NIS2 Supply-Chain Security: Managing Critical Suppliers and High-Impact Procurements


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NIS2 Supply-Chain Security: Managing Critical Suppliers and High-Impact Procurements

February 17, 2026

In the NIS baseline framework, supply-chain cybersecurity is a governance obligation, not only a procurement control. Organizations are expected to identify high-impact suppliers, assess and prioritize related risks, and integrate security requirements into contracts and lifecycle oversight.

Sources: ACN baseline obligations determination, ACN baseline reading guide

Key takeaways

  • Supply-chain controls are formalized through GV.SC baseline measures.
  • Critical suppliers should be identified, prioritized, and tracked in a maintained inventory.
  • Security requirements should be embedded in tendering and contractual documents.
  • Supplier risk must be evaluated, treated, and monitored throughout the procurement lifecycle.

Sources: ACN baseline obligations determination

Supply-chain control model (GV.SC)

1. Governance and policy baseline (GV.SC-01)

Define and approve supply-chain cyber-risk governance principles and requirements for high-impact procurements.

2. Roles and accountability (GV.SC-02)

Assign clear responsibilities across internal stakeholders and define interaction rules with suppliers, partners, and customers where relevant.

3. Supplier inventory and prioritization (GV.SC-04)

Maintain an updated inventory of suppliers linked to potentially high-impact supplies and prioritize them by criticality.

4. Contractual security integration (GV.SC-05)

Integrate required security clauses and control expectations into bids, contracts, agreements, and procurement artifacts.

5. Lifecycle supplier-risk oversight (GV.SC-07)

Evaluate, treat, and continuously monitor supplier-related cyber risks during the full supply lifecycle.

Sources: ACN baseline obligations determination

Minimum evidence set for supply-chain readiness

Area Practical objective Typical evidence
GV.SC governanceFormal supplier-risk governance modelGovernance policy, approval records
Supplier inventoryVisibility on critical suppliersSupplier inventory, criticality classification
Contract integrationSecurity requirements embedded in contractsTender clauses, contract annexes, agreement templates
Risk assessmentSupplier risk documented and prioritizedSupplier-risk assessments, treatment decisions
Ongoing monitoringContinuous supplier-risk oversightMonitoring log, reassessment records

Sources: ACN baseline obligations determination

90-day execution checklist

  1. Build or refresh inventory of high-impact suppliers and assign owners.
  2. Define supplier criticality criteria and scoring method.
  3. Update procurement templates with required cybersecurity clauses.
  4. Launch prioritized supplier-risk assessments and treatment plans.
  5. Establish recurring monitoring and reassessment cadence.

FAQ

Is supplier cybersecurity a technical-only responsibility?

No. Baseline requirements place it under governance, procurement, legal, and security coordination. Source: ACN baseline obligations determination

Are contract clauses sufficient by themselves?

No. Clauses must be backed by risk assessment, treatment decisions, and ongoing monitoring. Source: ACN baseline obligations determination

Which suppliers should be assessed first?

Priority should follow documented criticality and risk criteria defined by the organization and aligned with baseline expectations. Sources: ACN baseline obligations determination, ACN baseline reading guide

Official sources

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