The Foundation of Modern Cyber Resilience
In an era of hyper-connectivity, your organisation's security is only as strong as the weakest link in your extended ecosystem. With the introduction of stringent new frameworks like NIS2, DORA, and the evolving remit of the CSRB, comprehensive supply chain mapping is no longer a "best practice"—it is a legal mandate.
Modern cyber threats rarely strike the front door. Instead, they exploit trusted third-party vendors, software libraries, and outsourced service providers to bypass traditional defences. To mitigate these risks, you must move beyond a simple list of suppliers and develop a dynamic, multi-tier map of your entire digital dependencies.
The NIS2 Directive places a heavy emphasis on the security of supply chains for "Essential" and "Important" entities.
The Mandate: Entities must address supply chain security, including the relationships between the company and its direct suppliers or service providers.
The Risk: Failure to demonstrate due diligence in vetting your suppliers' security practices can lead to significant fines and management liability.
Specific to the financial sector, DORA introduces a harmonised framework for managing ICT third-party risk.
Critical Third Parties: You must identify "critical" ICT third-party service providers.
Continuous Monitoring: Mapping allows for the mandatory "exit strategies" and concentration risk assessments required by the regulator.
While the CSRB focuses on post-incident analysis, its findings consistently highlight systemic supply chain vulnerabilities (such as the Log4j vulnerability).
Proactive Compliance: By mapping your supply chain now, you align with the "lessons learned" approach championed by the CSRB, ensuring you aren't vulnerable to the same systemic failures identified in global post-mortems.
To achieve compliance, your mapping must go beyond Tier 1 vendors. You need to understand your supply chain's supply chain.
| Stage | Action Item | Regulatory Alignment |
|---|---|---|
| Identification | Catalog all ICT service providers, including cloud, data analytics, and software-as-a-service (SaaS). | DORA Art. 28 |
| Categorisation | Rank suppliers based on the criticality of the functions they support. | NIS2 Art. 21 |
| Dependency Mapping | Identify sub-contractors (Tier 2 and 3) that your primary vendors rely on to deliver services. | CSRB Recommendations |
| Data Flow Analysis | Map where your data travels and stays throughout the chain. | GDPR & NIS2 |
When a vulnerability is announced, you can instantly see which parts of your infrastructure are affected.
Avoid situations where multiple "independent" vendors all rely on the same underlying (and potentially vulnerable) cloud provider.
Provide auditors with a clear, visualised evidence base of your risk management posture.
Identify single points of failure before they cause a systemic outage.
Important Note: Under both NIS2 and DORA, the responsibility for supply chain risk remains with the management body of the organisation. You cannot outsource your liability.
Navigating the complexities of NIS2, DORA, and CSRB requires a blend of legal insight and technical prowess. We provide the tools and expertise to transform your vendor list into a robust, compliant, and resilient supply chain map.