18 April 2027 may still seem distant on the calendar, but for Managed Service Providers (MSPs) and their extensive web of subcontractors and suppliers, the countdown toward NIS2 Directive compliance in Belgium has already begun. As critical players in the digital infrastructure supply chain, MSPs face both direct regulatory obligations and indirect pressure to ensure their service ecosystem aligns with NIS2 cybersecurity requirements.
The NIS2 Directive not only elevates cybersecurity standards across the EU but also expands the scope of regulatory oversight to include MSPs and Managed Security Service Providers (MSSPs). Belgium’s firm compliance deadline means proactive preparation must start immediately—not only to avoid legal risks but to remain competitive in a shifting digital trust landscape.
Even when you are not a important or essential NIS2 entity your organisation may fall into the supply chain of a NIS2 entity and be faced with the obligation to implement cybersecurity risk-management measures because of a contractual requirement. NIS2 entities indeed have the obligation to insure the security of their supply chain, including security-related aspects concerning the relationships between each entity and its direct suppliers or service providers.
In this context, the Centre for Cybersecurity Belgium advises all organisations that may find themselves in the supply chain of a NIS2 entity, to at least comply with the measures set out in the CyberFundamentals (CyFun®) Framework level Basic. A NIS2 entity could theoretically impose the compliance with a certain CyFun® level onto its direct suppliers or service providers.
1. Urgency: Why Action is Needed Now
The March 2027 deadline is the formal enforcement point, but effective NIS2 compliance hinges on maturity, operational readiness, and demonstrable implementation—none of which happen overnight. Many MSPs and their supply chain actors are still in the early stages of awareness, let alone implementation.
Delaying action risks:
- Failing regulatory audits or sector supervision,
- Losing client trust or contracts requiring NIS2 assurance,
- Being excluded from procurement pipelines seeking certified providers.
2. Immediate Action Areas for MSPs and Their Supply Chain
1. Conduct a Full NIS2 Readiness Gap Assessment
MSPs must evaluate their current state of cybersecurity, governance, risk management, and incident response capabilities. This includes:
- Mapping existing controls to NIS2 Articles and national implementation law.
- Identifying maturity gaps in detection, response, resilience, and supply chain oversight.
2. Extend Risk Management Obligations to Your Suppliers
Under NIS2, third-party risk management is a binding requirement—not optional. MSPs must:
- Assess cybersecurity maturity across their subcontractors and partners.
- Mandate minimum security standards and contractual clauses aligned with NIS2.
- Monitor supplier compliance regularly through audits or security assessments.
3. Formalize Incident Reporting and Business Continuity Plans
MSPs and their ecosystem need:
- Incident classification and notification protocols.
- Escalation timelines (e.g., 24-hour initial notice, full report in 72 hours).
- Business continuity and disaster recovery plans validated through simulation or tabletop exercises.
4. Prepare for Certification Requirements
Belgium’s NIS2 implementation foresees sectoral supervision and potentially formal certification schemes—especially for critical ICT services. Start early:
- Align ISMS or SOC 2 frameworks with NIS2 controls.
- Engage certification bodies or external consultants for pre-audits.
- Consider ISO 27001:2022 or ENISA’s anticipated MSSP certification as future-proof pathways.
5. Join Information Sharing and Cybersecurity Collaboration Networks
Only 26% of ICT service providers currently participate in information-sharing initiatives, per ENISA’s 2024 report. Proactively:
- Join national CSIRT exchanges and EU-wide ISACs.
- Build public-private collaboration capacity to respond collectively to sector-wide threats.
6. Strengthen Internal Governance and Board-Level Awareness
Cyber governance must move to the executive level. MSPs should:
- Designate a NIS2 Program Owner.
- Embed NIS2 compliance and cybersecurity KPIs into corporate performance reviews.
- Train senior leadership and board members on their legal responsibilities under NIS2.
3. Why Subcontractors Can’t Remain Passive
Many tier-2 and tier-3 ICT service providers, who operate under MSP umbrellas, mistakenly assume they fall outside NIS2’s scope. That is no longer true:
- MSPs will be contractually obligated to demand cybersecurity guarantees from their partners.
- Subcontractors not ready to comply risk being removed from supply chains or facing business continuity impacts.
4. Final Thoughts: Compliance is a Journey, Not a Deadline
March 2027 may be the date etched in law—but cyber maturity cannot be rushed. Forward-looking MSPs are already building NIS2-aligned security cultures, governance frameworks, and risk-aware ecosystems.
Those who act early will not only meet regulatory expectations, but also build lasting trust with clients, partners, and regulators in a digital age where cyber resilience is competitive advantage.
Call to Action
✅ Start your NIS2 Gap Assessment now.
✅ Engage your supplier network early.
✅ Align your ISMS or security framework with NIS2 requirements.
✅ Prepare your organization for future audits and certification readiness.
✅ Don’t wait for 2027—build compliance into your operations today.
