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Evidence & Attestation Library Index

Indexes shareable evidence with sharing conditions, NDA requirement and expiry.

Available soon

Format
Excel
Size
98 KB
Length
11 sheets
Version
1.0
Updated

What's inside

What changed

  1. 1.0

    Published.

Changes across this pack

Preview

The workbook's sheets as you will receive them, with its example rows and the values its formulas calculate. Highlighted [[text]] is for you to replace; rows marked EXAMPLE are for you to delete. Wide sheets scroll sideways. The cover, document control and changelog sheets are in the file.

Instructions

How to use this workbook

StepWhat to do
1What this workbook is. It is the evidence index of Questionnaire Response Governance Method: one row for each document you may show a customer (QG-06, QG-13, EV-08 to EV-14). The Security Answer Library cites a row by its item ID.
2Start on the Index Counts sheet. Type the as-at date, which is the date the index is checked at. Type a date, never a formula. Check the warning window: 60 days is the house default (EV-09).
3Enter one row for each item on the Evidence Index sheet. Yellow cells are inputs. Choose from the lists where a cell has one. Write the title, the issuer and the dates as the document states them (EV-14), and nothing more.
4Choose the scope of claim from CS-1 to CS-7. It says what the document covers: the whole company, a named service, a named site, a system list, a supplier's service, a written policy or a plan with a date. The Types and Rules sheet lists them. A document never covers more than its own scope statement (QG-07).
5Mark a supplier's document with the supplier's reference and its terms. Share it only if the terms say permitted, and label it as the supplier's (EV-11, QG-14). Never show it as your own.
6Choose the sharing tier. Public goes to anyone. Under NDA goes only where a non-disclosure agreement covers the recipient on the day. Summary only never goes itself: give its summary a row of its own and enter that row's ID. Never shared stays inside. A change of tier is a decision of the Head of Information Security and Legal.
7Read the calculated columns at the right of the Evidence Index sheet. "Fields to fix" says what EV-08 still needs. "Expiry" says Expired, Expiring or In date. "Released by" names the role that releases the item (QG-13). "Goes out as" says what happens to it.
8Before you send evidence, open the Release Check sheet. Enter the send date and the recipient, and the dates of the non-disclosure agreement in force. Ask Legal to confirm that the agreement covers the recipient and the document. The sheet shows each item as Send, Summary in its place, or Not sent with the reason (EV-13).
9Record what you send in the Questionnaire Request Tracker: the item, the recipient and the day (EV-12). This workbook says what may go. It does not record what went.
10Renew an item before it expires. The Index Counts sheet lists every item that expires inside the window (EV-09). An answer that cites an expired item is held until its owner renews the item or changes the answer (EV-10). Mark a withdrawn item Withdrawn and keep its row.
11Report the counts each month (QG-23). They are on the Index Counts sheet, with the sentences for the report.
12To clear the EXAMPLE, delete the EXAMPLE rows on the index sheet and the recipients on the release sheet once your own are entered. The formulas stay.

Legend

Yellow cells are inputs. Everything else is calculated or fixed — do not overwrite formulas.

EXAMPLERows marked EXAMPLE in the first column show how a completed row looks. Delete them before approval.

Why an index. A questionnaire answer is a statement the organisation is held to. A customer reads it as a description of what the organisation does, relies on it when it decides to buy, and may point to it later if something goes wrong. So the organisation answers once, from an approved source, with evidence behind it, and says what the answer covers. A form is not the place to agree a new commitment. Promises are made in the contract, through a standard schedule and a short ladder of approvals, and an answer never promises what the contract or the controls do not support. The result is counts of requests answered on time, answers reused, evidence in date and commitments kept. It is never one score.

Limitations: This document helps you answer security questionnaires from your customers. It is not legal advice, and an answer, a certificate or a schedule from this pack is not a statement that you comply with NIS2, DORA, the GDPR or any standard. A response is a statement your organisation is held to. Ask counsel to confirm any answer that a customer could treat as a promise or as a legal claim, and whether a customer is a financial entity or an essential or important entity.

A document in this index shows what its issuer says, for the scope and the period it states. It does not show that an answer is true for anything wider (QG-10). Say that the organisation is certified, compliant or aligned only when the index holds a current document that says it for the scope stated and Legal has confirmed the wording.

