What else is consultancy and professional services called?

consulting, systems integrator, audit firm, legal.

How critical is a consultancy and professional services vendor by default?

Standard when the paste gives no rating: Work pauses rather than stops; the exposure is the confidential material they hold and the access a project grants. The register raises it to critical when the vendor is the only source and touches two or more systems, or touches three or more.

Which obligations attach to a consultancy and professional services vendor?

DORA: DORA Art. 28, DORA Art. 30, DORA Art. 31; NIS2: NIS2 Art. 21(2)(d), NIS2 Art. 21(3); SP 800-161: SP 800-161 SR-6, SP 800-161 SR-8, SP 800-161 SA-4, SP 800-161 SR-13, SP 800-161 SA-9, SP 800-161 PS-7, SP 800-161 MA-4, SP 800-161 AC-20, SP 800-161 IR-6; ISO 27001: ISO 27001 5.19, ISO 27001 5.20, ISO 27001 5.22, ISO 27001 5.21.

Which contract clauses does the register look for on a consultancy and professional services contract?

Confidentiality, access removal at project end, deliverable ownership, sub-contractor disclosure, beside the clauses each ticked regime expects on every vendor agreement.

Every vendor category · Managed and professional services

Consultancy and professional services

Advisers, integrators, auditors and lawyers engaged for projects and opinions, holding confidential material for the engagement.

How the register reads it

Also called	consulting, systems integrator, audit firm, legal
Family	Managed and professional services
Default criticality	Standard when the paste gives none. Work pauses rather than stops; the exposure is the confidential material they hold and the access a project grants. Raised to critical when the vendor is the only source and touches two or more systems, or touches three or more.
DORA scope	An ICT service: recorded in the register of information and reached by Articles 28 to 31.
Contract focus	Confidentiality, access removal at project end, deliverable ownership, sub-contractor disclosure.

What each regime attaches

18 clauses across 4 regimes

Shown on a register for the regimes you tick; with none ticked, the ISO 27001 rows are the default. Requirement text drawn from a human-verified compliance corpus under licence: the corpus statement of each clause, not the instrument verbatim.

DORA, the Digital Operational Resilience Act

Attaches to contractual arrangements for ICT services: cloud, software, network, managed services and data feeds. A supply of hardware, a bank or a courier is recorded in the register only where a service element sits in the contract.

DORA Art. 28 ICT third-party risk: general principles

Financial entities shall manage ICT third-party risk as an integral component of ICT risk, maintain a Register of Information on all contractual arrangements for the use of ICT services, report it to competent authorities, assess risk before entering arrangements (including concentration and subcontracting), and adopt an ICT third-party risk strategy.

Evidence an auditor accepts: A Register of Information of ICT third-party arrangements reported to the competent authority; Pre-contract risk assessment records
Common gap: No Register of Information
Source framework: DORA (Regulation (EU) 2022/2554)

DORA Art. 30 Key contractual provisions

Contractual arrangements for the use of ICT services shall include the mandatory key contractual provisions (e.g. clear service descriptions, locations of data processing, data protection, accessibility/availability/integrity/security, assistance on incidents, audit and access rights, termination rights and exit strategies), with enhanced provisions for serv...

Evidence an auditor accepts: ICT contracts containing the mandatory key provisions (audit/access, termination, exit, security); Enhanced provisions for critical/important-function services
Common gap: Contracts missing audit/access, termination or exit provisions
Source framework: DORA (Regulation (EU) 2022/2554)

DORA Art. 31 Designation of critical ICT third-party service providers

The European Supervisory Authorities designate critical ICT third-party service providers, which become subject to the Union Oversight Framework led by a Lead Overseer; financial entities shall account for the use of such providers in their third-party risk management.

Evidence an auditor accepts: Identification of any critical ICT third-party providers used and their oversight status
Common gap: No awareness of critical-TPP designations affecting the entity
Source framework: DORA (Regulation (EU) 2022/2554)

The NIS2 Directive

Attaches to every direct supplier and service provider of the entity, whatever it supplies; the depth of the assessment follows the access and the criticality.

