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Trust Center Requirements Under NIS2 and DORA
2026-02-22
By Anna Bley

Trust Center Requirements Under NIS2 and DORA

Neither regulation mentions "trust center" by name. Both create requirements that only a structured external proof layer can fulfill.

Trust Center
NIS2
DORA
Compliance

NIS2 and DORA are internal governance regulations. They tell you what security measures to implement, what incidents to report, and what evidence to maintain. They don't prescribe how to communicate your compliance posture externally.

But here's what happens in practice: your customers — especially those who are themselves regulated — need structured, continuous visibility into your security posture. Not because they're curious, but because their own NIS2 and DORA obligations require them to monitor their supply chain. Your trust center is where that monitoring happens.

The Regulatory Logic

NIS2 and DORA don't exist in isolation. They create a cascade of obligations that flows down supply chains.

An essential entity under NIS2 must ensure supply chain security (Article 21(2)(d)). To do that, they need to assess and monitor their vendors. Their vendors aren't directly regulated by NIS2 (unless they're also essential or important entities), but they face a commercial obligation: if you can't demonstrate your security posture to your regulated customers, you lose the contract.

The same logic applies under DORA. Financial entities must manage ICT third-party risk (Articles 28-30). Their ICT service providers need to provide evidence of security measures, incident management capabilities, and business continuity planning — not once, but continuously.

This creates a market-level demand for structured, verifiable, continuously updated external security communication. That's what a trust center does. The regulation creates the need; the trust center is the operational response.

NIS2 Requirements That Create Trust Center Need

Supply Chain Security — Article 21(2)(d)

What the regulation says: Essential and important entities must address "supply chain security, including security-related aspects concerning the relationships between each entity and its direct suppliers or service providers."

What this means for vendors: Your regulated customers must demonstrate to their national competent authority that they monitor their supply chain. They need evidence that their vendors maintain appropriate security measures.

What this requires from your trust center:

  • Structured presentation of your security posture, updated continuously — not a static PDF
  • Frameworks and certifications displayed with scope, validity, and audit dates
  • Subprocessor list with data processing locations and roles — visible, not gated behind a sales conversation
  • Vendor assurance profiles that your customers can reference in their own NIS2 documentation

If your trust center is a document repository that updates once a quarter, it doesn't meet the continuous monitoring expectation. If it provides real-time compliance status with automatically updated evidence, it does.

Incident Reporting — Article 23

What the regulation says: Essential and important entities must submit:

  • Early warning to their CSIRT within 24 hours of becoming aware of a significant incident
  • Incident notification within 72 hours with initial assessment
  • Final report within one month with root cause analysis

What this means for vendors: The reporting obligation falls on the entity, not their supplier. But when the incident originates at or affects a supplier, the entity's reporting timeline starts when they become aware. Delayed awareness means delayed reporting means regulatory exposure.

What this requires from your trust center:

  • Incident communication capability — structured status updates that affected customers receive through the trust center, not via individual emails
  • Severity classification visible to relevant stakeholders
  • Timeline documentation that your customers can reference in their own incident reports to their CSIRT
  • Post-incident evidence (root cause analysis, remediation steps) available through the same channel

This doesn't mean publishing every security incident publicly. It means having a gated communication layer within your trust center that reaches the right stakeholders with structured information within the right timeframes.

Supervisory Powers — Articles 32-33

What the regulation says: National competent authorities can conduct audits, request evidence, and require entities to demonstrate compliance measures — at any time, not just during scheduled audit cycles.

What this means for vendors: If your customer's competent authority (in Germany: the BSI) asks them to demonstrate supply chain security, your customer will turn to you. They need your compliance evidence quickly — not "we'll prepare something for the audit."

What this requires from your trust center:

  • Evidence that is current (today's state, not last quarter's)
  • Evidence that is structured (organized by framework, measure, and control — not a folder of PDFs)
  • Evidence that is retrievable (your customer can pull what they need within hours, not weeks)

DORA Requirements That Create Trust Center Need

ICT Third-Party Risk Management — Articles 28-30

What the regulation says: Financial entities must identify, classify, and manage risks arising from ICT third-party service providers. This includes maintaining a register of all ICT third-party arrangements, conducting due diligence before contracting, and monitoring compliance continuously.

What this means for vendors: If you sell to financial institutions in the EU, your customers must classify you in their ICT third-party register and monitor your security posture. They need structured data about your security measures, business continuity capabilities, and subcontractor chains.

