Cybersecurity Briefing — October 17, 2025
EU Member States must deliver coordinated supply-chain cybersecurity risk assessments by 17 October 2025 under Article 32 of the NIS2 Directive, and operators need data and mitigation evidence ready for regulators.
Executive briefing: Article 32 of Directive (EU) 2022/2555 (NIS2) requires Member States, in cooperation with the European Commission and the NIS Cooperation Group, to deliver a coordinated supply-chain risk assessment for critical ICT services, systems, and products by 17 October 2025. Essential and important entities will be asked to provide dependency inventories, incident histories, and mitigation plans covering key suppliers. Security and procurement leaders should prepare datasets and remediation evidence now so national authorities can complete their assessments on schedule.
Key risk themes
- Visibility expectations. NIS2 supervisors are requesting up-to-date catalogues of critical providers, subcontractors, and geographic footprints to identify systemic concentration risks.
- Cross-border coordination. Entities operating in multiple Member States must reconcile differing data models and submission portals while ensuring confidentiality controls protect sensitive supplier information.
- Mitigation accountability. Article 21 security measures—such as incident response, vulnerability management, and supply-chain security policies—will be cross-checked against assessment outputs, driving follow-on audits.
Operational priorities
- Data preparation. Normalise supplier metadata, contract references, and service criticality ratings into exportable formats aligned to the Cooperation Group’s templates.
- Evidence packaging. Bundle penetration-test results, SOC reports, and remediation plans for high-risk vendors so Member States can evaluate residual risk quickly.
- Executive reporting. Produce board-ready summaries highlighting top dependencies, geographic clustering, and remediation timelines tied to the coordinated assessment.
Enablement moves
- Establish secure data rooms for authorities to review supplier information while preserving trade secrets and contractual confidentiality obligations.
- Coordinate with strategic vendors to align their submissions across Member States and avoid inconsistent narratives.
Sources
Zeph Tech curates NIS2 supplier inventories, orchestrates cross-border submissions, and tracks remediation close-out so operators can evidence mature supply-chain security programmes.