Third-Party & Supply Chain Risk

Third-party risk management for NIS2 and DORA

Supply-chain obligations are now law — NIS2 Article 21 and DORA Articles 28–44. Inventory, assess and continuously monitor your ICT suppliers on Panorays.

Third-party risk management is the identification, assessment and monitoring of cybersecurity risk in your suppliers. NIS2 Article 21 and DORA Articles 28–44 make it a legal obligation — not a best practice. Passeca inventories your ICT vendors, maps the regulatory obligations, assesses each supplier on the Panorays platform, embeds the required contractual clauses, and monitors continuously.

The regulation

Supply-chain risk is now a legal obligation

Two EU regimes introduce specific supply-chain risk management requirements for organisations within their scope.

NIS2 — Article 21

Supply-chain security for essential and important entities

NIS2 requires entities to implement cybersecurity risk-management measures that cover their supply chain and suppliers — including the risk at each direct supplier and the security-related practices of the entities themselves. Failure is a compliance breach with fines up to €10m or 2% of global turnover.

DORA — Articles 28–44

ICT third-party risk for financial entities

DORA requires financial entities to maintain a register of information on all ICT arrangements, conduct due diligence, embed contractual clauses, define exit strategies, and monitor critical ICT providers continuously. Critical providers are also brought under direct ESA oversight.

For most other frameworks — ISO 27001, SOC 2, HIPAA — supplier risk is a control requirement too. Passeca builds a single programme that satisfies all of them, with Panorays as the monitoring engine.

Definition

What is third-party risk management?

Third-party risk management (TPRM) is the discipline of identifying, assessing, treating and monitoring the cybersecurity risk that suppliers and service providers introduce into your organisation. It covers every ICT supplier with access to your data, systems or network — from cloud platforms and SaaS tools to managed-service providers and offshore development partners.

It matters because the boundary of your organisation is no longer the boundary of your risk. A supplier's breach becomes your breach, a supplier's exposure becomes your exposure, and a supplier's outage becomes your outage. NIS2 and DORA now make managing that risk mandatory; ISO 27001, SOC 2, HIPAA and PCI DSS all require it as a control. Passeca delivers TPRM as a continuous programme on the Panorays platform.

Requirements

What does third-party risk actually require?

A defensible TPRM programme covers the full supplier lifecycle, from onboarding to offboarding, and keeps the risk picture current rather than annual.

  • Inventory and criticality — a complete register of ICT suppliers, scored by criticality and the data or systems they can reach.
  • Due diligence — assess each critical vendor's security posture before and during the relationship.
  • Contractual clauses — security, breach-notification, audit and exit requirements written into the contract (DORA, data-protection terms).
  • Continuous monitoring — a live risk score per supplier that updates as external posture and breach history change.
  • Concentration risk — awareness of dependency on a small number of providers, especially critical ICT providers.
  • Exit and remediation — a plan for when a vendor fails its assessment or a relationship must end.
  • Register of information — the DORA-mandated structured record, produced to authorities on request.
The platform

Panorays — the monitoring engine

From a slow, manual questionnaire to a live risk score per supplier.

Panorays automates third-party risk assessment by combining external cyber-posture data, questionnaire-based control validation and continuous monitoring into a single risk score per supplier. Passeca implements and operates Panorays so a vendor-review process that used to take weeks per supplier runs continuously across the whole estate — and feeds straight into your NIS2 and DORA evidence.

Continuous
monitoring, not annual
Per-vendor
live risk score
Automated
questionnaires + posture
NIS2 / DORA
evidence-ready
The engagement

How Passeca runs a third-party risk programme

  1. 01

    Vendor inventory & criticality

    We inventory your ICT suppliers and score their criticality — the starting point for both NIS2 and DORA. The inventory provides a foundation for the DORA register of information, where applicable.

  2. 02

    Regulatory mapping

    We map each critical vendor to the obligations that apply — NIS2 supply-chain security, DORA Article 28–44 for financial entities, ISO 27001 supplier controls — so you know exactly what each relationship requires.

  3. 03

    Risk assessment on Panorays

    We deploy Panorays to assess each vendor automatically — external posture, questionnaire-based controls and continuous monitoring — turning a slow, manual process into a live risk score per supplier.

