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NIS2 Supply Chain Guide: From Art. 21 to the Provider Register

Operational methodology to meet the supply chain security obligation

16 pagesNIS2 & CompliancePublished: February 20, 2026
Whitepaper cover: isometric illustration of a chain of ICT suppliers linked to a central risk-assessment node under NIS2

NIS2 & Compliance

NIS2 Supply Chain Guide: From Art. 21 to the Provider Register

Article 21.2.d of NIS2 requires essential and important entities to manage the security of their direct suppliers and service providers as part of their risk management policy. This guide explains what the article actually requires, how it relates to the ENS and DORA, and proposes a phased implementation plan with checklists and a reusable supplier assessment questionnaire template.

Contents / Contenido

  1. 1. Executive summaryPreview
  2. 2. Context: why supply chain gets its own chapter in NIS2Preview
  3. 3. Applicable regulatory frameworkPreview
  4. 4. What Article 21.2.d actually requires, in plain termsRequires download
  5. 5. Step-by-step implementation planRequires download
  6. 6. ChecklistsRequires download
  7. 7. Template: supplier assessment questionnaireRequires download
  8. 8. Common mistakes observed in adequacy projectsRequires download
  9. 9. GlossaryRequires download
  10. 10. How Hodeitek helpsRequires download
  11. 11. SourcesRequires download

Preview: first pages

Article 21.2.d of NIS2 requires essential and important entities to manage the security of their direct suppliers and service providers as part of their risk management policy. This guide explains what the article actually requires, how it relates to the ENS and DORA, and proposes a phased implementation plan with checklists and a reusable supplier assessment questionnaire template.

The preview of this whitepaper includes the executive summary, regulatory context and methodological approach that frames the rest of the document. Download to access full templates, matrices and checklists.

  • 1. Executive summary
  • 2. Context: why supply chain gets its own chapter in NIS2
  • 3. Applicable regulatory framework
Photo of Gorka Gonzalo

Gorka Gonzalo

Founder & CEO

Founded Hodeitek in 2023 and runs the company, after more than 8 years in pentesting, Red Team, OT/ICS auditing, and SOC leadership. A cybersecurity and AI expert, he sets the technical and product direction of HodeiShield and personally leads the most critical engagements — from defense strategy to applying AI in threat detection. He is the client's direct point of contact: whoever scopes the work also answers for the result.

“This whitepaper is the clearest guide I've seen on NIS2 in 2026.”
By Anonymous, CISO, Financial Sector
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