What this requires from your trust center:

  • Security documentation structured around the categories DORA requires financial entities to assess: availability, authenticity, integrity, confidentiality (Article 5)
  • Business continuity and disaster recovery documentation — not just that a plan exists, but evidence of testing
  • Subcontractor chain visibility — DORA requires financial entities to understand the full ICT supply chain, not just the direct relationship
  • Contractual compliance evidence — DORA Article 30 specifies what ICT service contracts must include; your trust center can demonstrate you meet these provisions

Incident Reporting — Article 19

What the regulation says: Financial entities must report major ICT-related incidents to their competent authority, with classification based on impact criteria including data losses, service unavailability, and number of affected clients.

What this means for vendors: When an incident at your end affects a financial entity customer, they need to classify it against DORA's impact criteria. They need your incident data structured, not buried in an email thread.

What this requires from your trust center:

  • Incident communication that provides data financial entities need for their own DORA classification: scope of impact, data categories affected, service availability status, remediation timeline
  • Structured format that maps to DORA reporting templates, reducing your customer's classification burden

Critical ICT Third-Party Provider Oversight — Articles 31-37

What the regulation says: The European Supervisory Authorities (ESAs) can designate ICT third-party providers as "critical" and subject them to direct oversight, including on-site inspections and evidence requests.

What this means for vendors: If you're designated as a critical ICT third-party provider, regulatory authorities may examine your security posture directly. Even if you're not designated as critical, your financial entity customers must demonstrate that they could replace you if needed — which requires understanding your service architecture in detail.

What this requires from your trust center:

  • Sufficient technical documentation for regulators to assess your security posture without requiring a separate audit process
  • Service architecture information that helps financial entities assess concentration risk and exit strategies
  • Evidence of compliance measures that can be presented directly to supervisory authorities

What a NIS2/DORA-Ready Trust Center Must Do

Based on these regulatory requirements, a trust center that serves NIS2- and DORA-affected customers needs five capabilities that go beyond traditional document sharing:

1. Continuous Compliance Status

Static documentation updated quarterly doesn't meet continuous monitoring expectations. The trust center should reflect your current compliance posture — certifications with validity dates, control status that updates when your ISMS updates, evidence that is timestamped and versioned.

2. Structured Vendor Assurance Profiles

Your customers need to include you in their supply chain security documentation (NIS2) or ICT third-party register (DORA). Make this easy: provide structured data about your security measures, certifications, data processing locations, and subcontractor relationships in a format they can reference directly.

3. Incident Communication Channel

Email threads don't scale. When an incident affects multiple customers, you need a structured communication channel within the trust center that provides severity classification, timeline documentation, impact scope, and remediation status — visible to affected stakeholders, gated appropriately.

4. Evidence Retrieval on Demand

If your customer's regulator asks for supply chain evidence, your customer shouldn't need to submit a support ticket and wait. The trust center should make compliance evidence retrievable directly — structured by framework and control, current, and verifiable.

5. Layered Access Controls

Not everything belongs on a public page. Pentest summaries might be NDA-gated. Incident communications might be restricted to affected customers. Framework certifications might be public. A trust center serving regulated industries needs granular access control — public, restricted, NDA-gated, customer-specific — without making the basic information inaccessible.

What This Means for Choosing a Platform

If your customers include essential or important entities under NIS2, or financial entities under DORA, the trust center you choose has regulatory implications — not just for you, but for your customers' compliance posture.

Evaluate the platform against these regulatory requirements, not just against feature lists. A trust center with beautiful analytics and AI questionnaire automation but no incident communication capability, no vendor assurance profiles, and no evidence retrieval — that trust center doesn't serve the market NIS2 and DORA are creating.

Consider data sovereignty in the regulatory context. Your trust center contains compliance evidence that your customers rely on for their own regulatory obligations. If that evidence is stored on infrastructure subject to the US CLOUD Act, your customers inherit that sovereignty risk in their supply chain assessment.

Ask whether the platform treats EU frameworks as primary or secondary. If NIS2 and DORA are afterthoughts in the product experience — available but not prominent — your regulated customers will notice. They're evaluating your compliance maturity, and your trust center is the evidence.

Sources

  1. Directive (EU) 2022/2555 (NIS2 Directive) — Supply chain security (Art. 21(2)(d)), incident reporting (Art. 23), supervisory powers (Art. 32-33).
  2. Regulation (EU) 2022/2554 (DORA) — ICT third-party risk management (Art. 28-30), incident reporting (Art. 19), critical provider oversight (Art. 31-37).
  3. NIS2 Implementation Act Germany (NIS2UmsuCG) — German transposition establishing BSI supervisory authority.

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