EU authorities are intensifying NIS2 compliance enforcement across automotive and logistics operational technology (OT) networks, compelling mid-sized suppliers to invest in private 5G infrastructure, continuous monitoring, and structured supplier risk governance - or face fines and contract exclusion.
NIS2, formally Directive 2022/2555, replaced its predecessor in October 2024 and raises the EU's baseline cybersecurity standards through broader scope, clearer rules, and stronger supervision tools.1NIS2: Understanding the Obligations of Critical Suppliers The directive is particularly consequential for the automotive supply chain: it does not merely target Original Equipment Manufacturers (OEMs) but places direct and indirect obligations on every tier of the supply ecosystem - from Tier 1s to Tier 3s and beyond. For logistics operators, transport and freight companies fall under the directive's Annex I critical sectors, triggering the strictest oversight tier.
Background
Although the number of EU member states that transposed NIS2 into national legislation rose from four to nine as of mid-February 2025, the process has been marked by substantial divergence in adoption timelines and requirements, creating compliance challenges for entities operating across multiple jurisdictions. On 28 November 2024, the European Commission opened infringement procedures against 23 member states that missed the October 2024 transposition deadline. Germany missed the deadline as well; its implementation law - the NIS2UmsuCG - was delayed by federal elections and must now be re-approved by the new Bundestag, with final approval projected for the second half of 2025.
Hungary has imposed particularly strict requirements on its manufacturing sector, the backbone of its economy, especially in automotive and battery manufacturing. In Greece, the National Cybersecurity Authority has scheduled formal audits beginning in Q4 2025. These national-level enforcement actions are widely regarded as the first concrete signals of compliance scrutiny that will spread across the bloc.
The threat environment reinforces regulatory urgency. Ransomware attacks surged across manufacturing in 2025, rising 56% year-over-year to 1,466 incidents and accounting for roughly half of all global attacks - driven by vulnerable legacy OT systems, complex supply chains, and the rapid scaling of ransomware-as-a-service operations, according to Check Point Research. In Q2 2025, global cyberattacks rose approximately 21% versus the same period the prior year, with Europe recording the highest region-level increase, according to Schneider Electric analysis.
Details
Under NIS2, all organizations with more than 50 employees and annual revenues of over €10 million must comply, whether public or private. Key obligations include:
- Board-level cyber risk management and governance
- Supply chain security assessments covering all vendors and service providers
- Incident reporting to national authorities within 24 hours of becoming aware of a significant incident
Sanctions for non-compliance are substantial, with fining powers of up to €10 million or 2% of worldwide turnover and, in some cases, personal sanctions against management and C-suite executives.
Notably, NIS2 applies regardless of whether an organization is directly attacked: if a supplier's security failure affects an essential entity's operations, both parties may face regulatory consequences. OEMs are rapidly reassessing the cybersecurity posture of their supply networks and must demonstrate due diligence and ongoing oversight of third-party cybersecurity risks. This is reshaping procurement: the TISAX framework, developed by the European automotive association ENX, continues to gain momentum as more manufacturers adopt the standard. However, even organizations with active TISAX certification at the highest assurance levels must separately adhere to NIS2's registration, incident management, and reporting requirements.
On the technical side, meeting NIS2's 24/72-hour incident reporting window is practically impossible through manual audits alone, given that legacy OT systems were built for availability rather than logging or alerting. Manufacturers are expected to implement continuous risk management processes tailored to OT environments, including:
- Identifying vulnerabilities in both legacy and modern systems
- Maintaining a detailed inventory of devices and data flows
- Deploying controls such as network segmentation and anomaly detection
Data-driven production systems require wireless connectivity for numerous sensors and mobile assets, making private 5G essential compliance infrastructure - particularly as cyberattacks can cause costly downtime or compromise worker safety. Regulations such as NIS2 mandate defense-in-depth security architectures meeting IEC 62443 standards. Private 5G networks enable manufacturers and utilities to deploy ultra-low-latency communications, autonomous robotics, predictive maintenance systems, and real-time industrial analytics within controlled environments. However, private 5G delivers strong built-in protections only when paired with governance: factories adopting private 5G must also strengthen identity management, SIM and eSIM lifecycle handling, OT-IT segmentation policies, and anomaly detection.
The private 5G market is projected to reach USD 17.55 billion by 2030 from USD 3.86 billion in 2025, at a CAGR of 35.4%, according to MarketsandMarkets. The manufacturing sector holds the largest share of this market, driven by Industry 4.0 adoption and the need for real-time automation.
NIS2 envisions a European certification scheme - currently under development - for cloud services, 5G, consumer IoT, and industrial infrastructures; the industrial infrastructure scheme is likely to be based on or derived from ISA/IEC 62443. ENISA has released updated resources mapping NIS2 obligations to global cybersecurity frameworks such as ISO/IEC 27001, NIST CSF, and IEC 62443, offering a clearer picture of what practical implementation looks like in OT/ICS environments.
Outlook
For many small and mid-sized suppliers, meeting NIS2 requirements presents significant challenges given limited resources, lack of in-house expertise, and operational complexity. While implementation remains uneven across EU member states, organizations that adopt best practices now will be better positioned as enforcement tightens. ENISA forecasts a 40% increase in collaborative audits by 2026, according to its Prospective Study 2025 - meaning suppliers across automotive and logistics value chains face not only their own regulators but also OEM-initiated third-party audits as a condition of continued engagement.
