Scorecard
The NIS2 supplier scorecard
Twenty yes/no questions mapped to NIS2 articles 20, 21, and 23: the ones a regulated customer's questionnaire will ask a startup supplier.
I'm starting to see NIS2 reach startups through their customers, not through a regulator. Entities in scope have to manage the security of their suppliers (art. 21(2)(d) and 21(3) Directive (EU) 2022/2555). That duty turns into the security questionnaire on a startup's desk. These twenty questions follow the directive's own list. A yes counts only when the evidence exists today.
From the talk: NIS2 for startup engineers: what to build first
The twenty questions
Each yes scores one point.
- 1.Do the founders sign off a one-page risk register at least once a year? Risk analysis, art. 21(2)(a).
- 2.Do we have a written security policy that management approved? Art. 21(2)(a) and art. 20(1).
- 3.Do security alerts page a named person, day and night? Incident handling, art. 21(2)(b).
- 4.Does our incident runbook name who decides whether an incident is significant? Art. 21(2)(b) and art. 23(3).
- 5.Do we encrypt backups and copy them to an isolated account with deletion protection? Backups and continuity, art. 21(2)(c).
- 6.Have we restored from backup, and timed it, in the last six months? Art. 21(2)(c).
- 7.Do we keep a register of critical suppliers and what each one can reach? Supply chain security, art. 21(2)(d).
- 8.Do we check a new critical supplier's security before we sign? Art. 21(2)(d) and art. 21(3).
- 9.Do we define infrastructure in code and review every change? Secure development, art. 21(2)(e).
- 10.Do dependency and secret scanning run on every change? Art. 21(2)(e).
- 11.Do we follow a patch cadence and keep a record of it? Vulnerability handling, art. 21(2)(e).
- 12.Do we check every quarter that the controls work, and file the results? Testing effectiveness, art. 21(2)(f).
- 13.Does every staff member take security training at least once a year, with a record? Cyber hygiene and training, art. 21(2)(g).
- 14.Has the management body taken security training? Art. 20(2).
- 15.Do we encrypt data at rest and in transit everywhere, with keys we control? Cryptography, art. 21(2)(h).
- 16.Does every human sign in through single sign-on, with least-privilege roles? Access control, art. 21(2)(i).
- 17.Do we generate an inventory of accounts, identities, and data stores from the cloud APIs? Asset management, art. 21(2)(i).
- 18.Do we enforce MFA on every human account? Art. 21(2)(j).
- 19.Do admins use phishing-resistant MFA, such as passkeys or hardware keys? Art. 21(2)(j).
- 20.Could we send an early warning within 24 hours of becoming aware of a significant incident? Reporting, art. 23(4)(a).
What the score means
| Score | Where we stand |
|---|---|
| 18 to 20 | A regulated customer's questionnaire takes days, not weeks. The work now is keeping the evidence current. |
| 14 to 17 | Most answers are there. The gaps usually sit in incident reporting and supplier checks. |
| 0 to 13 | I'd start with identity and guardrails (questions 16 to 19). They're the gap an attacker reaches first and the first question on every questionnaire. |
What I leave out on purpose
I leave out a full identity governance platform, a privileged access management suite, and a zero-trust network rebuild. Single sign-on, MFA, and no long-lived keys close most of the risk at a fraction of the cost. The bigger tools can come once the basics hold.
Next step
Under 14? I highly recommend a thirty-minute call with your cloud console on screen. I'll show which three gaps a regulated customer will spot first. Which question was hardest to answer with evidence?
Book a callThese takeaways are an engineer's reading of the rules and the tools. I wrote them to help teams decide what to build. They aren't legal advice. I recommend checking the current text with your own counsel before planning around a date or a threshold.
Other takeaways from this talk
Runbook template
24-hour incident runbook
A one-page incident runbook with the NIS2 and GDPR reporting clocks side by side, roles, a decision tree for significant, and a drill.
Answer bank
Questionnaire answer bank
Thirty supplier security questions with model answers and the evidence behind each one, so the next questionnaire starts from proof.
Let's talk.
A 30-minute call, no pitch. We look at your current setup, your stage, and the thing that's bothering you about it. I give a straight opinion on what to change, what to leave alone, and whether the problem is the one it looks like. What's the one thing in your stack you'd fix tomorrow?
Prefer email or phone? hello@netninjas.eu or +31 6 45984313