The Critical Entities Resilience (CER) Directive places strict demands on critical infrastructure operators across the EU. One of the core requirements is the ability to report on compliance, both internally and to supervisory authorities. The supply chain is explicitly identified as a key area of risk. In this article, we explore how critical entities can build compliant reporting practices and which best practices to apply for managing third-party risks.
Critical entities must:
Conduct risk assessments, including supply chain risks,
Develop and maintain a resilience plan,
Report significant incidents to national authorities,
Demonstrate the implementation of appropriate technical and organizational measures – including those applied to suppliers and contractors.
In practice, this means organizations need a systematic, verifiable approach to monitoring, logging, auditing, and documentation.
Start by identifying which suppliers and subcontractors have a direct or indirect impact on your critical operations. Classify them based on:
Criticality to your services,
Geographic exposure (e.g., non-EU entities),
Security posture (e.g., IAM maturity, certifications).
Use frameworks like NIST Cyber Supply Chain Risk Management or ISO/IEC 28000 to guide your classification process.
Integrate CER-specific requirements into your procurement contracts, such as:
Mandatory incident reporting within 24 hours,
Periodic security audits,
Access to audit logs or security assessments.
Actively verify compliance through vendor security assessments, penetration testing, or automated compliance scanning tools.
Third-party access to physical infrastructure or digital systems should be managed centrally through Identity & Access Management (IAM). Recommended measures include:
Time-bound access based on job role or contract duration,
Logging of physical access using smart key systems like ASSA ABLOY CLIQ or iLOQ,
Automated provisioning and deprovisioning via platforms like Key2XS.
This significantly reduces the risk of unauthorized access and supports full traceability for compliance reporting.
Ensure you can produce CER-aligned reports quickly and accurately. These reports should include:
Incident logs (who, what, when, resolution),
Access logs (employees and contractors),
Audit results,
Evidence of applied controls per vendor.
Use tooling that aggregates, timestamps, and structures these logs automatically – ideally integrated with your GRC or IAM platform.
CER compliance is not a one-off exercise but a continuous process of risk mitigation and improvement. Establish an annual review cycle where audit results and incident reports are used to refine internal policies and supply chain controls.
Robust CER compliance reporting starts with transparency – across your organization and throughout your supply chain. By actively managing third-party risks, automating access controls, and standardizing your reporting practices, you’ll build a resilient infrastructure that meets the directive and withstands modern threats.
About Key2XS
Key2XS provides a unique SaaS platform for managing both physical and digital access within a single IAM-governed environment. With native integrations for ASSA ABLOY CLIQ, Microsoft Entra ID, and SailPoint, we help critical entities achieve full CER compliance – including logging, auditing, and supply chain control.
Learn more about Key2XS & CER/NIS2 at www.key2xs.com/whitepaper