EXAMPLE: the distributor, a wholesale distributor with about 900 staff, three warehouses and an online ordering service, as at 30 Sep 2026. Its index holds 9 items. The distributor holds no ISO/IEC 27001 certificate of its own. Its hosting provider holds one for the hosting service. P08's example is a different company, a software firm working towards its first certificate.

Adapting this template:

• Small organisation: one person may keep the index and own every item. Start with the few documents customers ask for most: a policy extract, your hosting provider's certificate, an insurance certificate and a test summary. Keep every column. A short index with dates is worth more than a long one without.

• Regulated organisation: your customers or your regulator may ask for more evidence, for longer, or under a form of agreement you cannot change. Add rows and notes, and have Legal read the agreement before you release an Under NDA item. Counsel confirms whether a customer is a financial entity.

• IT run by a service provider or outsourced: much of your evidence is the provider's. Enter it with the provider's reference and its terms, label it as theirs, and ask the provider in writing whether you may share it. Do not show it as your own.

• Larger group: keep one index for each legal entity or service where the scope differs. Do not copy a certificate onto a row for an entity it does not cover.

This workbook is your own record. Keep a copy that can be reached when the main systems are down.

Evidence Index

EXAMPLE: 9 items as at 30 Sep 2026. One row for each document you may show a customer. Yellow columns are inputs; white columns calculate. The Release Check sheet says what may go to a named recipient.

ExampleItem ID (EI-nn)Title of the document, as it states itType (EV-01 to EV-07)Scope of claim (CS-1 to CS-7)Issuer or signerOwnerIssuedExpires (a date, or None)Sharing tierSummary item (Summary only items)Supplier reference (a supplier's document)Supplier's terms for sharingStatusNotesDays to expiry (calc)Expiry (calc)Fields to fix (calc)Released by (calc)Goes out as (calc)
EXAMPLEEI-01Hosting provider's ISO/IEC 27001 certificate and scope statementCertificateCS-5The hosting provider's certification bodyHead of IT15 Nov 202314 Nov 2026PublicSUP-002permittedCurrentThe provider's, for its hosting service. Renewal audit expected before the expiry date.45ExpiringCompleteQuestionnaire response leadSend to anyone
EXAMPLEEI-02Penetration test report, online ordering service, March 2026Audit reportCS-2An independent testing firmHead of IT27 Mar 202626 Mar 2027Summary onlyEI-03CurrentHolds exploit detail. Only the summary leaves.177In dateCompleteHead of Information SecuritySummary EI-03 in its place
EXAMPLEEI-03Penetration test summary, online ordering service, March 2026Penetration test summaryCS-2An independent testing firmHead of IT3 Apr 202626 Mar 2027Under NDACurrentThe report that stays under a non-disclosure agreement.177In dateCompleteHead of Information SecuritySend only with an NDA in force
EXAMPLEEI-04Information security policy, signed-off summaryPolicy extractCS-1Executive CommitteeHead of Information Security15 Jan 202615 Jan 2027PublicCurrentApproved by the Executive Committee at P04's Policy tier.107In dateCompleteQuestionnaire response leadSend to anyone
EXAMPLEEI-05Data-flow diagram, online ordering service (high level)Architecture diagramCS-2Head of ITHead of IT12 May 202611 May 2027Under NDACurrent223In dateCompleteHead of Information SecuritySend only with an NDA in force
EXAMPLEEI-06Cyber insurance certificateInsurance certificateCS-1The insurerHead of Risk1 Apr 202631 Mar 2027Under NDACurrent182In dateCompleteHead of Information SecuritySend only with an NDA in force
EXAMPLEEI-07Recovery test attestation, online ordering service, June 2026Attestation letterCS-2Head of ITHead of IT30 Jun 202629 Jun 2027Under NDACurrentSigned by the Head of IT.272In dateCompleteHead of Information SecuritySend only with an NDA in force
EXAMPLEEI-08Incident response exercise summary, March 2026Attestation letterCS-1Head of Information SecurityHead of Information Security25 Mar 202618 Mar 2027Under NDACurrentThe exercise took place on 2026-03-18.169In dateCompleteHead of Information SecuritySend only with an NDA in force
EXAMPLEEI-09Internal control test resultsAudit reportCS-1Head of Information SecurityHead of Information Security15 Sep 202614 Sep 2027Never sharedCurrentInternal workpapers (P20). Never leave the organisation.349In dateCompleteNobody: not releasedNot sent: never shared

Release Check

What may go to each recipient

Enter the send date, then each recipient and the dates of the non-disclosure agreement in force. Each row of the Evidence Index shows as Send, a summary in its place, or Not sent with the reason. Ask Legal to confirm that an agreement covers the recipient and the document. This sheet does not record the release (EV-12).

