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Compliance · Medium and large entities in 18 critical sectors across the EU, such as energy, transport, health, finance, digital infrastructure and public administration, as set out in each member state's national law. Member states may also cover some smaller entities.

NIS2 and field work.

NIS2 Directive (Directive (EU) 2022/2555)

General information, not legal advice. Last reviewed October 27, 2026.

Quick answer

How does NIS2 touch field work?

NIS2 is the EU cybersecurity directive that requires covered organizations to manage cybersecurity risk, including risk from suppliers, and to report significant incidents. For on-site IT work, a covered customer may require its field services provider to follow access, supply chain and incident reporting rules in the contract, and some IT service providers can be covered directly under national law.

What is NIS2?

NIS2 is Directive (EU) 2022/2555 on measures for a high common level of cybersecurity across the Union. It came into force in January 2023 and repealed the earlier NIS Directive from 18 October 2024. Because it is a directive, it takes effect through national laws, not directly on companies.

Member states had to transpose NIS2 by 17 October 2024, and transposition has been uneven. On 8 July 2026 the European Commission decided to refer Ireland, Spain, France and the Netherlands to the Court of Justice of the EU for not having notified full transposition, after sending reasoned opinions to 19 member states in May 2025. Check the national law of each country where your sites are, because registration steps and details differ.

Covered entities must address a minimum set of risk management measures. They include incident handling, supply chain security, access control, asset management and security for the physical environment of their systems. They must send an early warning of a significant incident within 24 hours of becoming aware of it, an incident notification within 72 hours and a final report within one month after the notification. Senior management can be held accountable.

Member states must set maximum fines of at least EUR 10 million or 2 percent of worldwide annual turnover for essential entities, and at least EUR 7 million or 1.4 percent for important entities, whichever is higher.

NIS2 also covers managed service providers, meaning providers of installation, management, operation or maintenance of ICT products, networks, infrastructure or systems through assistance or active administration on customers' premises or remotely. Whether a particular field services firm falls in scope depends on what it does, its size and the national law of the country concerned.

How it touches on-site IT work

  • Suppliers are part of the customer's risk: a covered customer must address cybersecurity risk in its supply chain, which includes the firms that send engineers to its sites. Expect security clauses in contracts, supplier questionnaires and questions about subcontractors.
  • Physical and logical access: covered customers are expected to control access to the rooms and equipment that hold their systems, including access by external suppliers. For field work this usually means named engineers, ID checks at the door, escorts where needed, time-limited access and a record of who entered which room.
  • Asset handling: customers must manage their assets, so installs, moves, swaps and removals need accurate records, labels and a log of what left the site.
  • Incident reporting: the customer's 24-hour and 72-hour clocks start when it becomes aware of a significant incident. A provider that notices tampered equipment, an unknown device in a rack, lost media or an unexplained outage needs to tell the customer quickly through an agreed route.
  • Personnel: customers may ask how a provider screens, trains and assigns the people who attend their sites.
  • Records: change records, work notes and photos that show what was done give the customer evidence for its own audits and incident reviews.

What you can agree in a written scope

  • Security clauses that match the customer's supplier security policy, written into the contract or the scope.
  • Named personnel or a named pool of engineers, with the customer's right to approve or refuse an individual.
  • A rule on subcontractors: approval before use, and the same security terms passed down.
  • Physical access rules: ID checks, escorts, time windows, badge handling and what happens at the end of a visit.
  • An incident notification route and a target time that fits inside the customer's own 24-hour and 72-hour obligations.
  • Evidence the provider will supply after each visit, such as work notes, asset records and photos, and how long they are kept.
  • The customer's right to ask reasonable security questions and to review the answers.
  • Return or secure disposal of customer assets, media and data when the work or the engagement ends.

Questions to ask any field services provider

  • Do you consider yourself in scope of NIS2 in any country where you operate, and in which category?
  • How do you screen and brief the people you send to our sites?
  • Which parts of the work are done by subcontractors or independent engineers, and how are they bound by our terms?
  • How and how fast will you tell us if you spot a security event on site?
  • How do you control and record physical access to our rooms and equipment?
  • What evidence do you give us after each visit, and how long do you keep it?
  • Can you answer our supplier security questionnaire?

This page is general information and not legal advice. Deploris does not claim certification or compliance status here. Confirm what applies to you with your own counsel or compliance team.

Official sources

QUESTIONS

Common questions.

Is NIS2 a law or a directive?
NIS2 is an EU directive, so it takes effect through the national law of each member state rather than directly. Details such as who must register and which authority supervises differ by country. Check the national law where your sites are located.
Does NIS2 apply to an IT field services provider?
It can, depending on what the provider does, its size and the national law. NIS2 lists managed service providers as a covered category, and a covered customer will in any case pass security requirements to its suppliers by contract. Ask the provider directly how it assesses its own position and confirm with counsel.
What incident reporting deadlines does NIS2 set?
Covered entities must send an early warning within 24 hours of becoming aware of a significant incident, an incident notification within 72 hours and a final report no later than one month after the notification. These deadlines apply to the covered entity. A customer therefore usually asks its field services provider for a shorter internal reporting time.
Has every EU country adopted NIS2?
No. On 8 July 2026 the European Commission said Ireland, Spain, France and the Netherlands still had to notify full transposition and referred them to the Court of Justice of the EU. The position can change, so check the Commission's transposition page and the national authority for the country you care about.
What can a customer ask a field services provider for under NIS2?
A customer can ask for supplier security terms in the contract, including named personnel, access rules, subcontractor controls, incident reporting times and records of work. These requests follow from the customer's duty to manage supply chain risk. Put them in the written scope so both sides know what is expected.

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