  4. 04

    Contracts & remediation

    We embed the required contractual clauses (DORA, data-protection terms), flag the vendors that fail their assessment, and drive remediation with the supplier or an exit strategy where remediation fails.

  5. 05

    Continuous monitoring

    We keep Panorays running so a vendor's risk score updates as its external posture and breach history change — alerting you before a supplier compromise becomes your incident.

Deliverables

What you get from the engagement

A complete ICT vendor inventory scored by criticality
A regulatory-obligations map (NIS2, DORA, ISO 27001) per vendor
Panorays deployed and configured for your estate
A live risk score per supplier, continuously updated
A DORA register of information, production-ready
Contractual clause library for critical ICT providers
Concentration-risk analysis across your supply chain
Remediation and exit strategies for failing vendors
Comparison

Manual questionnaires vs continuous monitoring

Why a point-in-time questionnaire is no longer enough.

 Manual questionnairePanorays (continuous)
Assessment depthSelf-reportedPosture + controls
CadenceAnnualContinuous
Detects supplier breach
External posture data
Effort per supplierHighLow
Scales to 100s of vendors
DORA / NIS2 evidence-readyManual export

Manual questionnaires capture what a supplier claims at a point in time. Panorays combines supplier-provided information with external security data to support ongoing monitoring and NIS2 and DORA compliance efforts.

FAQ

Third-party risk, answered

The questions buyers ask when NIS2 or DORA makes supply-chain risk mandatory.

What is third-party risk management?
Third-party risk management is the process of identifying, assessing and monitoring the cybersecurity risk your suppliers and service providers introduce into your organisation. It exists because most breaches now involve a supplier in the chain — and because NIS2 and DORA now make supply-chain risk a legal obligation, not a best practice.
What do NIS2 and DORA require for supply-chain security?
NIS2 Article 21 requires essential and important entities to manage cybersecurity risk across their supply chain and suppliers. DORA Articles 28–44 require financial entities to maintain a register of information on all ICT arrangements, conduct due diligence, embed contractual clauses, and monitor critical providers continuously. Both make the failure to manage supplier risk a direct compliance failure.
What is the DORA register of information?
The register of information (Article 28) is a structured record of every ICT third-party arrangement a financial entity has — provider, services, criticality, contractual details and concentration risk. It must be produced to authorities on request and kept current. Passeca builds and maintains it, on Panorays where appropriate.
What is Panorays and why does Passeca use it?
Panorays is a third-party risk-management platform that automates supplier assessment — combining external cyber-posture data, questionnaire-based control validation and continuous monitoring into a live risk score per supplier. Passeca implements and operates Panorays so a slow, manual vendor-review process becomes continuous and scalable.
How is third-party risk different from vendor management?
Vendor management is the procurement and contract function. Third-party risk management is the cybersecurity assessment and monitoring of those vendors — scoring the risk each supplier introduces and keeping it current. They overlap but are distinct; Passeca covers the risk side, working with your procurement team.
How often should third-party risk be assessed?
Continuously, not annually. A vendor's risk can change overnight with a breach or a new exposure, so a point-in-time questionnaire is quickly stale. Passeca runs the formal assessment on a cycle but keeps the Panorays risk score live between cycles, alerting you when a supplier's posture degrades.
Does ISO 27001 cover third-party risk?
Partly. ISO 27001 includes supplier-relationship controls (A.5.19–A.5.23 in the 2022 revision), but it is a control baseline, not a supplier-monitoring programme. NIS2 and DORA go further by requiring continuous monitoring and, for DORA, a detailed register of information. Passeca layers the regulatory requirements on top of the ISO 27001 baseline.
How much does a third-party risk programme cost?
Cost has two components: Panorays licensing (set by Panorays, scaled by the number of suppliers monitored) and Passeca's consulting to inventory, assess and remediate. The vendor inventory and criticality scoring are the largest effort components.
Always-on defence

Can you produce your register of information?

Book a free scoping call. We will inventory your ICT suppliers, map the NIS2 and DORA obligations, and stand up Panorays so your supply-chain risk is live — not last year's questionnaire.