Accelerating NIS2 enforcement across the European Union is compelling automotive manufacturers and logistics operators to adopt open cybersecurity standards for operational technology (OT), reshaping vendor selection, supply chain governance, and remote access practices. The NIS2 Directive (EU 2022/2555) came into force in January 2023, with Member States required to transpose it into national law by October 17, 2024, though implementation across the bloc remains uneven and continues to evolve into 2025 and 2026.
Background
NIS2 replaces its predecessor NIS1, expanding the directive's scope to cover 18 critical sectors, including transport, critical product manufacturing, and logistics-sectors not previously subject to the same obligations. The directive applies to organizations with more than 50 employees and annual revenues exceeding €10 million operating in those sectors, according to the European Commission. An estimated 350,000 organizations across the EU are subject to NIS2, according to Cisco.
For the automotive sector, the stakes are particularly high. NIS2 does not merely target original equipment manufacturers (OEMs); it places direct and indirect obligations on every level of the supply ecosystem-from Tier 1s to Tier 3s and beyond, according to PECB Insights. IT/OT convergence on factory floors and in logistics hubs has broadened the threat surface, while global cyberattacks rose approximately 21% in Q2 2025 versus the same period the prior year, with Europe recording the highest region-level increase, according to Schneider Electric's industrial security analysis.
Transposition of NIS2 into national law has been fragmented. As of mid-2025, 13 out of 27 EU Member States had not yet implemented NIS2 into local law, prompting infringement proceedings from the European Commission, according to law firm Skadden, Arps, Slate, Meagher & Flom. Germany's national NIS2 implementation act is expected to take effect in the second half of 2025, while France remains in the legislative process, according to Greenberg Traurig. On January 20, 2026, the European Commission proposed targeted amendments to NIS2 to increase legal clarity and ease compliance burdens, specifically citing relief for 28,700 companies, including 6,200 micro and small-sized enterprises, according to the Commission's digital strategy portal.
Details
For OT-heavy sectors, open standards have emerged as the primary compliance pathway. IEC 62443, the global standard for Industrial Automation and Control Systems (IACS) security, maps directly to NIS2's core requirements, including risk-based security measures, supply chain security, incident notification, access control, and operational continuity, according to HMS Networks and DNV Cyber. IEC 62443-2-1 covers security program requirements for IACS asset owners, while Part 4-2 sets technical security requirements for components such as PLCs, HMIs, and SCADA systems, according to INTECH Automation & Intelligence. On the corporate IT layer, ISO/IEC 27001 provides a complementary framework for information security management, and automotive-specific standard ISO/SAE 21434 addresses secure development lifecycle and supplier risk management for OEMs and their supply chains, according to Deloitte and PECB Insights.
On remote access-a critical control point in automotive and logistics environments-NIS2 mandates multi-factor authentication (MFA) and zero-trust network principles. Industrial organizations frequently provide remote access to suppliers for maintenance and upgrades, which represents the most commonly exploited attack vector for OT environments, according to Cisco's industrial operations guidance. NIS2 explicitly calls for zero-trust principles and network segmentation, including isolating OT zones by function-for example, preventing welding equipment in an automotive plant from communicating with paint shop systems, according to Cisco.
Supply chain risk management is proving to be among the most demanding NIS2 obligations. The directive requires in-scope entities to incorporate cybersecurity risk-management measures into contractual arrangements with direct suppliers and service providers, including audit rights, defined incident reporting SLAs, and evidence of security practices, according to DLA Piper's NIS2 supply chain analysis. ENISA published technical implementation guidance in June 2025, supplementing the EU Commission's Implementing Regulation 2024/2690, providing practical advice on how security requirements should be evidenced during audits, according to Skadden. Vendor selection criteria are shifting accordingly, with procurement teams embedding NIS2 and IEC 62443 alignment as mandatory qualification criteria for industrial suppliers and system integrators.
SMEs in automotive and logistics supply chains face a distinct compliance burden. Although NIS2 does not impose direct legal obligations on SMEs below the size thresholds, larger in-scope entities are contractually compelling their suppliers to meet equivalent security standards, according to DIESEC and CyberTrust365. Research by the European Cyber Security Organisation (ECSO) notes that medium-sized enterprises directly in scope face disproportionate resource allocation challenges compared to larger organizations, creating asymmetric compliance pressures across cross-border supply chains. One 2025 study found that almost six in ten SMEs in the Belux region were unaware whether NIS2 applied to them, despite the directive having been in force since October 2024, according to DIESEC.
Outlook
With ENISA's June 2025 technical guidance now published and national enforcement accelerating, organizations that have not yet mapped OT controls to NIS2 obligations face growing audit and penalty risk. Non-compliance can result in fines of up to €10 million or 2% of global annual turnover, whichever is higher, and management bodies can face personal liability or temporary disqualification from leadership roles, according to Greenberg Traurig. Reporting obligations vary across Member States-for example, Cyprus requires early warnings within six hours of detection, well ahead of NIS2's 24-hour standard, underscoring the compliance complexity for cross-border automotive and logistics operators managing multi-jurisdiction OT estates.
