Supply chain security policy

Extend security requirements down the ICT products and services supply chain.

What the ISO 27002 guidance expects the document to say: Requires processes and procedures to be defined and implemented to manage information security risk arising along the supply chain for ICT products and services.

The Directive scopes this deliberately at direct suppliers and service providers, which makes the first artefact an inventory of who those parties are and which of them touch the network and information systems behind the service. From there the entity has to manage the security-related aspects of each relationship: what the supplier may access, what security obligations bind it, what happens on incident, and what happens at exit. Contract terms are the enforcement mechanism, so contracts that predate NIS2 and carry no security clauses are a live gap rather than a legacy inconvenience. Managed service providers and managed security service providers deserve separate attention because they hold privileged access into the estate, which makes their compromise the entity's incident.

Deciding what supply chain measures are appropriate is not left to general judgement. The entity has to take into account the vulnerabilities specific to each direct supplier and service provider, and the overall quality of those parties' products and cybersecurity practices including their secure development procedures. Separately, it must take into account the results of the Union level coordinated security risk assessments of critical supply chains carried out under Article 22(1). That second limb creates an external input the entity has to watch for and respond to: when a coordinated assessment lands on a technology the entity uses, the outcome has to reach the supplier risk decisions rather than stop at a policy team. Evidence of consideration is what is being asked for, including reasoned decisions not to change anything.