Supply chains have become a critical element in the cybersecurity strategies of modern organizations. The statistics leave no room for doubt - as many as 63% of insurers identify ransomware attacks carried out through the supply chain as the greatest cyber threat . In response to this growing risk, the European Union has tightened regulations by introducing the NIS2 Directive, which comes into force in October 2024, fundamentally transforming the approach to security of networks, information systems, and the entire ecosystem of suppliers.
The new regulations will cover approximately 160,000 organizations operating within the EU, radically expanding the scope from the original 7 economic sectors to 18 industries considered strategic for the functioning of the European economy and society . For many businesses, this necessitates a complete rethinking of their existing security strategies and relationships with external partners.
Key aspects of NIS2 in the context of supply chain security
Expanded scope and personal accountability of management
The NIS2 Directive introduces an unprecedented change - personal accountability of the management team for the state of cybersecurity in the organization. Board members may face financial penalties and even receive a temporary ban on performing managerial functions in cases of serious negligence . This represents a fundamental paradigm shift compared to previous regulations.
Despite clear legal requirements, studies reveal a concerning reality - as many as 34% of organizations admit that their boards are not engaged in the process of implementing NIS2 requirements . Furthermore, 73% of companies have not allocated a dedicated budget for adapting to the new regulations , which raises serious questions about the feasibility of achieving timely compliance.
Article 21 as the foundation of supply chain security
The central element of the regulations concerning supply chain protection is Article 21, which mandates the implementation of "appropriate and proportionate" technical and organizational measures. These regulations encompass a wide range of requirements:
Companies must conduct comprehensive risk assessments related to supplier relationships. They must also implement detailed contractual safeguards that clearly define security expectations. Additionally, the new regulations require regular security audits of key partners and precise mapping of all dependencies in the supply chain.
A thorough understanding of these requirements is essential for properly planning the adaptation process and avoiding potential sanctions.
Division into "essential" and "important" entities
NIS2 introduces a two-tier system for classifying organizations, differentiating the regulatory approach:
Organizations classified as essential entities are subject to intensive, proactive regulatory supervision, must meet more stringent security requirements, and undergo more frequent inspections by supervisory authorities.
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Conversely, important entities are covered by a less stringent, reactive supervision regime. However, this does not mean they can disregard the new requirements.
This classification directly affects how organizations must approach securing their supply chains, with substantially more rigorous requirements for entities classified as essential.
Practical aspects of implementing NIS2 compliance in the supply chain
Supplier categorization and due diligence process
According to the new regulations, organizations must develop and implement a precise system for classifying suppliers based on the criticality of services they provide. An example model of such categorization might look as follows:
For high-risk suppliers, such as companies providing key ICT systems or operational technologies (OT), comprehensive security audits, regular vulnerability assessments, and continuous monitoring are necessary.
Medium-risk suppliers require periodic assessments of security levels, verification of compliance with contractual requirements, and regular reviews of security policies.
For low-risk suppliers, basic assessment questionnaires and declarations of compliance with minimum security standards may suffice.
This risk-based approach allows more efficient allocation of limited financial and personnel resources, concentrating the greatest efforts where potential threats pose the most serious risk.
Effective vulnerability management in the supply chain
Current statistics paint an alarming picture of organizational readiness to meet the new requirements. Only 46% of companies remediate critical vulnerabilities within a month of detection, and 13.5% of firms admit they have no visibility over more than half of their IT assets.
The NIS2 Directive significantly raises standards in this area, requiring the implementation of:
A comprehensive program of systematic vulnerability scans, covering both internal infrastructure and touchpoints with external suppliers. Companies must develop precise patching procedures with clearly defined response times based on the criticality of detected vulnerabilities. Regular testing of implemented safeguards' effectiveness and rigorous documentation of all remediation activities for subsequent audits are also mandatory.
Meeting these requirements demands significant investments in tools that automate the process of detecting and managing vulnerabilities throughout the organization's entire IT ecosystem.
Incident reporting obligations and early warning systems
One of the most demanding aspects of the new directive is the introduction of an obligation to report within 24 hoursany serious security incident that may affect supply chain continuity.
To meet this challenge, organizations must:
Implement advanced monitoring systems capable of detecting even subtle signs of potential security breaches or supply chain disruptions. They need to develop detailed incident response plans that account for the specific characteristics of individual suppliers and the types of services they provide. Organizations should create dedicated crisis teams responsible for coordinating actions during supply chain disruptions. Integration of internal reporting procedures with the pan-European CSIRT ENISA network is also essential, enabling effective coordination of defensive actions at the international level.
Effective implementation of these mechanisms requires not only technological investments but also profound organizational and process changes.
Contemporary challenges and trends in supply chain security (2025)
Growing geopolitical tensions and state-sponsored threats
Specialized cyber criminal groups sponsored by certain states increasingly target strategic supply chains, seeking to achieve political, economic, or intelligence advantages.
This trend compels organizations to incorporate geopolitical factors into their risk analyses, especially when establishing relationships with suppliers from or operating in high-risk regions.
Businesses must conduct detailed analyses of the geopolitical context, identify potential conflicts of interest, and implement additional control mechanisms for suppliers from countries considered sources of advanced cyber threats.
Evolution of artificial intelligence-based threats
We are witnessing a dynamic evolution of attack techniques leveraging artificial intelligence to automate phishing campaigns, identify vulnerabilities, and deploy malware.
