NIS2 in focus: supply chain security

The NIS2 Directive, which came into effect across the EU in 2024, imposes stricter cybersecurity requirements on essential and important entities. One of the most critical components of this directive is the emphasis on supply chain security. For organizations relying on third-party vendors and partners, cybersecurity is no longer an internal affair—it is a shared responsibility throughout the entire ecosystem.

Supply Chain Security is Essential

The growing complexity of IT and OT environments has made organizations increasingly dependent on external vendors for software, hardware, and services. Threat actors actively exploit this dependency through supply chain attacks, targeting vulnerabilities in one of the many links in the chain. High-profile incidents such as the SolarWinds breach (2020) and Kaseya ransomware attack (2021) demonstrate how a single weak link can result in catastrophic consequences for hundreds of organizations worldwide.

NIS2 Requirements

Under NIS2, organizations are required to:

• Conduct risk assessments of their supply chain, including software and hardware suppliers.
• Enforce contractual obligations (SLAs) related to security standards and incident response capabilities.
• Implement business continuity plans to minimize the impact of supply chain-based incidents.
• Perform detailed monitoring and auditing of third-party cybersecurity posture.

Technical Implementation of NIS2 Supply Chain Security

Compliance with NIS2 demands a structured, proactive approach to third-party risk management. Key technical and organizational measures include:

Vendor Evaluation & Due Diligence

Organizations should implement a comprehensive vendor risk management framework, including:

• Assessing supplier cybersecurity maturity based on standards such as ISO 27001, SOC 2, and NIST.
• Requiring a Software Bill of Materials (SBOM) from software vendors to gain visibility into dependencies, third-party libraries, and potential vulnerabilities.
• Requesting periodic penetration test reports from third-party services, covering API security, container hardening, and cloud configurations.
• Enforcing secure coding practices through mandatory code reviews and the integration of SAST/DAST within the CI/CD pipeline.

Zero Trust Architecture

A zero trust model ensures that vendors and partners do not gain unnecessary access to critical systems. Key components include:

• Network and micro-segmentation to strictly isolate vendor systems from internal networks using SDN (Software Defined Networking) and NAC (Network Access Control).
• Multi-Factor Authentication (MFA) and Just-in-Time (JIT) access, granting temporary, verified access based on identity and behavioral analysis.
• Cryptographic verification and digital signatures to validate software deliveries and firmware updates against tampering.
• Continuous vendor activity monitoring through SIEM, XDR, and UEBA, combined with real-time Threat Intelligence feeds.

Incident Response and Crisis Management

NIS2 mandates that organizations be fully prepared for supply chain-related incidents and capable of executing rapid response. This includes:

• Integrating supply chain scenarios into the incident response plan, with procedures for isolating compromised vendors.
• Enforcing automatic quarantine mechanisms using SOAR (Security Orchestration, Automation, and Response) platforms.
• Defining clear contractual agreements with vendors regarding breach notification obligations, maximum response times, and forensic investigation requirements.
• Conducting advanced threat modeling and attack simulations using MITRE ATT&CK to map potential attack surfaces within the supply chain.
• Simulating supply chain-specific cyberattacks during tabletop exercises and Red Team engagements to test and refine response strategies.

Summary

With the introduction of NIS2, supply chain security has become a foundational element of cybersecurity strategies. Organizations dependent on third-party providers must go beyond mere compliance—they must harden both technical and organizational defenses. By implementing zero trust principles, proactively managing vendor risks, and refining incident response capabilities, organizations can significantly enhance their resilience against modern supply chain threats.

At DeepBlue Security & Intelligence, we support organizations in aligning their supply chain security with NIS2 requirements, offering expert guidance on pentesting, risk assessments, and incident response strategies.

Contact us for a strategic approach that not only meets compliance but also strengthens operational resilience.
www.deepbluesecurity.nl | info@deepbluesecurity.nl | +31 (0)70 800 2025

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