i cant make a mod
when i use generatemod it fails and says it needs a steamapi dll. ??!

created new mod
edited ndf file
generate mod -- not working

Almost the same issue here, except I used the CreateNewMod.bat as instructed in the modding manual. Apparently, the modding tools only work for steam users, please do something -.-

when i said created new mod that means i used the CreateNewMod.bat file.
do you mean that it fails for you on that step?

I opened the command console in the folder and executed the .bat with my mod name behind it. This did not work, because the .bat was looking for a folder that didn't exist. Eugen have updated the mod tools download to include said folder and it works for me now.
However, after you made all the changes you want, you need to "generate" the mod. This does not work for GOG, because the mod generation .exe wants steam_api64.dll, which is a file usually included in game directories for games that use steam. The issue is fixed if you just download the file from the internet (there's .dll databases, you will immediately find it using google) and put it in the game directory.

I ran into this same issue myself. The fix is to use the DLL I uploaded to the SD2 ModDB page, which can be found here: https://www.moddb.com/games/steel-division-2/downloads/steam-dll-for-modgen-exe#downloadsform

Simply extract the file into your SD2 primary folder (where the ModGen.exe is) and you're good to go.