In response to these threats, a growing number of organizations are implementing their own artificial intelligence-based solutions to protect their supply chains.
A notable example of innovative approaches is Honeywell's strategy, which combines advanced AI-based threat detection algorithms with Virtual Twin technology, enabling comprehensive simulations of supply chain behavior under various attack scenarios . This approach allows for proactive detection of potential security gaps before attackers can exploit them.
Regulatory harmonization challenges as a significant barrier
The varied pace and manner of implementing the NIS2 Directive across EU member states (e.g., different implementation schedules in Belgium and Croatia) significantly complicates compliance for organizations operating in multiple jurisdictions.
International businesses must account for these differences in their compliance strategies, often forcing them to adopt the most stringent interpretation of regulations to ensure compliance across all locations.
Additionally, organizations must continuously monitor changes in implementing regulations across different countries and adjust internal policies and procedures to align with evolving legal requirements.
Realistic analysis of NIS2 compliance costs and benefits
Implementation costs and practical challenges
Comprehensive implementation of all NIS2 requirements is a lengthy and resource-intensive process. Studies show that the average time needed to fully adapt to the new regulations is approximately 12 months, including conducting necessary security audits and implementing specialized technical tools.
This timeline presents a significant challenge, especially for medium-sized organizations that must balance security investments with other business priorities.
Implementation costs encompass not only the acquisition of new technologies and tools but also employee training, hiring security specialists, and reorganizing internal processes. For many companies, this necessitates a substantial increase in cybersecurity budgets.
Proven risk management frameworks as compliance foundations
Research indicates that about 66% of organizations leverage existing standards, such as ISO 27001 or NIST frameworks, as the foundation for meeting NIS2 requirements.
This pragmatic approach allows organizations to build upon security structures and processes already in place, rather than starting from scratch. Integrating NIS2 requirements with existing security management frameworks enables cost optimization and reduces the time needed to achieve compliance.
Organizations that have previously invested in ISO 27001 certification or implemented other recognized security standards enjoy a significant advantage in adapting to the new regulatory requirements.
Historical lessons and instructive case studies
The devastating NotPetya attack on global logistics giant Maersk in 2017, which caused enormous losses estimated at over 300 million dollars, is frequently cited in official ENISA guidelines as an example of the catastrophic consequences of supply chain security negligence.
This case powerfully illustrates the potential costs of inadequate safeguards and procedures. As a result of the attack, Maersk had to completely halt operations in 76 ports worldwide and manually coordinate the movement of thousands of containers, leading to massive disruptions across global supply chains.
Analysis of this incident clearly demonstrates that investments in supply chain security, while significant, pale in comparison to the potential losses resulting from a serious security breach.
Specific implementation steps to ensure NIS2 compliance
Achieving compliance with NIS2 requirements regarding supply chain security demands a systematic approach and implementation of the following activities:
First, organizations must conduct a detailed inventory of all suppliers and business partners, particularly focusing on those with access to critical systems or sensitive data. Identifying all dependencies and potential vulnerability points is crucial for effective risk management.
Following this assessment, the organization should develop a methodology for classifying suppliers according to risk level, considering factors such as the type and extent of access to internal systems, the nature of processed data, the criticality of services provided, and the potential impact on business continuity in the event of a security incident.
The next critical step is developing standard contractual clauses that comply with NIS2 requirements for inclusion in all new agreements and amendments to existing contracts. These clauses should clearly define security expectations, incident reporting obligations, and consequences for failing to adhere to established standards.
Organizations must also implement comprehensive systems for continuous monitoring of supplier security, particularly for those classified as high-risk. Such systems should include regular security assessments, technical audits, and monitoring of compliance with contractual requirements.
Another essential element is preparing detailed incident response plans that address various scenarios related to supply chain security breaches. These plans should define roles and responsibilities, escalation paths, and internal and external communication procedures to ensure swift and effective responses.
Regular audits and security assessments of suppliers constitute another vital component of a robust compliance strategy. These evaluations may be conducted by internal teams or external specialists, depending on the risk level and available resources.
Organizations should also provide comprehensive training for all employees responsible for managing supplier relationships. These training programs should cover risk identification, supplier security assessment methodologies, and incident reporting procedures.
Finally, organizations must rigorously document all supply chain security activities, including risk assessments, security audits, detected incidents, and remedial actions taken. This documentation serves as essential evidence during regulatory inspections and compliance audits.
Conclusion
The NIS2 Directive introduces fundamental changes to supply chain security approaches, requiring organizations to implement substantially more rigorous mechanisms for assessing and monitoring external partners. While adapting to these new requirements undoubtedly presents significant organizational, financial, and technical challenges, it simultaneously offers an opportunity to build more resilient and secure business operations.
Organizations that proactively implement NIS2 requirements will not only avoid potential administrative and financial penalties but also gain significant competitive advantages through enhanced resilience against modern cyber attacks. In an environment where a single serious security incident can trigger catastrophic operational and financial consequences, strategic investments in supply chain security become a business necessity rather than an option.
The implementation of security mechanisms required by NIS2 should be viewed not merely as a regulatory compliance cost but primarily as a strategic investment in building trust among customers, business partners, and other stakeholders, ultimately translating into measurable business benefits and market advantages over the long term.
Sources
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