NIS2 Compliance with SBOMs: a Scalable, Secure Supply Chain Solution
Software supply chain attacks have emerged as one of the most acute cybersecurity threats in the last decade. The European Union’s (EU) Network and Information Security 2 (NIS2) Directive represents a significant up-leveling of cybersecurity requirements for EU businesses to address this rising threat. NIS2 is, also, a piece of the evolution of a larger, global regulatory puzzle focused on modernizing cybersecurity by codifying supply chain security—with special emphasis on SBOMs—into law.
The NIS2 Directive: A New Era for EU Cybersecurity
NIS2 expands the scope and requirements of its predecessor (NIS1), with software supply chain security playing a starring role in this update. EU member states had until October 17, 2024, to transpose it into national law, with NIS2 superseding the original NIS Directive as of October 18, 2024.
The most notable change to NIS2 is the shift of liability from corporation to personal. This means the executive team and board of directors are now personally liable for compliance and the consequences of non-compliance. A significant deterrent to corporate executives who would rather prioritize growth and neglect cybersecurity.
This expanded directive applies to “essential” services, though the definition is broad. It includes the usual suspects like energy, transportation, healthcare, financial services, but also encompasses “digital service providers” including public cloud platforms, online marketplaces, and search engines. If you’re headquartered outside the EU, NIS2 may still apply to your organization if you have over €10 million in revenue in a given EU member nation or over 50 employees, regardless of your headquarters location.
The Broader Landscape: SBOMs, Supply Chain Security and NIS2 in Context
NIS2 is one step in a broader regulatory reformation to make supply chain security a first-class citizen of cybersecurity compliance:
- EU Cybersecurity Act (2019): Established ENISA (the EU cybersecurity agency) as a permanent agency and created a voluntary cybersecurity certification framework for Information and Communication Technology (ICT) products. SBOMs were not required, but third-party supplier component management was specified as best practice.
- ETSI Standards (2020): ETSI (European Telecommunications Standards Institute) first published standards for consumer IoT security in June 2020. These recommended maintaining a list of third-party software and managing known vulnerabilities, which aligns with SBOM principles, even though “SBOM” did not explicitly appear in the standards.
- NIS2 Directive: Proposed in December 2020 and adopted as law January 2023, emphasizes supply chain security and third-party supplier component management.
- TR-03183 Part 2: SBOMs become mandatory (October 2024) for third-party supplier component management.
- EU Cyber Resilience Act (CRA): Adopts the mandatory SBOM requirement from TR-03183 Part 2 when it is adopted as law in November 2024, though not fully enforced until December 2027.
- Digital Operational Resilience Act (DORA): Couldn’t wait for EU CRA enforcement and requires SBOMs now. Proposed January 2023 and enforced as of January 2025 for financial services including traditional banking, fintech, and crypto services.
How NIS2 Up-levels Software Supply Chain Security Requirements
Beyond the shift of liability highlighted above, NIS2 represents a substantial evolution in the EU’s approach to cybersecurity, with several key changes that directly impact software supply chain security:
Expanded Sector Coverage
NIS2 covers significantly more sectors than the original NIS Directive, introducing categories of “Highly Critical Sectors” and “Critical Sectors.” This broader scope reflects the EU’s recognition that nearly all industries now rely heavily on digital infrastructure and face similar threat landscapes.
Rigorous Size-Based Requirements
The directive applies to medium and large entities based on specific size criteria, ensuring that organizations with significant digital footprints meet appropriate security standards regardless of their industry classification.
Enhanced Supply Chain Security Focus
NIS2 places particular emphasis on supply chain security as a key focus area, acknowledging that modern cyberattacks increasingly target the weakest links in interconnected digital ecosystems.
How SBOMs Address NIS2 Requirements
SBOMs serve as the foundation for meeting several critical NIS2 requirements. They enable organizations to:
- Enable scalable risk management for complex, modern software development patterns
- Meet incident reporting deadlines (24-hour early warning, 72-hour assessment)
- Automate supply chain security and third-party supplier risk management
- Manage corporate and personal liability under NIS2 compliance requirements
Here’s how SBOMs specifically address key aspects of the directive:
1. Automated and Scalable Vulnerability Management
NIS2 requires proactive risk management as outlined in Article 21(2)(d), which mandates that entities protect their networks and IT system from security incidents by implementing “supply chain security, including security-related aspects concerning the relationships between each entity and its direct suppliers or service providers”.