NIS2 Art. 21(2)(d) Supply chain security, covering the relationship with each direct supplier and service provider

The Directive scopes this deliberately at direct suppliers and service providers, which makes the first artefact an inventory of who those parties are and which of them touch the network and information systems behind the service. From there the entity has to manage the security-related aspects of each relationship: what the supplier may access, what securit...

Evidence an auditor accepts: Inventory of direct suppliers and service providers, flagged for access to in-scope systems; Risk assessment per supplier proportionate to the access and criticality involved; Contractual security clauses, including incident notification obligations and audit or assurance rights
Common gap: Inventory built from the procurement system, so shadow and free-tier services are missing
Source framework: NIS2 Directive

NIS2 Art. 21(3) Take account of supplier-specific vulnerabilities and of Union coordinated supply chain risk assessments

Deciding what supply chain measures are appropriate is not left to general judgement. The entity has to take into account the vulnerabilities specific to each direct supplier and service provider, and the overall quality of those parties' products and cybersecurity practices including their secure development procedures. Separately, it must take into account...

Evidence an auditor accepts: Per-supplier assessment records that address that supplier's own vulnerabilities and secure development practice; A watch process for Union coordinated supply chain risk assessments and the outputs it has captured; Decision records showing how each relevant coordinated assessment was reflected in supplier measures
Common gap: Supplier assessment reduced to a questionnaire score with no view of that supplier's actual weaknesses
Source framework: NIS2 Directive

NIST SP 800-161 Rev 1

Attaches to every supplier, developer, integrator and service provider of a federal system, with the hardest controls on components and on privileged access.

SP 800-161 SR-6 Supplier Assessments and Reviews

Assesses and reviews suppliers, at a depth matched to what they supply and the access they hold.

Evidence an auditor accepts: assessment methodology and tiering by criticality; assessment records per supplier; review cycle evidence
Common gap: all suppliers assessed with the same questionnaire
Source framework: NIST SP 800-161 Rev 1

SP 800-161 SR-8 Notification Agreements

Establishes agreements requiring suppliers to notify the organization of compromise, vulnerability and relevant change.

Evidence an auditor accepts: notification clauses with defined triggers and timeframes; evidence of notifications received; escalation route when notification fails
Common gap: notification obligation absent or without a timeframe
Source framework: NIST SP 800-161 Rev 1

SP 800-161 SA-4 Acquisition Process

Puts security and supply chain requirements into the contract, including the evidence the supplier must provide.

Evidence an auditor accepts: contract templates carrying security and C-SCRM requirements; evidence of requirements in executed contracts; acceptance criteria tied to those requirements
Common gap: requirements in the template but absent from signed contracts
Source framework: NIST SP 800-161 Rev 1

SP 800-161 SR-13 Supplier Inventory

A control new in this publication: maintains an inventory of suppliers so that exposure to any one of them can actually be answered.

Evidence an auditor accepts: supplier inventory with the systems and components each supports; criticality attached to each supplier; update procedure on supplier change
Common gap: supplier list held by procurement with no link to systems
Source framework: NIST SP 800-161 Rev 1

SP 800-161 SA-9 External System Services

Governs external service providers across their life cycle, including the security roles each party holds.

Evidence an auditor accepts: inventory of external services; agreements defining security roles and responsibilities; monitoring and assessment evidence
Common gap: responsibilities assumed rather than defined
Source framework: NIST SP 800-161 Rev 1

SP 800-161 PS-7 External Personnel Security

Sets and enforces the personnel security requirements applying to external providers, including notification when their staff leave.

Evidence an auditor accepts: requirements imposed on providers; notification obligations for personnel change and their evidence; records of access removed on notification
Common gap: provider does not notify departures so access lingers
Source framework: NIST SP 800-161 Rev 1

SP 800-161 MA-4 Nonlocal Maintenance

Governs remote maintenance performed by suppliers, which is where most supplier technical access actually occurs.

