coordinate civilian and military stakeholders, during a conflict and defining Germany’s function as a central logistics hub for allies.

However, there is a catch. If the battle intensifies or the adversary launches cyberattacks on German cyberspace, there could be major consequences (and the adversary has already understood and is well aware of the disruptive fallout of hybrid warfare). This makes German energy grids, rail networks, and communication lines the most lucrative targets for "pre-war" sabotage. While in the pre-cyber era, spies used to be deployed for physically sabotaging critical infrastructure, today, even before the first shot is fired, the enemy could already be in our cyberspace with a disruptive payload waiting to be executed.  

The OPLAN explicitly identifies that the first phase of any conflict will not be kinetic (tanks and missiles) but hybrid. This is pointing to a blend of cyberattacks, disinformation, and targeted sabotage of civilian infrastructure.

What KRITIS operators should watch out for

The "gray zone" of hybrid warfare is already active. As per German military strategists, operators need to be hyper-vigilant regarding three specific threat vectors:

• "Blind Spot" sabotage: Modern defense relies on the seamless movement of heavy armor. Sabotage of unmonitored rail switches, signaling systems, or the digital twins of autobahn networks could paralyze troop movements well before they even reach the EU frontier in Poland or the Baltics.

• Dual-use disruptions: Military logistics are heavily reliant on civilian providers. An attack on a "civilian" energy provider in a port city like Bremerhaven or Hamburg is, in the eyes of OPLAN DEU, an attack on NATO’s ability to deploy. Rising attacks on airlines, coal complexes and oil and gas facilities indicates that such attacks are already ongoing which means the cyber frontier has already been activated and the adversary is leveraging the extended threat surface prevailing in the infrastructure belonging to civilian providers.

• Supply chain "Sleeper" Attacks: Planners are increasingly concerned about compromised hardware or software within the 80% of critical infrastructure owned by the private sector. These could be activated as "kill switches" during the mobilization phase. Supply chain poisoning will be a major challenge in 2026.

Analysis: The "whole-of-society" mandate

The most insightful aspect of the new defense plan is the blurring of the boundary between civilian and military responsibility. Under OPLAN DEU, defense is no longer "outsourced" to the Bundeswehr.

The plan assumes that in a crisis, the military will provide command and protection, but the private sector will be the providing the actual (support) muscle that includes logistics, construction, and medical services. This requires a level of data sharing between the BSI (Federal Office for Information Security) and private operators that has historically been hampered by German privacy laws and bureaucracy.

Roadmap: Aligning with the cyberdefense plan

For operators looking to align with this new reality and the obligations that stem from it, we present herewith a roadmap that is built on three pillars: Compliance, Connectivity, and Capability.

Step 1: legal compliance (NIS-2 & KRITIS-DachG)

The legal framework is catching up to the military reality. By the end of 2025, operators must ensure full compliance with:

• NIS-2 Directive: Mandatory implementation of state-of-the-art attack detection systems.

• KRITIS-Dachgesetz: A new "umbrella law" that mandates physical security measures alongside digital ones.

Step 2: resource assessment

Companies must identify "Essential Personnel" and reservists within their ranks. The OPLAN suggests that businesses need to know exactly how many of their staff are part of the military reserve to avoid a sudden brain drain during mobilization.

Step 3: integrating "attack detection"

Peacetime cybersecurity is often about data protection; wartime cybersecurity is about ensuring availability. Operators must shift their focus toward systems that can detect anomalies in real-time, ensuring that vital services remain operational even while under a sustained Distributed Denial of Service (DDoS) or wiper malware attack.

Step 4: sector-specific drills

Join the UP KRITIS (the public-private partnership for infra-protection). Participation in cross-sectoral exercises like "Red Storm Bravo" is no longer optional for major players. It is the only way to test the "turntable" before it is needed for real during a crisis.

As of December 6, 2025, the German NIS-2 Implementation Act is officially in force, and the KRITIS-Dachgesetz (Umbrella Act) is moving into its final implementation phase. For critical infrastructure operators, compliance is no longer a future project—it is a current legal requirement with significant personal liability for management.

This broad checklist aligns your operations with both the regulatory mandates and the strategic needs of the Operational Plan for Germany (OPLAN).

Pillar 1: Governance and personal Liability

Under the new Section 38 of the BSIG (BSI Act), cybersecurity is now a non-delegable board responsibility.

• [ ] Executive Training: Ensure all managing directors and board members have completed mandatory cybersecurity training (required every 3 years).

• [ ] Implementation Oversight: Formalize a process where the board "approves and monitors" all cyber-risk measures. Evidence of active supervision is required to mitigate personal liability.

• [ ] Liability Review: Update D&O (Directors and Officers) insurance to reflect the specific personal liability risks introduced by NIS-2 for breaches of duty.

• [ ] Budget Allocation: Verify that cybersecurity and physical resilience budgets are "proportionate" to the risk—underfunding is now a compliance red flag.

Pillar 2: Cybersecurity Risk Management (NIS-2)

These measures focus on the digital "turntable" functions identified in the national defense plan.

• [ ] Asset & Supply Chain Inventory: Document all "Critical Components." You must now manage risks not just for your company, but for your entire tier-1 supplier network.

• [ ] Multi-Factor Authentication (MFA): Implement MFA or continuous authentication across all administrative and remote access points.

• [ ] Cryptography Policy: Deploy state-of-the-art encryption for data at rest and in transit, specifically for communication regarding logistics and energy distribution.

• [ ] Attack Detection Systems: Ensure active "intrusion detection" is operational 24/7. Peace-time logs are insufficient; you need real-time anomaly detection.

• [ ] Business Continuity (BCM): Test your "Offline Mode." Can your infrastructure function if the public internet or specific cloud service providers are cut off?

Pillar 3: Physical and operational resilience (KRITIS-DachG)

While NIS-2 handles the "bits," the KRITIS-Dachgesetz handles the "bricks."

• [ ] Facility Registration: Register all "Critical Facilities" with the BBK (Federal Office of Civil Protection) within 3 months of falling under the scope.

• [ ] Physical Risk Analysis: Conduct a comprehensive assessment of "All-Hazards," including climate risks (floods/storms) and man-made threats (sabotage/terrorism).

• [ ] Access Control: Audit physical perimeters. For OPLAN DEU logistics hubs, this includes drone defense and hardened entry points for sensitive signaling or switchgear.

• [ ] Personnel Screening: Implement enhanced background checks for staff with access to critical control systems (OT).

Pillar 4: Reporting and compliance timelines

Germany has adopted a strict, multi-stage reporting regime.

 Deterrence through resilience

The ultimate goal of OPLAN DEU is deterrence. By hardening critical infrastructure, Germany signals to adversaries that a hybrid attack will not yield the desired paralysis or disruption. For the KRITIS operator, cybersecurity is no longer just a cost, instead it is a core component of national sovereignty.

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