Supply Chain Security: what the NIS2 Directive requires
What obligations does NIS2 impose on the Supply Chain?
The NIS2 Directive (EU 2022/2555) introduces a systemic vision of cybersecurity, recognizing that an organization’s resilience also depends on the strength of its Supply Chain.
In particular, Article 21 of NIS2 explicitly mentions “Supply Chain security” as a key obligation.
Consequently, companies subject to NIS2 must assess, monitor, and manage cyber risks across their entire value chain.
This means that even SMEs, although not directly classified as “essential” or “important entities,” that provide products or services to NIS2-regulated organizations must comply with the required security standards.
To meet these requirements, companies will need to map suppliers and sub-suppliers with access to critical data or systems, including stringent contractual clauses and targeted technical controls.
The objective is to protect the entire supply chain: from partner selection to incident management involving third parties.
NIS2 Requirements for the Supply Chain
NIS2 requires specific technical and organizational measures for supply chain security.
First and foremost, it is mandatory to establish a Supply Chain security policy, with formal rules governing relationships with all direct suppliers of products and services.
According to ENISA guidelines, this policy must include supplier selection criteria, evaluation of their cybersecurity practices, and analysis of the resilience of the ICT products and services provided.
Additionally, supplier contracts must include detailed clauses with minimum security requirements.
For example, as indicated by regulations and best practices:
Security requirements in contracts: obligation for suppliers to comply with specific ICT standards in delivering services/products.
Training and certifications: contractual commitments regarding supplier personnel expertise and required security certifications.
Incident notification: procedures for the rapid reporting of breaches or attacks detected by the supplier.
Audits and inspections: the right to periodically inspect supplier systems and verify compliance with security clauses.
Vulnerability management: obligation to analyze and patch vulnerabilities identified in supplied software/hardware.
Subcontracting rules: conditions ensuring that sub-suppliers (third parties of the supplier) adhere to the same security standards.
Suppliers must implement basic technical controls within their digital perimeter, such as network monitoring systems, secure backups, disaster recovery solutions, and regular software and firmware updates.
These requirements integrate with the general obligation to proactively manage third-party risk, which includes verifying suppliers’ ability to comply with security SLAs and continuously updating risk assessments in line with the directives of the National Cybersecurity Agency (ACN).
Strategies to Align Supply Chain Security with NIS2
To adapt to NIS2, companies must review supply risk management with a structured approach.
Among the most effective operational best practices are:
- Software Bill of Materials (SBOM): maintaining a detailed list of software components used (and their suppliers) allows organizations to always know what is inside their software and react quickly to new vulnerabilities (e.g., targeted patching).
- Due Diligence and Supplier Control: establishing a rigorous Third-Party Risk Management (TPRM) program.
This involves qualifying each supplier (evaluating certifications, incident history, and security levels), including security clauses in contracts (e.g., data breach notification obligations, minimum policies, audits), and continuously monitoring critical partners with security tools (cybersecurity scorecards, penetration tests on provided services, etc.).
It is also important to classify suppliers by criticality and manage sub-suppliers, ensuring transparency across the extended supply chain.
- Supply Chain Incident Response and Resilience Plans: prepare incident scenarios involving suppliers and define countermeasures.
For example, companies should plan alternative backups or emergency suppliers for critical services, establish communication plans for customers/partners in the event of a supplier incident, and define clear agreements with suppliers regarding escalation procedures and points of contact.
NIS2 requires incident management plans covering detection, response, and recovery, extending this principle across the entire supply chain. Some companies also conduct supply chain attack simulations (war games) together with key suppliers.
- Standards and Certifications: promote the adoption of recognized standards across the supply chain, for example by requiring critical suppliers to be ISO/IEC 27001 certified or aligned with frameworks such as the CIS Controls.
Compliance with advanced certification schemes (European or sector-specific) provides objective assurance of a supplier’s security capabilities. Adhering to these standards reduces the risk of severe vulnerabilities and prepares organizations for future regulatory requirements.
Companies must integrate cybersecurity and procurement within a new defense framework: involving purchasing and legal departments in ICT risk assessment, embedding cybersecurity into every supply agreement, and building a collaborative ecosystem of trust across the Supply Chain.
The Opportunity for SMEs in the Supply Chain
For SMEs active in the Supply Chain, NIS2 is not just a burden but also a growth opportunity.
For small and medium-sized enterprises, compliance with NIS2 “does not entail direct legal obligations,” but it offers significant competitive advantages.
An SME that demonstrates a strong commitment to cybersecurity becomes more attractive to large clients seeking reliable and compliant partners.
Conversely, failure to adapt may result in exclusion from strategic Supply Chains and lost market opportunities.
Investing in Supply Chain security represents a strategic asset that enhances corporate reputation and builds trust throughout the broader economic system.
How SMEs can adapt
SMEs can also address the challenge through concrete steps. Suggested practical measures include:
Initial risk assessment: conduct an assessment to identify vulnerabilities and define the company’s cyber risk profile.
Implementation of security measures: adopt basic solutions such as secure backups, disaster recovery plans, timely updates, and updated internal policies on security and privacy procedures.
Staff training: train employees to recognize cyber threats and follow good cyber hygiene practices (e.g., avoiding phishing and managing passwords securely).
Incident management and notification: establish clear processes to detect incidents and understand how and when to report them, reducing response times. SMEs should understand that collaboration is essential: promptly communicating an incident to customers or partners can limit reputational and legal damage.
Adopting these measures, even gradually, helps SMEs position themselves as reliable suppliers.
During tenders or contract renewals, being able to demonstrate a security roadmap aligned with NIS2 standards can make the difference in entering (or remaining in) digital supply chains.
The benefits of Supply Chain security
Building strong supply chain cybersecurity delivers tangible benefits and competitive advantages, including:
Enhanced operational continuity: reducing the risk of service disruption caused by incidents involving critical suppliers.
Greater reputation and trust: suppliers and customers value partners who guarantee security, strengthening the company’s market credibility.
Competitive advantage: reinforcing supply chain protection reduces downtime and recovery costs after an attack, enabling service continuity even during crises. In an interconnected market, “digital trust” thus becomes a key shared value.
Investing in supply chain security translates into resilience and reputation: every incident avoided thanks to better-prepared suppliers represents a gain for the company.
Therefore, NIS2 compliance should be viewed not only as a regulatory obligation, but as an opportunity to enhance the overall security posture.
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