Evidence an auditor accepts: approval records per remote maintenance session; authentication and monitoring evidence; termination of access after the session
Common gap: permanent vendor tunnels rather than session enablement
Source framework: NIST SP 800-161 Rev 1

SP 800-161 AC-20 Use of External Systems

Sets the terms under which organizational information may be processed on supplier and provider systems, and verifies them.

Evidence an auditor accepts: inventory of external systems used by suppliers for organizational data; agreements setting the security terms; verification evidence such as assessment or attestation
Common gap: supplier subcontracts processing with no notification
Source framework: NIST SP 800-161 Rev 1

SP 800-161 IR-6 Incident Reporting

Reports supply chain incidents to the parties who need to know, including other users of the same supplier or component.

Evidence an auditor accepts: reporting thresholds and recipients including external bodies; records of reports made; evidence of onward notification where required
Common gap: reporting obligations to sector bodies unidentified
Source framework: NIST SP 800-161 Rev 1

ISO/IEC 27001:2022

Attaches to every supplier relationship through controls 5.19 to 5.23, and to outsourced development through 8.30. With no regime ticked, these rows render as the default.

ISO 27001 5.19 Information security in supplier relationships

Define and apply processes to manage the security risk suppliers introduce.

Evidence an auditor accepts: supplier_risk_assessment; contractual_security_requirements; supplier_security_monitoring
Common gap: Treating all suppliers as low risk
Source framework: ISO/IEC 27001:2022

ISO 27001 5.20 Addressing information security within supplier agreements

Establish and agree the relevant security requirements in each supplier contract.

Evidence an auditor accepts: contract_security_clauses; supplier_risk_assessment; security_incident_reporting
Common gap: missing explicit security clauses
Source framework: ISO/IEC 27001:2022

ISO 27001 5.22 Monitoring, review and change management of supplier services

Regularly monitor, review and manage change in supplier security practice and service delivery.

Evidence an auditor accepts: supplier_security_monitoring_reports; supplier_service_review_meetings; supplier_change_management_records
Common gap: relying on informal verbal updates
Source framework: ISO/IEC 27001:2022

ISO 27001 5.21 Managing information security in the ICT supply chain

Extend security requirements down the ICT products and services supply chain.

Evidence an auditor accepts: supplier_security_requirements; contractual_security_clauses; supply_chain_risk_assessments
Common gap: Treating supplier security as one-off check
Source framework: ISO/IEC 27001:2022

Findings this category can raise

Single-source vendors with no fallback named
The paste marks these vendors as the only source and names no fallback. Every regime treats that as the concentration it exists to surface: the question is what happens on the day the vendor is unavailable, and who has written the answer down.
Concentration at or above the threshold
One vendor carrying a quarter or more of the spend, the top three carrying sixty percent or more, or one country carrying half or more: the register names the share so the dependence is a recorded one. Concentration is often the right commercial choice; the regimes ask that it be assessed, not avoided.
Contracts ending inside 90 days with no re-tender noted
A contract end inside ninety days of the as-at date, with no re-tender, renewal or extension recorded in the paste. Ninety days is shorter than most exit plans and most procurement cycles; the finding lists the days left beside each vendor.
DORA register-of-information fields missing
DORA asks financial entities to keep a register of information on every contractual arrangement for ICT services, in the columns the supervisory authorities' template sets: identification, type of service, the function it supports, criticality, country of provision, substitutability, sub-outsourcing and the exit plan. These vendors are ICT services in that sense and one or more of those columns is blank.
NIS2 supplier assessment not evidenced
The Directive asks an essential or important entity to manage the security of each direct supplier relationship and to take account of each supplier's own vulnerabilities and practices. These vendors touch in-scope systems and the paste carries no assessment date for them: the assessment may exist, but the register cannot show it.
Sub-outsourcing chains longer than one hop
The paste names a chain of two or more parties beneath a vendor. Each hop is a relationship the buyer has no contract with; DORA asks for the chain in the register, NIS2 asks that the supplier's own suppliers be considered, and the notification duty has to run the whole length of it.

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