When, and to whom

Date the evidence is sent30 Sep 2026EXAMPLE: 30 Sep 2026. Type a date, never a formula.
Recipient (a customer, or a prospect in a live opportunity)Retail groupHospital groupRegional public bodyConvenience-store chain
Tracker referenceC-01C-02C-03C-04
Non-disclosure agreement in force from (blank for none)3 Mar 202510 Feb 20264 Nov 2024
Last day of the agreement (blank for no end date)9 Feb 20293 Nov 2027

What may go

Item IDItemSharing tierRetail groupHospital groupRegional public bodyConvenience-store chainRecipient 5Recipient 6
EI-01Hosting provider's ISO/IEC 27001 certificate and scope statementPublicSend, and say it expires soonSend, and say it expires soonSend, and say it expires soonSend, and say it expires soon
EI-02Penetration test report, online ordering service, March 2026Summary onlySummary EI-03 in its placeSummary EI-03 in its placeSummary EI-03 in its placeSummary EI-03 in its place
EI-03Penetration test summary, online ordering service, March 2026Under NDASendNot sent: no NDA in forceSendSend
EI-04Information security policy, signed-off summaryPublicSendSendSendSend
EI-05Data-flow diagram, online ordering service (high level)Under NDASendNot sent: no NDA in forceSendSend
EI-06Cyber insurance certificateUnder NDASendNot sent: no NDA in forceSendSend
EI-07Recovery test attestation, online ordering service, June 2026Under NDASendNot sent: no NDA in forceSendSend
EI-08Incident response exercise summary, March 2026Under NDASendNot sent: no NDA in forceSendSend
EI-09Internal control test resultsNever sharedNot sent: never sharedNot sent: never sharedNot sent: never sharedNot sent: never shared

Counts for each recipient

Items that can be sent as they are7277
Items that go as a summary in their place1111
Items not sent1611
Items to fix first0000
In words7 of 9 items can be sent as they are; 1 go as a summary; 1 are not sent2 of 9 items can be sent as they are; 1 go as a summary; 6 are not sent7 of 9 items can be sent as they are; 1 go as a summary; 1 are not sent7 of 9 items can be sent as they are; 1 go as a summary; 1 are not sent

Counts of items, never a share. An item that expires inside the warning window goes with a reminder to say so and to renew it (EV-09).

Index Counts

Settings and counts

Set the two yellow cells, then read the counts. Each count is a number with the others named: no score and no percentage.

Settings

As-at date: the date the index is checked at30 Sep 2026Expiry is worked out at this date. EXAMPLE: 30 Sep 2026. Type a date, never a formula.
Days before expiry that an item counts as expiring (EV-09)60A house default. Your policy states your value (EV-09).

Counts for the report

CountNumberWhich items
Items in the index9
Items withdrawn0
Items not withdrawn9
Sharing tier: Public2
Sharing tier: Under NDA5
Sharing tier: Summary only1
Sharing tier: Never shared1
Type: Certificate1
Type: Audit report2
Type: Penetration test summary1
Type: Policy extract1
Type: Architecture diagram1
Type: Insurance certificate1
Type: Attestation letter2
Items past their expiry date, not withdrawn0
Items that expire within the warning window, not withdrawn1
Items expired or expiring (QM-04)1EI-01
Items that are a supplier's document (EV-11)1
of which the supplier's terms do not allow sharing0
Items with a field to fix (EV-08)0None

In words (for the report)

9 items in the index: 2 Public, 5 Under NDA, 1 Summary only and 1 Never shared; 0 withdrawn.

1 item is expired or expiring within 60 days: EI-01 (QM-04).

Supplier's documents: 1 of 9 items (EV-11).

Every item has the fields EV-08 asks for.

QM-04 is the measure of this index. QM-01 to QM-03 and QM-05 come from the tracker and the answer library.

