Third-Party Cybersecurity Assessment: NIS 2 and DORA Compliance

European companies are facing a major regulatory challenge with the simultaneous implementation of NIS 2 and DORA. These two regulations are radically transforming approaches to cybersecurity and operational resilience, particularly in critical and financial sectors. This convergence requires in-depth multi-regulatory expertise to navigate between specific sectoral obligations and operational synergies.

Understanding NIS 2 and DORA

The NIS 2 Directive significantly expands the scope of European cybersecurity by imposing stronger security standards on essential and important entities. It now applies to 18 sectors—including energy, transport, healthcare, and digital services—with transposition deadlines set for October 2024. According to ENISA, 75% of essential entities reported a significant improvement in their cybersecurity posture after implementation. Penalties can reach €10 million or 2% of global annual turnover.

Meanwhile, the DORA regulation (Digital Operational Resilience Act) focuses on financial sector operational resilience through five pillars: ICT governance, risk management, resilience testing, incident management, and critical third-party oversight. The European Banking Authority confirms that DORA-compliant institutions see a 25% drop in ICT-related incidents. Resilience testing becomes mandatory for significant financial entities.

Strategic Synergies Between NIS 2 and DORA

The integrated approach of these regulations reveals critical synergies for streamlined compliance. The PwC white paper on NIS 2 and DORA highlights the importance of a unified risk management framework.

Likewise, the Secure by Design comparative analysis notes that financial institutions integrating NIS 2 and DORA benefit from enhanced operational resilience through shared risk management processes. This convergence enables the development of a unified third-party governance framework that meets both DORA’s critical ICT vendor oversight and NIS 2’s essential service provider assessment requirements.

This necessitates multi-regulatory expertise to build a unified compliance framework that maximizes efficiency while ensuring comprehensive regulatory coverage.

Impact on Vendors and Third Parties

NIS 2 and DORA fundamentally change third-party risk management by enforcing stronger oversight across supply chains. NIS 2 places third-party risk at the heart of the directive, requiring companies to perform thorough supplier assessments.

DORA is even more stringent for the financial sector. House of Control confirms that DORA’s third-party risk approach is more structured and includes mandatory audits and resilience testing for critical ICT vendors.

Organizations must also implement cyber risk management measures in supplier contracts. However, this results in growing supplier fatigue, with vendors receiving an average of 35 assessment questionnaires per year—reducing response quality.

Internal Governance Implications

These regulations redefine governance responsibilities at the highest level. Telefónica Tech highlights that DORA requires board-level approval of policies and strategies, while operational procedures can be delegated.

This division of responsibility optimizes governance by balancing strategic control and operational agility. Multi-regulatory expertise is needed to articulate DORA’s strategic governance needs with NIS 2’s sectoral operational obligations.

Best Practices for NIS 2 and DORA Compliance

Best practices rely on rigorous risk management and stronger governance. According to ENISA, companies must implement a NIS 2-aligned risk framework including continuous monitoring, incident response capabilities, and regular training. Third-party cybersecurity and supply chain protection are top priorities.

For finance, the European Banking Authority advises strong ICT governance, resilience testing, incident reporting, and critical vendor monitoring to ensure optimal compliance.

Organizations should also train teams on evolving cybersecurity issues and include contractual clauses to ensure full digital ecosystem coverage.

Collaborative Cybersecurity Assessment

Unlike internal audits that focus on protecting an organization’s own systems, collaborative assessment aims to strengthen the cybersecurity maturity of the entire third-party ecosystem. This approach enables proactive identification of potential vulnerabilities in partners, while providing them with the necessary support to improve their security posture.

According to the AMF Cybermalveillance guide, French local authorities are developing collaborative third-party governance approaches to meet NIS 2 requirements. The guide specifically recommends pooling digital security services between inter-municipal bodies and member communes, allowing smaller structures to rely on the expertise of larger authorities. This collaborative approach generates significant cost savings through joint procurement initiatives and optimizes the evaluation of critical service providers in compliance with regulatory obligations.

Document intelligence and real-time monitoring technologies facilitate this approach by automating the analysis of ISO 27001/27701 certifications and detecting anomalies in partner security practices. This automation effectively combats supplier fatigue: vendors subjected to multiple assessment questionnaires tend to lose engagement and accuracy. A collaborative approach allows evaluations to be shared between clients, significantly reducing the administrative burden on third parties through standardized processes.

Challenges and Opportunities in Implementing Both Regulations

According to the ENISA NIS Investments 2024 study, 68% of European organizations cite regulatory coordination as their top challenge.

Risk Management and Readiness

Supplier fatigue is a major challenge to the effective implementation of NIS 2 and DORA. According to Assent, vendors who receive multiple, non-standardized questionnaires pay less attention to the accuracy of their responses, undermining the effectiveness of cybersecurity assessments.

According to the French Senate’s report on local cybersecurity, territorial authorities are developing inter-municipal strategies to pool cyber expertise and comply with NIS 2 requirements. This collaborative approach makes it possible to “combine efforts, address the shortage of qualified professionals, and implement collective protection” for third-party partners. The shared model improves the evaluation of critical vendors while reducing the administrative burden on suppliers through standardized and jointly managed processes across local authorities.

Automating security evaluation processes is becoming essential to efficiently manage the growing number of third-party providers. Predictive, AI-powered solutions help anticipate potential vulnerabilities and proactively adapt protective measures.

Highlighting Operational Benefits

These regulations offer significant strategic opportunities to enhance supply chain security. Harmonizing compliance practices creates strong operational synergies, especially for multi-sector organizations.

European standardization also facilitates international expansion by establishing a coherent regulatory framework. Compliant companies gain a lasting competitive advantage, boosting their reputation and appeal to demanding business partners.

The collaborative approach turns supplier fatigue into a competitive edge. As demonstrated by Security Scorecard, integrated third-party governance platforms enable structured communication with vendors, promoting collaborative remediation of vulnerabilities rather than multiplying redundant audits.