The cybersecurity landscape is evolving rapidly as firms become more interconnected across borders, sectors and service providers. The EU’s revised Network and Information Systems Directive 2 (NIS 2), and its UK equivalent, the Cybersecurity and Resilience Bill raises the bar for increased cybersecurity oversight for medium to large entities in essential and important sectors, placing a renewed emphasis on supply chain security.

No longer is supply chain risk management a compliance checkbox; it is a board-level, operational and reputational imperative. NIS 2 requires firms to strengthen the weakest and often most overlooked links in their digital ecosystems: the supply chain.

In this blog, we explore the key challenges around building a NIS 2-compliant supply chain security programme, and the critical questions senior leaders should be asking themselves as part of their ongoing compliance journey.

Challenges: The Evolving Landscape Under NIS 2

Is the Complexity of Supply Chain Security Implementation Holding You Back?

• Broader Scope, Increased Responsibility: NIS 2 expands the range of organisations and third parties subject to its requirements. This significantly increases the complexity of supply chain security management, requiring oversight of a larger number of suppliers, including subcontractors and digital service providers. Firms must understand their essential services, the functions enabled by their network and information systems, and the third-party dependencies on which these services rely, or which directly underpin their provision.
• Achieving Comprehensive Visibility of Supply Chain Dependencies: Gaining a complete understanding of supply chain cybersecurity risks requires moving beyond traditional tiering models. Identifying which suppliers regardless of their tier are critical from a cyber disruption and business continuity perspective is crucial, as seemingly insignificant suppliers can have a significant and cascading impact if their services are unavailable or compromised. This necessitates a new approach to supply chain risk management specifically tailored to NIS 2 requirements.
• Strengthening Contractual Obligations: One of the most challenging and underestimated aspects of NIS 2 compliance is the need to upgrade supplier contracts. Security, legal and procurement teams must work in tandem to embed cybersecurity requirements into new and existing contracts, including obligations around incident reporting, audit rights, secure development practices, breach accountability and real-time collaboration during a crisis.
• Heightened Expectations for Incident Response and Communication: Regulators are placing greater emphasis on an organisation’s ability to detect, respond to and communicate supply chain related incidents. Under NIS 2, operators of essential and important entities must notify incidents within tight timeframes – often as little as 24 hours for early warning and 72 hours for full notification. This demands strong incident detection, real-time communication pathways, clearly defined protocols and legal agreements that enforce timely information sharing with suppliers. Many firms will need to re-evaluate and stress-test their supply chain communication pathways and incident management readiness.
• Shifting supplier assurance from tick-box questionnaires towards verifiable evidence: Recent updates to the UK’s NCSC Cyber Assessment Framework (CAF), aligned with NIS 2, raises the bar further by necessitating organisations to obtain evidence from suppliers on recognised secure development lifecycle (SDLC) practices. This emphasises organisations to change their approach toward supplier due diligence and ongoing assurance to obtain evidence-backed validation of software and development standards.

Key Considerations for Building a Strong and Effective Supply Chain Security Programme:

NIS 2 provides organisations with an opportunity to re-evaluate their existing supply chain security practices and modernise their approaches. As firms embark on their journey to enhance supply chain security, below are questions every senior leader or compliance lead should be asking across four core areas as part of their compliance programmes:

Meeting the NIS 2 supply chain security requirements isn’t only about tightening controls. It’s about building adaptive, risk-aware ecosystems that can withstand shocks, and demonstrate resilience under pressure. These questions aren’t meant to be a checklist, but a catalyst for action. The organisations that will thrive under these new obligations will be those that treat supply chain security as a strategic asset and a core pillar of resilience, not just a regulatory obligation.

We have developed a NIS 2 supply chain checklist to help you get started and identify key gaps in your own practices. Please get in touch to hear more.