Since the last decade (and sometimes even earlier), we have seen the industry pivot from "trusted" handshake deals to a dimension where a single unvetted library in a sub-vendor's firmware can bring a global enterprise to its knees. In fact most of the breaches today are occurring due to weak links that overwrite the power of stronger controls to essentially increase risk exposure and create points of failure that are exploited by threat actors. As we have seen with the recent Adidas breach, even weak third-party controls can impact the most secure data fortresses that businesses have built over the years.

The message is more than clear. We all need to take a hard look at discovering and mitigating  risks and security gaps that are hidden within the infrastructure, networks or the processes associated with operations.   

The European Commission’s Toolbox to improve ICT supply chain security, adopted by the NIS Cooperation Group on February 13, 2026 is an important step in this direction. It isn't just another PDF to archive. It is a strategic pivot. It provides a common, structured approach for identifying and mitigating the "all-hazards" risks that have come to define our modern digital ecosystem.

Before we take a look at this toolkit, don’t forget to check out our previous blog post on “AI and NERC CIP-015: Automating Anomaly Detection in Critical Infrastructure” here.

What’s lies under the Hood? The Toolkit Breakdown

The Toolbox is a comprehensive and granular framework designed to help EU Member States and private entities align with the NIS2 Directive (specifically Articles 21 and 22). It moves well beyond technical checkboxes while focusing on a holistic lifecycle that runs all the way from design and procurement to maintenance and decommissioning. It is a ready reference document that can be used to inform your OT/ICS risk management approach and beyond.

Risk scenarios and assessments

The kit provides a baseline for evaluating supply chain vulnerabilities that have the potential to impact operations. It identifies four primary risk drivers:

• Malicious action: Intentional compromise by state actors or cybercriminals.

• System failure: Critical dependencies that could lead to cascading outages.

• Human error: Configuration drifts and lack of security-by-design.

• External events: Geopolitical shifts or natural disasters impacting availability.

Strategic recommendations  

• Scrutiny of High-Risk Suppliers (HRS): A framework for identifying and, if necessary, restricting vendors based on non-technical risk factors, such as foreign interference or weak legal frameworks in their home jurisdictions. HRS is a growing concern not just for critical infrastructure operators but also regular businesses that have OT systems managing processes and operations.

• Multi-vendor strategies: Promoting diversification to avoid the "single point of failure" trap and vendor lock-in. Such an approach enables a more resilient supply chain that is secure and disruption proof.

• Lifecycle integrity: Recommendations for maintaining security throughout the product lifespan, including strict requirements for maintenance access and firmware updates. Eliminating or even rationalising HRS exposure can also feed into improving the lifecycle integrity of products.

Vertical deep dives

The 2026 release includes two critical sector-specific risk assessments:

• Connected and Automated Vehicles (CAV): Addressing the weaponization potential of mobility data across scenarios.

• Detection equipment: Focus on security hardware at border crossing points where vendor dominance can lead to strategic dependencies.

How enterprises benefit: Moving from compliance to resilience

For the modern CISO or CTO, this toolbox is more than a simple regulatory sermon. Instead it is a manual for building a defensible industrial posture.

• Board-level clarity: By aligning with an EU-wide standard, ICT leaders can translate abstract supply chain threats into business risks that boards actually understand and is willing to act upon.

• Procurement leverage: Use the toolbox’s "High-Risk Supplier" criteria and security-by-design requirements as leverage during contract negotiations to ensure vendors provide Software Bill of Materials (SBOMs) and transparency.

• Operational continuity: The focus on "all-hazards" means your business isn't just protected against hackers, but also against the sudden insolvency or geopolitical removal of a key service provider.

• Simplified NIS2 alignment: The toolbox maps directly to the upcoming enforcement cycles, reducing the "compliance tax" for enterprises operating across multiple EU borders.   

The "so what?" for decision makers

If you are still managing your supply chain risks via spreadsheets and "standard" indemnity clauses, you’re behind. The EU’s guidance suggests that trust must be verified, not assumed. Implementing these measures now creates a competitive advantage: you aren't just selling a product; you're selling a resilient service that is immune to the next global supply chain contagion.

Specific assets for implementation assistance

To bridge the gap between EU policy, OT security governance and plant-floor execution, I recommend referencing these specific industry playbooks and guides:

• IEC 62443 and NIS2 Compliance Checklist – A pragmatic tool for mapping international standards to EU mandates.

• NIS2 Master Checklist for OT Operators – Strategic guidance for those managing critical infrastructure.

• NIS2 Audit Report Template – Streamline evidence collection for your next regulatory inquiry.

Reference eBooks:

• The Ultimate OT Security eBook – A deep dive into protecting the cyber-physical backbone.

• OT & Industrial IoT Security: Key Challenges and Fixes – Essential reading for understanding the 2026 threat landscape.

• SCADA Guide for OT/ICS Security – Technical controls for legacy and modern control systems.