Types and Rules

Types, sharing tiers, scopes of claim and rules

The lists the Evidence Index uses, and the rules EV-08 to EV-14. Use the words exactly: the checks read them.

Evidence types (EV-01 to EV-07)

IDTypeWhat it isP06 evidence itemWhat to check about its scope
EV-01CertificateA certificate issued by a certification body for a management system or a service, with its scope statement.P06 EV-02Check the scope names the service, the sites and the legal entity that holds it.
EV-02Audit reportA report by an independent auditor or tester on the organisation or a service, for a named period.P06 EV-03Check the period, the service covered and who commissioned it.
EV-03Penetration test summaryA short document by the tester or the owner that says what was tested, when, by whom, and how findings were handled.P06 EV-06Check the systems and the date. A summary never replaces the report for the owner.
EV-04Policy extractThe signed-off summary or an extract of a policy, with its approver and date.P06 EV-05A policy shows what is required. It does not show that it is met.
EV-05Architecture diagramA high-level diagram of a service and its data flow.NoneSend the high-level version only. Detail stays inside.
EV-06Insurance certificateA certificate of an insurance policy, with the insurer, the cover and the period.NoneState the cover as the certificate states it.
EV-07Attestation letterA signed statement by a named person of a fact they have checked, such as a recovery test result, with its date and scope. A bridge letter is an attestation that covers the gap after a report period.P06 EV-04It covers what its signer checked, on its date, and nothing else.

Sharing tiers

TierRuleReleased by
PublicMay be sent to a customer or prospect with no further agreement.Questionnaire response lead
Under NDAMay be sent only where a non-disclosure agreement covers the recipient on the day it is sent.Head of Information Security
Summary onlyThe item itself is never sent. Its approved summary, named in the index, is sent in its place.Head of Information Security
Never sharedNot sent outside the organisation. A change of tier is a decision of the Head of Information Security and Legal.Nobody. A change of tier is a decision of the Head of Information Security and Legal.

Scopes of claim (CS-1 to CS-7)

IDScopeWhat it means
CS-1Whole companyTrue of the whole organisation, as the answer says.
CS-2Named serviceTrue of one named service, such as the online ordering service, and no other.
CS-3Named siteTrue of named sites, such as the three warehouses, and no other.
CS-4Named system or tool listTrue of the systems or tools named, or on the list as at the date shown.
CS-5Supplier's service, not oursTrue of a supplier's service. The supplier, not the organisation, holds the control and the attestation.
CS-6Written policy onlyWhat the organisation's written policy requires. The answer does not say that every case meets it.
CS-7Plan with a dateA plan that is not yet in place, stated with its date. It is never worded as present.

Rules for the index (EV-08 to EV-14)

IDRule
EV-08Every item has a type, a scope of claim, an issuer or signer, an owner, an issue date, an expiry date (or the word None), a sharing tier and, where it is a supplier's, the supplier and its terms.
EV-09An item with an expiry date is renewed before it expires. The owner is reminded [[60]] days ahead, and the response lead lists every item that expires inside that window.
EV-10An item that expired, or was withdrawn, is not sent. The answers that cite it are held until the owner renews it or changes the answers.
EV-11A supplier's certificate or report is shared only if the supplier's terms allow it, and is labelled as the supplier's, with its scope. It is never shown as the organisation's own (QG-14).
EV-12Evidence is released by its tier and by the person that tier names (QG-13). The release is recorded in the tracker with the item, the recipient and the date.
EV-13A recipient with no non-disclosure agreement in force is offered Public items, and a summary whose own sharing tier is Public. The request for an agreement goes to Legal.
EV-14An item is described to a customer by its title, scope, issuer and dates, as the document states them, and no further.

Where the other documents fit

TopicWhat to know
The answers that cite an itemThe Security Answer Library holds the answers. Each cites the item IDs of this index, or says Statement only (AL-04, QG-06). An answer whose item has expired is held until its owner renews the item or changes the answer (EV-10).
Recording a releaseThe Questionnaire Request Tracker records the item, the recipient and the day (EV-12, RT-12). This workbook says what may go. It does not record what went.
A wrong item sentAn item sent by mistake, or an expired one, is a wrong answer. The correction route of the Questionnaire Response Governance Method applies (QG-19). Do not hide it.
Suppliers' certificatesP06 owns how you assess and monitor your own suppliers and how you validate what they send you (P06 TP-04). This index holds a supplier's document only so that you can show it, as theirs, when their terms allow (QG-14, EV-11).
Keeping the responseThe exact response as sent, with the item versions it cited, is kept for the records period (QG-16, P22).
A document that says the organisation is certifiedSay so only when the index holds a current document that says it for the scope stated, and Legal has confirmed the wording (QG-10). The EXAMPLE holds no certificate of its own.

