the work

supplier risk

Your suppliers' failures count as yours. Three rules ask for the same thing: know who they are, look at them in proportion, and put security in the contract.

NIS2 / DORA / GDPRlast checked 2 November 2026not legal advice
01

the reality

All three rules ask for the same work, so build one register and let each rule read from it. A company under DORA should build to the DORA register and use it for everything, since that one asks for the most.

If you sell to a bank or a regulated customer, expect this page in reverse, with their terms arriving as contract changes for you to accept.

what passes along a supply chain

your customermay be under NIS2 or DORA itself
  • contract terms, questionnaires
  • your incident notices
youstay answerable for what you hand on
  • your data, your access
  • security terms, audit rights
  • their incident notices, reports
direct supplierthe one the law names
  • the same terms, passed on
  • often your data too
its subcontractorreached only through your contract
Duties run in the same direction as your data. Notices have to run back, and only do if a contract says so.

basis NIS2 Art. 21(2)(d), 21(3); GDPR Art. 28(1), 28(3), 28(4); IR 2024/2690 Annex 5.1.4 as a reference

You remain answerable either way. The Polish authority fined the customer far more than the processor in 2025.

basis DORA Art. 28(1), 30(2); NIS2 Art. 21(2)(d); GDPR Art. 28(1)

02

what to decide

  • Who owns the registernamed owner, usually procurement or IT
  • How hard to look at each tier of suppliernamed owner, approved by the board
  • Which clauses are non-negotiable in new contractslegal, with the owner
  • Which suppliers need an exit planoperations

basis NIS2 Art. 21(2)(d), 21(3); DORA Art. 28(3). The tiers are practice.

how hard to look at which supplier

how much you depend on them
easy to replacehard to replace
no data, no accesson the registerregister and an exit plan
holds your datacontract terms, read their reportterms, report, exit plan
can reach your systemsterms, report, access limitsall of it, every year
what they can touch
  • light
  • medium
  • heavy

basis working practice. No legal text sets this.

03

what to build

  1. Export every supplier from accounts payable, then add the tools in your identity provider's app list. That is your starting register.
  2. Mark each one: does it hold your data, can it reach your systems, would you stop without it. Anything with no marks leaves the list.
  3. For the marked ones, record owner, contract date, data involved, where the service runs and who to call in an incident.
  4. Collect the certificate or report the top ten already have and read its scope, or send a short questionnaire. Note the date.
  5. Write one clause set for new deals and renewals: security requirements, incident notice to you, audit or report rights, subcontractors, data return at exit.
  6. Set a yearly review, because a check done once and never again does not hold up.

basis NIS2 Art. 21(3); GDPR Art. 28(1), 28(3); IR 2024/2690 Annex 5.1.4, 5.2 as a reference; DORA Art. 30(2)

04

the evidence it leaves

what you can showwho owns itrefresh
supplier register with criticality marksprocurement or head of ITtwice a year
assessment records with datessupplier's business owneryearly for critical suppliers
signed processing agreementslegal or DPOat signing and on change
clause set, and a list of contracts carrying itlegalyearly
exit plan for critical suppliershead of ITyearly

basis GDPR Art. 28(3), 5(2); DORA Art. 28(3)

05

what goes wrong

trusting an old relationship

A Polish customer relied on a PR firm's earlier work and did not check its ability to secure data. The case.

audit rights nobody uses

A clause only helps if someone reads the reports. Put a name and a date on it.

the certificate that covers something else

A report on one product says nothing about the service you buy. Read the scope.

free tools off the list

Accounts payable misses anything that costs nothing and still holds your data.

basis GDPR Art. 28(1), as applied by UODO on 21 July 2025; the rest is practice

06

what the texts leave open

  • How deep to go. NIS2 speaks of direct suppliers. Subcontractors enter through your contract terms.
  • Whether a supplier's certificate is enough. No text says so. Read the scope and record why you accepted it.
  • Which functions count as critical or important under DORA. The test is yours to apply, and your supervisor can question it.

basis NIS2 Art. 21(2)(d); DORA Art. 28(3)

07

check it yourself

fyi Last checked 2 November 2026. This is not legal advice. It is a plain reading of the texts listed on this page, and national law can add to them. Before you rely on it in front of a regulator, an auditor or your board, have a lawyer confirm it for your company. What this means.

your next step

Export last year's supplier payments and mark the first ten, today.