The Cybersecurity Act V2 (CSA V2), expected to be fully implemented by 2027, will fundamentally change how European organizations manage their ICT supply chains. For CISOs, this means mandatory vendor risk assessments must include ownership structure and country-of-origin analysis, not just technical security controls.
Starting in 2027, organizations classified as essential or important under NIS2 will be prohibited from using ICT components from designated high-risk suppliers in critical infrastructure. Mobile network operators have 36 months to replace affected equipment; other sectors will follow.
The immediate impact: procurement processes need updating, existing vendor relationships require auditing, and replacement roadmaps must be developed. Organizations with significant exposure to potentially affected suppliers (currently ~32% of 5G infrastructure in the EU) face substantial transition costs.
CISOs should act now: map your supply chain exposure, implement enhanced vendor due diligence incorporating non-technical risk factors, and align replacement cycles with the transition timeline. Early preparation minimizes disruption and positions your organization ahead of mandatory compliance deadlines.
Recommended advisory: PAC Leadership Session – Cybersecurity Compliance
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