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Not automatically. A customer’s NIS2 status does not, by itself, make every supplier directly subject to the Directive. But covered customers must manage cybersecurity risks in their supply chains, so they may assess suppliers and include security requirements in contracts. Your own direct NIS2 obligations depend separately on your activities, size, and the national rules that apply to your business.
What NIS2 requires of covered customers
Under Article 21 of the NIS2 Directive, essential and important entities must take appropriate and proportionate technical, operational, and organisational measures to manage risks to the network and information systems they use to provide services. Those measures include supply-chain security, including security-related aspects of relationships with direct suppliers and service providers. The legal duty described here is imposed on the covered entity; it is not a blanket rule making every supplier a regulated entity. Read Article 21 of Directive (EU) 2022/2555.
This distinction has a practical consequence: a supplier may face NIS2-related scrutiny through a customer’s procurement and risk-management process without being an essential or important entity itself. Contract terms the supplier agrees to may be binding, while other laws or the supplier’s own regulatory status may create separate duties. A customer’s covered status alone does not make every request it sends a legal obligation for the supplier.
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How to determine whether your company is directly in scope
Assess your own business rather than inferring your status from a customer’s. NIS2 scope depends on factors including the supplier’s sector and activities, and the applicable Member State framework. Because NIS2 is a directive implemented through national laws, the relevant local rules and sector-specific requirements matter. The European Commission’s NIS2 policy page provides EU-level context; check the current law and regulator guidance for the country and sector that apply to your company.
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For a specific determination, identify the legal entity providing the service, its activities and size, and the national rules that govern it. Do not assume that a customer’s classification settles the supplier’s status. This article describes the general EU-level distinction, not a legal assessment of any particular company.
What an NIS2 customer may ask suppliers to demonstrate
ENISA’s June 2025 version 1.0 technical implementation guidance describes supply-chain security policies and examples of contract topics that covered entities may consider according to their policies and risk assessments. These are context-sensitive examples, not terms every supplier must accept unchanged. Read ENISA’s NIS2 technical implementation guidance.
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| Possible topic | What the customer may seek to address |
|---|---|
| Security requirements | Cybersecurity expectations relevant to the supplier relationship and the customer’s risk assessment. |
| Staff capability | Staff awareness, skills, training, and, where appropriate, certifications. |
| Personnel checks | Employee background verification where appropriate. |
| Incident notification | Supplier notification of incidents without undue delay. |
| Assurance | Audit rights or the provision of audit reports. |
| Vulnerabilities | Processes for identifying and handling vulnerabilities. |
| Subcontracting | Controls over subcontracting and subcontractor security. |
| End of contract | Retrieval or disposal of information when the contract ends. |
The right requirements depend on how the service affects the customer’s systems and the risks in that relationship. A proposed clause is not automatically proportionate or necessary just because it appears in a guidance example; discuss scope, evidence, timelines, and responsibilities with the customer.
Which supplier relationships deserve the closest attention
The clearest focus is on direct suppliers and service providers whose products or services affect a covered entity’s network and information systems. Depending on the relationship and risk, that may include ICT, software, hardware, cloud, managed service, or managed security service providers. Neither the Directive nor the cited guidance supports treating every supplier in every tier as subject to identical requirements. The covered entity’s direct relationships, its risk assessment, and relevant subcontracting arrangements shape what it needs to manage.
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How to prepare for a supplier security review
ENISA’s guidance identifies policy and contract areas a covered entity may address. A supplier can prepare to respond by organising relevant information around those topics; doing so is a practical readiness step, not a universal standalone duty imposed on every supplier by the guidance.
- Map the service. Describe what you provide, which customer systems or services it affects, and the security responsibilities each party handles.
- Document controls and incident handling. Keep a clear account of relevant security measures and how your organisation identifies, escalates, and communicates incidents.
- Assign a response owner. Make clear who can answer security questionnaires and coordinate supporting evidence consistently.
- Identify subcontractors. Maintain visibility into relevant subcontractors and how security expectations are handled across the relationship.
- Clarify vulnerability and notification processes. Be ready to explain how vulnerabilities are handled and how incident-notification arrangements would work in practice.
- Review contract terms in context. Check proposed audit or reporting rights, subcontracting conditions, and information-return or disposal provisions against the service, evidence available, and agreed responsibilities.
These preparation steps follow the topics ENISA identifies for supply-chain policy and contract consideration; they should be adapted to the service and the customer’s actual risk needs.
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What the available supply-chain statistic does—and does not—show
ENISA’s June 2023 report says 86% of surveyed organisations had implemented ICT/OT supply-chain cybersecurity policies, based on a 2022 study. That is a historical survey finding, not a measure of NIS2 compliance or current supplier readiness. See ENISA’s 2023 supply-chain cybersecurity report.
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