NIS2 and the New Reality for Interconnection: What US
Carriers Need to Know About Supply Chain Transparency

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The new EU network security directive, NIS2, has brought with it a fundamental change in how digital infrastructure is expected to operate, shifting the balance from passing compliance to proactive, provable resilience. At its heart there is a demand for visibility that goes far deeper than anything European carriers have been required to demonstrate before. Operators must know, and be able to show, how traffic moves through their networks, which suppliers sit inside critical paths, and where interconnection occurs.

This is a far cry from the old days when IP transit was treated as an acceptable black box. Under NIS2, the lack of transparency that was traditionally baked into long-haul routes, third-party dependencies, and multi-operator transit chains is no longer acceptable. That means visibility is no longer just a nice-to-have layer to give operators an added element of control – it’s a fundamental necessity that will change how networks need to be architected from the ground up.

For US carriers with transatlantic business, this carries some immediate implications. Even if domestic regulatory frameworks remain more permissive, operators serving European customers or transporting European traffic will “inherit” the transparency obligations that NIS2 now enforces. Traffic paths that traverse European areas, even briefly, will simply fall under a different level of scrutiny. Architectural decisions that were once based on cost and convenience now have to consider traceability, auditability, and supplier accountability as a minimum. It’s a sensible piece of legislation, particularly when you consider the multi-million-dollar disruption that can be caused by outages or security issues cascading through supply chains due to a single, hidden dependency.

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NIS2 may be a European directive, but its ripple effects are unmistakably global, and they point to a new era in which interconnection strategy is inseparable from regulatory compliance and competitive positioning.

NIS2’s supply chain impact: new depths of visibility

NIS2 is recasting digital infrastructure as a regulated supply chain in which every dependency must be identified, validated, and monitored. Where previous frameworks concentrated on internal systems and security controls, the new directive forces operators to map the full ecosystem that keeps their services running, including upstream carriers, data center partners, cloud interconnects, and any external provider that touches critical traffic.

Companies must now understand which functions are essential, how failures propagate, and where single points of failure may be hiding. And in order to do that they will require a level of observability that exposes pathways as well as the contractual and operational relationships that hold those pathways together. Put simply, it means that interconnection, which was historically a technical footnote or a way to boost speed and control, is now an important compliance tool.

There’s a cultural angle to all of this too. By its nature, NIS2 elevates business continuity and resilience to the boardroom, requiring executives to demonstrate that they understand how traffic moves through their infrastructure and which suppliers influence service availability. The directive makes clear that resilience can’t be