NIS2 and Supply Chain: security requirements

Table of contents

• The NIS2 Directive: a step beyond NIS1
• What NIS2 requires regarding the supply chain
• Why the supply chain is so vulnerable
• Security measures required by NIS2
• The role of Member States
• Challenges for businesses
• Opportunities for cyber security

In recent years, cyber security has become a central issue for governments, businesses, and citizens. The growing interconnection of systems, combined with the dependence on digital and ICT service providers, has made the supply chain one of the most vulnerable links to cyber threats. It is in this context that the NIS2 Directive, approved by the European Union, was introduced, expanding and strengthening the requirements already laid out in the first NIS Directive.

But what does NIS2 require regarding the supply chain? How does the regulation compel companies to better manage their relationships with suppliers and strengthen supply chain security? And above all, what practical measures must be taken to reduce the risk of cyberattacks that infiltrate through third parties?

In this article, we will answer these questions by analyzing the key points of NIS2 and supply chain, highlighting obligations, opportunities, and challenges for European organizations.

The NIS2 Directive: a step beyond NIS1

The NIS2 Directive is the natural evolution of the first Directive on network and information systems security (NIS1), adopted in 2016. Its main goal is to harmonize security requirements across Member States and to strengthen incident response capabilities.

One of the crucial points of NIS2 is its focus on the supply chain. In fact, many recent attacks have shown that cybercriminals prefer to target smaller, often less protected suppliers, and then penetrate the systems of final customers. A striking example was the SolarWinds attack, which highlighted the vulnerability of IT systems through software providers.

As a result, the directive requires organizations to adopt specific measures concerning supply chain security, imposing much stricter controls on third parties.

What NIS2 requires regarding the supply chain

Now let’s get to the heart of the matter: what does NIS2 require regarding the supply chain?

The regulation establishes that companies must ensure not only their internal protection but also that of their service providers and partners. In practice, security does not stop at the boundaries of the organization but extends throughout the entire supply chain.

The main requirements are:

• Supply chain risk assessment
  Companies must conduct risk management that includes suppliers, subcontractors, and third parties. It is no longer sufficient to assess only internal risks.
• Contractual clauses on security
  Contracts with partners must contain contractual clauses regarding supply chain security. These must specify minimum security measures, periodic audits, and incident response procedures.
• Security requirements for ICT services
  Particular attention is given to ICT services, which often represent a critical point in the chain. Companies must ensure that suppliers meet adequate standards for protecting information systems.
• Continuous supply chain monitoring
  Relying only on an initial audit is not enough. The directive requires ongoing monitoring of partners’ security practices.
• Incident reporting obligations
  In the event of incidents involving the supply chain, the company must notify the competent authorities within set timeframes.

These requirements, while increasing management complexity, provide a clear framework for strengthening supply chain security and preventing devastating attacks.

Why the supply chain is so vulnerable

To better understand the significance of the directive, it is useful to understand why the supply chain is such a prime target.

The modern supply chain is made up of a multitude of players: software suppliers, maintenance companies, cloud providers, IT consultants, hardware manufacturers. Each of these links uses and accesses critical information systems.

Hackers know that directly attacking a large, well-protected company is difficult. It is much easier to infiltrate through a less prepared third party. This method allows them to bypass stronger defenses and gain privileged access to the target’s data or systems.

This is why NIS2 and supply chain are inseparable: without careful supplier management, any cyber security strategy is bound to fail.

Security measures required by NIS2

Let’s now look in more detail at the security measures companies must adopt to comply with NIS2 in terms of supply chain security.

• Regular audits
  Suppliers must undergo periodic, even independent, audits to ensure they meet security requirements.
• Segmentation of information systems
  Suppliers’ access must be limited strictly to what is necessary.
• Standardized security practices
  Adopting common protocols such as encryption, multi-factor authentication, and patch management.
• Ongoing supplier assessment
  Monitoring not only the financial reliability but also the cyber resilience of partners.
• Internal training
  Employees must be aware of threats arising from the supply chain.

All these practices fall under the concept of supply chain security and represent the core of the EU requirements.

The role of Member States

Another fundamental aspect concerns the role of Member States. NIS2 does not leave full discretion to companies: each State must supervise and enforce effective controls.

Member States must:

• provide common guidelines on supply chain security requirements;
• carry out inspections and random audits;
• impose penalties for non-compliance;
• promote cooperation between national authorities and industry operators.

This approach aims to create a uniform level of supply chain security across the EU, avoiding imbalances that could be exploited by cybercriminals.

Challenges for businesses

Complying with NIS2 requirements regarding the supply chain is not without challenges.

Example
Many SMEs lack the resources to conduct in-depth checks on suppliers. In addition, negotiating detailed contractual clauses can be complex, especially when dealing with partners outside the EU.

There is also the risk that excessive bureaucracy could slow down procurement processes. However, the directive emphasizes that the benefits outweigh the costs: preventing a cyberattack along the supply chain means avoiding enormous economic and reputational damage.

Opportunities for cyber security

Despite the difficulties, NIS2 also represents an opportunity. Strengthening supply chain security is not just a legal obligation but also a competitive advantage.

Companies that can demonstrate a robust supply chain security inspire trust in customers and partners, increasing business opportunities. Moreover, adopting advanced security practices reduces incidents, service interruptions, and emergency-related costs.

In other words, investing in supply chain risk management means not only complying with the law but also building a more resilient future.

Conclusion

The initial question – what does NIS2 require regarding the supply chain – thus has a clear answer: the directive obliges companies to extend their cyber security strategy throughout the entire supply chain, requiring risk assessments, continuous monitoring, specific contractual clauses, and close cooperation with Member States.

The NIS2 and supply chain pairing marks a cultural shift: it is no longer enough to protect one’s own perimeter. Every link in the supply chain must be secure. Only then will it be possible to reduce the risk of devastating cyberattacks and strengthen the overall resilience of the European system.

Questions and answers

1. What does NIS2 require regarding the supply chain?
   It requires risk assessments, specific contractual clauses, continuous monitoring, and incident reporting obligations.
2. What is the difference between NIS1 and NIS2 regarding the supply chain?
   NIS1 did not focus on the supply chain, while NIS2 expands requirements to include suppliers and third parties.
3. Why is the supply chain so vulnerable to cyberattacks?
   Because it involves numerous suppliers and partners with often heterogeneous security levels.
4. What are the main security measures required?
   Regular audits, system segmentation, standardized practices, monitoring, and training.
5. Do SMEs have to meet the same requirements as large companies?
   Yes, although in some cases proportionate approaches may apply.
6. What is the role of Member States in NIS2?
   They must supervise, conduct inspections, and impose penalties for non-compliance.
7. What are the benefits of a secure supply chain?
   Increased customer trust, fewer incidents, and competitive advantage.
8. How are contractual clauses on security integrated?
   They must be included in contracts with suppliers and partners, with clear and verifiable requirements.
9. Which sectors are most affected?
   Energy, transport, healthcare, digital infrastructure, and all critical ICT services.
10. What are the consequences of non-compliance?
    Financial penalties, loss of contracts, and severe reputational damage.