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Vendor due diligence is a proportionate investigation of a supplier before you commit—and an ongoing check that its security, data handling and service remain acceptable. Start with what the supplier will do, what you depend on it for, and what information or access it needs. Then scale the review to the consequences of failure. The checklist below gives you a practical process; NIST’s detailed C-SCRM framework applies specifically to information and communications technology (ICT) suppliers, not every vendor or every legal obligation.

What vendor due diligence covers

NIST defines cybersecurity supply-chain risk management (C-SCRM) due diligence as research and verification of pertinent information about a supplier or product to inform acquisition decisions. Its SP 1326 quick-start guide, published July 8, 2026, identifies five areas for ICT suppliers: foreign ownership, control or influence; provenance; resilience; foundational cyber practices; and supply-chain tiers. The guide supplements NIST SP 800-161 Revision 1.

Due diligence is a minimum research layer before a more complete ICT supplier review, not a substitute for a full supply-chain risk assessment. For other vendors, use the same practical questions where relevant, but do not treat NIST’s ICT-specific categories as a universal checklist or legal standard.

Scale the review to the relationship

Basic due diligence can be desktop research using publicly available information. Enhanced review may draw on commercial datasets, proprietary sources and supply-chain illumination tools. Choose the level of effort according to the supplier’s criticality and your organization’s resources; corroborate important findings with more than one source where possible.

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  • Low impact: A supplier with no sensitive data or privileged access and an easily replaceable service may need a documented identity check, basic security review and clear data terms.
  • Higher impact: A supplier that handles sensitive information, connects to business systems, supports a critical operation or would be difficult to replace warrants stronger evidence, deeper review and planned reassessment.
  • ICT supplier: Consider NIST’s five categories and how much is known about the product’s origin, components and sub-tier suppliers.

These are risk-based distinctions, not a universal scoring scheme. Set concern levels using your own risk tolerance rather than assuming one score fits every organization.

Vendor due diligence checklist

1. Scope the relationship

  • What business outcome will the vendor provide, and how dependent will you be on it?
  • What systems, facilities or data will it access? Does the work involve personal, financial, regulated or otherwise sensitive information?
  • What would be the consequence of an outage, compromise or supplier failure? How quickly could you switch or recover?
  • Who owns the business decision, and who should review security, privacy, legal, procurement and operational issues?
  • Set the review level before requesting evidence, and note why that level fits the vendor’s criticality and access.

2. Establish identity and context

  • Confirm the supplier’s legal name, public identity, headquarters and operating locations, website, and relevant parent or subsidiary relationships.
  • For public-sector procurement or other applicable contexts, check relevant exclusion, sanction or procurement status. NIST SP 1326 discusses U.S. government screening resources; applicability depends on the buyer and transaction.
  • For ICT suppliers, consider ownership, control or influence; where the supplier and product operate or are produced; relevant components and supply-chain tiers; and whether provenance information is sufficient for the risk.
  • Label what is verified, what is a supplier assertion, what comes from third-party reporting and what remains unknown. Save each source and the date checked, and corroborate material claims where possible.

3. Examine capability, security and resilience

  • Review available information about security practices, incidents, product or service vulnerabilities, and remediation.
  • Ask for evidence supporting claimed controls. For each report or certification, identify its scope, date and what independent validation it represents; a logo or questionnaire response alone does not establish that every relevant control is effective.
  • Ask how the supplier detects and reports incidents that could affect you, what response support it provides, and what recovery commitments apply.
  • For ICT products or services, assess foundational cyber practices, organizational and product resilience, and supply-chain dependencies using NIST’s categories.
  • Small organizations can use CISA’s SMB vendor and supplier assessment material to structure evidence requests for ICT hardware, software and services. The material describes a template and spreadsheet with yes, no and partial responses. Treat a partial response as an issue to understand, not as a pass.

4. Map data and access

  • List data the vendor will collect, receive, create or access. Determine where it is stored and processed and who can reach it.
  • Reduce the data and privileges to what the service actually needs.
  • Decide how access is granted, monitored, limited to the work period and removed when no longer necessary. The FTC recommends restricting vendor access to what is needed and for as long as needed.
  • Ask how encryption is configured and how multifactor authentication protects vendor access to business networks, as recommended by the FTC.
  • Define whether the vendor may use, share or sell data, how long it may retain it, and how it must delete it. The FTC recommends putting vendor security and data-handling expectations in writing and verifying that they are followed.
  • For personal information, map how it flows through the business, who can access it, and what retention and secure-disposal approach applies. The FTC advises keeping only what is needed and only as long as needed.

5. Put requirements into the agreement

Match contract terms to the service, applicable law and negotiation. The FTC’s guidance supports written security and data-handling expectations; it does not prescribe a one-size-fits-all clause.

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  • State required security practices and how controls will be evaluated and updated. If you require a particular standard, name it clearly.
  • Specify permitted data use and sharing, retention and deletion, access controls, evidence or verification expectations, and incident communications as appropriate.
  • Agree how you will verify compliance and how the supplier must communicate material changes to its controls or service. Do not rely only on assurances.

6. Decide, document and revisit

  • Record findings, source links and dates, the concern level, open questions, accountable owners, and the decision or conditions for proceeding.
  • Define what counts as concerning according to your organization’s risk tolerance. NIST recommends a due-diligence report template and concern-rating schema, but does not supply a universal score.
  • Choose a refresh schedule or event-based triggers based on criticality, data and access. NIST recommends considering continuous monitoring but does not prescribe a universal reassessment interval.
  • For unresolved concerns, decide whether to escalate, request more evidence, narrow access, add contract conditions or select another supplier.

Compare suppliers on the same evidence

When alternatives are available, compare them against the same criteria rather than relying on polished claims or a single certification.

Comparison area Questions to record
Business dependency How critical is the service, and what is the impact and recovery path if it fails?
Data and access What data is involved, how sensitive is it, and what level and duration of system access is required?
Ownership and jurisdiction Who owns or controls the supplier, and what relevant jurisdictional exposure exists?
ICT provenance and tiers What is known about product origin, components and sub-tier suppliers?
Security evidence What does each item of evidence cover, when was it produced, and what independent validation does it represent?
Incident and recovery How are incidents reported and handled, and what support or recovery commitments apply?
Data commitments What use, sharing, retention and deletion terms are documented?
Verification and gaps How can commitments be checked, and which material questions remain unresolved?

Using tools for higher-risk reviews

For enhanced due diligence, commercial datasets, proprietary sources and supply-chain illumination tools may help uncover information that public desktop research does not. Treat tool output as evidence to assess and corroborate, not as an automatic decision. Record where an important finding came from and what uncertainty remains.

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