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Vendor due diligence is a risk-scaled investigation of a supplier before you rely on it, followed by checks that confirm the supplier continues to meet your requirements. Start with what the vendor will do, what business failure would mean, and what data, systems, or facilities it can reach. For information and communications technology (ICT) suppliers, NIST’s July 8, 2026 guide identifies five areas to examine: foreign ownership, control, or influence; provenance; resilience; foundational cyber practices; and supply-chain tiers. These categories are specific to ICT supplier due diligence, not a universal legal checklist for every vendor.
What vendor due diligence should establish
The goal is to make an informed decision about a supplier and define the conditions under which the relationship is acceptable. NIST defines cybersecurity supply-chain risk management (C-SCRM) due diligence as “the investigative process of researching and verifying all available, pertinent information about a given supplier or product so that informed decisions can be made on new acquisitions or existing systems.” Its SP 1326 guide supplements NIST SP 800-161 Revision 1 and addresses ICT suppliers. Read NIST SP 1326 or see its publication record.
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Due diligence is a minimum research layer, not a substitute for a full supplier-risk assessment. Scale it to the vendor’s criticality, your dependency on its service, the sensitivity of data involved, the access it receives, and the resources available to investigate. The process should produce a documented decision, not just a completed questionnaire.
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Before requesting evidence, map the proposed service and the consequences of failure. This helps focus questions on the supplier’s actual role rather than collecting paperwork that does not bear on your exposure.
- Business purpose and dependency: What outcome will the supplier provide? Is it replaceable, and how quickly could you operate without it?
- Data: What information will the vendor collect, receive, create, store, process, or access? Does it include personal, financial, regulated, confidential, or otherwise sensitive data?
- Access: Which systems, accounts, networks, facilities, or devices will it reach? Will access be continuous or limited to particular work?
- Impact: What would a compromise, outage, failed delivery, or supplier closure mean for customers, operations, compliance, and recovery?
- Decision owners: Identify the business owner and the people responsible for security, privacy, legal, procurement, and operations review.
Choose a review depth proportionate to those answers. A low-impact vendor with no sensitive data or system access may need a focused check. A critical ICT supplier with privileged access or opaque dependencies warrants more extensive evidence gathering and follow-up.
2. Verify supplier identity and context
Establish who you are contracting with and distinguish verifiable facts from the supplier’s own claims, outside reporting, and unanswered questions. For each material finding, keep the source and the date checked; seek corroboration when possible.
- Confirm the supplier’s legal name, public identity, website, headquarters, operating locations, and relevant parent and subsidiary relationships.
- Check exclusion, sanctions, or procurement status where relevant to your organization and transaction. NIST SP 1326 discusses U.S. government screening resources in its pre-check material; those checks do not apply universally to every buyer or purchase.
- For ICT suppliers, examine foreign ownership, control, or influence; where the supplier and product operate or are produced; relevant components and supply-chain tiers; and whether available information provides a useful picture of provenance.
- Record gaps as unknowns rather than treating missing information as proof of safety or misconduct.
NIST’s five ICT-focused assessment areas are a useful way to organize this part of the review:
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- Foreign ownership, control, or influence: Consider relevant ownership and jurisdictional exposure in the context of the service and your risk tolerance.
- Provenance: Look for credible information about where products, services, and components originate and how they are supplied.
- Resilience: Consider the supplier’s ability to withstand disruption and continue or restore the service.
- Foundational cyber practices: Review the supplier’s baseline cybersecurity practices and the evidence supporting claims about them.
- Supply-chain tiers: Identify important dependencies beyond the direct supplier where visibility is material to your risk.
3. Assess capability, security, and resilience
Look at both the supplier’s public track record and evidence it can provide about its current controls. Ask what a document actually covers: its scope, date, systems or services included, and whether an independent party validated it. A certification logo or questionnaire response alone does not establish that every relevant service or control is covered.
- What public information is available about security practices, incidents, product or service vulnerabilities, and remediation?
- How does the supplier detect, report, investigate, and respond to incidents that may affect your organization?
- What support, continuity, backup, and recovery commitments apply, and do they match the business impact of an interruption?
- What evidence supports security claims, and what services, locations, or systems fall outside that evidence?
- For ICT products and services, what do the supplier’s foundational cyber practices, resilience, provenance, and supply-chain dependencies reveal?
For small and medium-sized businesses, CISA describes a vendor SCRM template and spreadsheet for ICT hardware, software, and services, with yes/no/partial response options. It can help structure evidence requests; treat a partial answer as an item to understand, not as a pass. See CISA’s fact sheet.
4. Map data handling and access
Understand the full data path, not only what the vendor says it stores. The FTC recommends identifying what personal information your business holds, how it moves through the business, and who can access it; keep only what is needed and only for as long as needed. FTC: Protecting Personal Information.
- List the data the supplier will collect, receive, create, or access, and where it will be stored and processed.
- Identify the supplier personnel and subcontractors who can access it, and the business reason for each access path.
- Reduce data scope and privileges to what the service needs. Limit vendor access to the necessary systems and the period it is needed, then remove it when the work ends.
- Ask how access is approved, monitored, reviewed, and revoked. For network access, the FTC recommends properly configured encryption and multifactor authentication.
- Set expectations for how the vendor may use, share, retain, and delete data, including any permitted onward sharing.
- For personal information, define retention and secure disposal in line with business need and applicable obligations.
5. Put requirements and verification in the contract
Translate the risks you identified into written obligations that fit the service. The FTC recommends putting vendor security expectations in writing, specifying how vendors can use, share, retain, and delete data, and checking that they follow the agreed expectations. It also advises against relying only on a vendor’s assurances. FTC: Cybersecurity for Small Business — Vendor Security.
Depending on the relationship and applicable law, address:
- Required security practices and how controls will be evaluated or updated. If you require a particular standard, name it clearly.
- Permitted data use and sharing, retention limits, deletion or return at the end of the relationship, and access boundaries.
- Evidence the supplier must provide and how you can verify compliance, such as reports, answers, or other agreed evidence.
- Incident communication expectations and notice of material changes to the service or relevant controls.
- Support, continuity, and recovery responsibilities where interruption would materially affect your operations.
These are topics to negotiate, not a one-size-fits-all contract clause. Match terms to the service, the risks, and applicable legal requirements; obtain legal review where appropriate.
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6. Document the decision and plan follow-up
Keep a record that lets another decision-maker understand what was checked and why the supplier was approved, conditionally approved, or declined. NIST recommends a due-diligence report template, a concern-rating schema, and consideration of continuous monitoring; it does not prescribe one universal score or reassessment interval.
- Record the supplier and service reviewed, findings, sources and dates, evidence scope, unknowns, and open questions.
- Rate concerns against your organization’s own risk tolerance; do not present a generic score as if it were universally valid.
- Name an accountable owner for each unresolved issue and state whether it must be resolved before signing, before access is granted, or by an agreed date.
- Set review triggers or a refresh schedule based on criticality, data sensitivity, access, and changes in the supplier or service.
- Decide how to respond when evidence is missing or risk is unacceptable: seek further evidence, narrow access, add conditions, escalate, or choose another supplier.
How much investigation is enough?
NIST distinguishes basic from enhanced due diligence. Basic work is desktop research using publicly available information. Enhanced work can draw on commercial datasets, proprietary sources, and supply-chain illumination tools. Choose the level based on supplier criticality and available resources, and corroborate important findings with multiple sources where possible. Higher-cost data or tools are most relevant when the potential impact or uncertainty justifies them; they are optional aids, not a requirement for every supplier.
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