The CSA STAR registry, SOC 2 reports and ISO/IEC certificates are named by their publishers. A document in this index is evidence about its own scope and period only.

Lists

ListTypeListScopeListTierListStatusListTermsListSupplierListSupplierName
CertificateCS-1PublicCurrentpermittedSUP-001SUP-001 Managed IT service provider
Audit reportCS-2Under NDAWithdrawnnot permittedSUP-002SUP-002 Cloud hosting provider
Penetration test summaryCS-3Summary onlySUP-003SUP-003 Payment service provider
Policy extractCS-4Never sharedSUP-004SUP-004 ERP software provider (hosted)
Architecture diagramCS-5SUP-005SUP-005 Email and office software provider
Insurance certificateCS-6SUP-006SUP-006 Security monitoring provider
Attestation letterCS-7SUP-007SUP-007 National parcel carrier
SUP-008SUP-008 Express courier
SUP-009SUP-009 Pallet network
SUP-010SUP-010 Warehouse management system provider
SUP-011SUP-011 Backup service provider
SUP-012SUP-012 Payroll bureau
SUP-013SUP-013 Outsourced customer contact centre
SUP-014SUP-014 Network connectivity provider

Definitions

Definitions

TermMeaning in this workbook
EvidenceA document that supports an answer: a certificate, an audit report, a penetration test summary, a policy extract, a diagram, an insurance certificate or an attestation letter.
AttestationA signed statement by a named person of a fact they have checked, such as the result of a recovery test, with its date and scope.
Sharing tierThe rule for who may receive an evidence item: Public, Under NDA, Summary only or Never shared.
Non-disclosure agreement (NDA)A non-disclosure agreement that covers the recipient and the document, in force on the day the document is sent.
Scope of claimWhat an answer covers: the whole company, a named service, a named site, a named system or tool list, a supplier's service, a written policy only, or a plan with a date. An answer never implies a wider scope than its evidence has.
StaleA library answer whose review date has passed. A stale answer is not sent until its owner has confirmed or changed it.
Questionnaire response leadThe person who owns a request from receipt to close, keeps the library, the evidence index and the tracker, and releases responses.
Topic ownerThe manager who runs the control an answer describes, and who writes or confirms answers on that topic.
ItemOne row of the index: one document you may show a customer, with an ID of the form EI-nn.
Summary onlyThe tier of a document that is never sent itself. Its approved summary, which has a row of its own, is sent in its place.
Supplier's documentA certificate or report that belongs to a supplier. It is shared only as the supplier's terms allow, and labelled as theirs (EV-11).
As-at dateThe date the index is checked at, typed on the Index Counts sheet.
Warning windowThe days before the expiry date within which an item counts as expiring (EV-09). The last day of the window counts.
Days to expiry (calc)The expiry date less the as-at date. Negative once it has passed. Blank where there is no expiry date.
Expiry (calc)Withdrawn, No expiry, Expired (the expiry date is before the as-at date), Expiring (within the warning window of the as-at date, counting the last day) or In date.
Fields to fix (calc)Complete, or the fields EV-08 asks for that are empty or wrong: the ID, name, type, scope of claim, issuer, owner, issue date, expiry date, sharing tier, summary item, supplier's terms and status.
Released by (calc)The role that releases an item of its tier (QG-13). Never shared items are not released.
Goes out as (calc)What happens to the item, before you know the recipient: Send to anyone, Send only with an NDA in force, the summary in its place, or Not sent with the reason. The Release Check sheet gives the answer for a named recipient.
Expired or expiring (calc)1 for an item that is not withdrawn and whose expiry date is on or before the last day of the warning window. This is the count of QM-04.
EI-nn, EV-nn, CS-n, QG-nn, QM-nnItem IDs, evidence types and rules, scopes of claim, requirements of the Questionnaire Response Governance Method and measures. The other documents of this pack use the same IDs.
EXAMPLEA worked example: the distributor as at 30 Sep 2026. Every name and value is made up. Delete before use.