SBOMs enable automated vulnerability identification and management by providing a comprehensive inventory of all software components in use including the relationships between each entity and its direct suppliers or service providers. With this inventory, organizations can automatically cross-reference their components against vulnerability databases, prioritize patches based on severity, and address issues before they can be exploited.
This proactive approach significantly reduces the risk of breaches due to unpatched vulnerabilities—a common attack vector that NIS2 specifically targets in its risk management framework.
2. Rapid Zero-Day Incident Response
Article 23 of NIS2 requires rapid incident notification, with “essential and important entities [submitting] an early warning without undue delay and in any event within 24 hours” of becoming aware of a significant incident.
SBOMs accelerate identification of affected components during incidents by providing immediate visibility into where vulnerable components exist across the organization. When a new zero-day vulnerability is announced (as with Log4j), companies with SBOMs can quickly search their inventory to determine exposure and prioritize remediation efforts.
This capability is crucial for meeting NIS2’s strict reporting timeline requirements, as organizations must know what’s affected to report accurately and respond effectively.
Learn how SBOMs enable organizations to react to zero-day disclosures in minutes rather than days or weeks.
3. Automated Compliance Evidence Generation
Article 21 of NIS2 emphasizes accountability and documentation, requiring entities to “maintain documentation that is sufficient to demonstrate compliance” with its risk management measures.
SBOMs serve as evidence of due diligence in security practices by documenting the components used in software systems and demonstrating an organization’s proactive approach to supply chain security. They provide auditable records of software components and their security status, which can be crucial during regulatory inspections.
This documentation capability aligns directly with NIS2’s emphasis on accountability and transparency, providing tangible evidence of compliance efforts.
Practical Implementation Roadmap with Timelines
Implementing SBOM-based compliance for NIS2 requires a systematic approach. Here’s a practical roadmap to help organizations prepare:
1. Conduct a Risk Assessment of Current Software Assets
Start by generating SBOMs for all software components. Integrate software composition analysis (SCA) scans and SBOM generation directly into your DevSecOps pipeline to ensure comprehensive coverage. Then, integrate these SBOMs into your vulnerability management processes by connecting SBOM data with vulnerability scanners in your pipeline.
Finally, establish incident response plans that incorporate SBOM data by creating automated alerts based on this information that feed directly into your incident response system.
2. Automate Risk Assessment
To maintain compliance over time, regularly update and audit SBOMs to ensure ongoing accuracy and completeness. Implement a policy-as-code approach for automated NIS2 compliance checking, allowing for continuous validation against regulatory requirements.
How Anchore Enterprise Automates NIS2 Compliance
Anchore’s comprehensive SBOM-powered platform provides the tools necessary to meet NIS2 requirements efficiently:
- Automate software composition analysis (SCA) and SBOM generation with AnchoreCTL, making it easy to inventory all software components
- Implement automated vulnerability scanning and management with Anchore Secure, ensuring rapid identification and remediation of security issues
- Generate automated NIS2 compliance evidence with Anchore Enforce, streamlining documentation requirements
- Achieve supply chain transparency, tracking, and management with Anchore SBOM, providing visibility throughout your software ecosystem
Future-Proofing Compliance with Robust SBOM Practices
As the October 2024 deadline for NIS2 implementation has passed, organizations must act quickly to ensure compliance if they haven’t already done so. By implementing a comprehensive SBOM strategy, businesses can not only meet NIS2 requirements but also position themselves advantageously for future regulatory frameworks.
SBOMs provide the foundation for a secure software supply chain, enabling the transparency, vulnerability management, and rapid incident response capabilities that NIS2 demands. With potential penalties including significant fines and personal liability for executives, the stakes for compliance have never been higher.
By adopting SBOM-based practices now, organizations can transform their approach to software security, moving from reactive firefighting to proactive risk management—a shift that aligns perfectly with NIS2’s objectives and the broader evolution of global cybersecurity standards.
Learn about the role that SBOMs for the security of your organization in this white paper.
