Operationalising NIS2 Supply Chain Requirements: A Compliance Framework based on Microsoft 365 Purview

Digital supply chains have become a major pathway for cyber risk, as organisations rely on cloud services, managed service providers, software components, and tightly coupled data flows. Compromise of an upstream vendor can propagate quickly and create downstream impact across multiple sectors and jurisdictions. The EU’s NIS2 Directive responds to this systemic exposure by expanding sectoral scope, strengthening governance duties, and harmonising baseline risk-management and incident reporting requirements across Member States. This paper analyses the NIS2 obligations most relevant to supply chain security, with emphasis on risk-management measures under Article 21, incident reporting under Article 23, and the accountability model that places oversight responsibilities on management bodies. Building on recent implementing rules for selected digital infrastructure and providers, the paper proposes an operational compliance approach that integrates supplier assurance, evidence-based controls, and continuous monitoring. A practical case study illustrates how organisations can translate legal duties into implementable controls and auditable governance artefacts, including mappings to widely used security standards and enterprise compliance tooling. The analysis argues that effective NIS2 compliance requires treating supplier relationships as a managed security domain, not a procurement afterthought.