Framework References

Framework references

These references indicate relevance only and do not reproduce the text of any standard.

FrameworkReferenceSupported by
ISO/IEC 27001:2022Clause 7.5 — Documented informationEvidence Index sheet: the index is documented information, identified, dated, owned and kept current
NIST CSF 2.0GV.OC-03 — “Legal, regulatory, and contractual requirements regarding cybersecurity - including privacy and civil liberties obligations - are understood and managed”Evidence Index sheet: the evidence you hold and may share shows what customers and others can expect of your cybersecurity risk management
NIS2 — Directive (EU) 2022/2555Article 21(3) — measures take into account each direct supplier's specific vulnerabilities and the overall quality of its products and cybersecurity practices, including secure developmentEvidence Index sheet: a customer that is an essential or important entity takes the quality of your practices into account. The index lists what you can show, with its scope and dates
DORA — Regulation (EU) 2022/2554Article 30(3)(e) — contracts for ICT services supporting critical or important functions include the right to monitor the provider’s performance on an ongoing basis, with unrestricted rights of access, inspection and audit by the financial entity or an appointed third party and by the competent authority, the right to agree alternative assurance levels where other clients’ rights are affected, the provider’s obligation to cooperate fully during on-site inspections and audits by the authorities, the Lead Overseer, the entity or an appointed third party, and details of the scope, procedures and frequency of auditsRelease Check sheet: a financial entity customer may ask for more. Report-based assurance is the default offer, and Legal decides what else
GDPR — Regulation (EU) 2016/679Article 28(5) — adherence of a processor to an approved code of conduct (Article 40) or an approved certification mechanism (Article 42) “may be used as an element by which to demonstrate sufficient guarantees”Evidence Index sheet, Type and Scope of claim columns: a certificate or code of conduct may be used as an element in showing guarantees, and shows only what its scope states
GDPR — Regulation (EU) 2016/679Article 32(3) — adherence to an approved code of conduct (Article 40) or an approved certification mechanism (Article 42) “may be used as an element by which to demonstrate compliance with the requirements set out in paragraph 1” of Article 32Evidence Index sheet, Issued and Expires columns: a certification mechanism may be used as an element in showing security, for the period it covers
ENISA, Procurement guidelines for the cybersecurity of hospitals and healthcare providers (July 2026)Measure SOURCE-01 asks hospitals, when feasible, to prioritise suppliers “who demonstrate certified compliance with relevant security standards and regulations”; its checks include criteria that “prioritise suppliers with certified or independently assessed security postures” and an assessment of the supplier's incident response plansEvidence Index sheet: a customer that follows this measure prefers suppliers with certified or independently assessed postures, and asks for the document and its scope
UK NCSC, Supply chain security guidancePrinciple 10, “Build assurance activities into your supply chain management” — “Build the 'right to audit' into all contracts and exercise this.” It adds that this “might not always be possible or desirable, particularly where this relates to a Cloud service”, and that, where justified, a buyer builds in assurance requirements such as penetration tests, external audit or formal security certificationsEvidence Index and Release Check sheets: assurance such as penetration tests, external audit and certifications is offered as reports and summaries. A right to audit goes to Legal
Cloud Security Alliance (CSA)CSA STAR (Security, Trust, Assurance and Risk): “a publicly accessible registry that documents the security and privacy controls provided by popular cloud computing offerings”. Level 1 is a self-assessment that submits the CAIQ. Level 2 builds on third-party audits: a STAR Certification for ISO/IEC 27001, whose certificates “expire after three years unless updated”, and a STAR Attestation for SOC 2, whose listings “will expire after one year unless updated”. CSA says publishing to the registry can help “alleviate the need to fill out multiple customer questionnaires”Evidence Index sheet, Expires column: STAR certifications and attestations expire, so the index tracks the dates
AICPA, SOC 2SOC 2® Reporting on an Examination of Controls at a Service Organization Relevant to Security, Availability, Processing Integrity, Confidentiality, or Privacy (AICPA). Cited by name and title only; no criterion is quoted, and a SOC 2 report is evidence about the service organisation and the period it namesEvidence Index sheet, Scope of claim and Issued columns: a report is evidence about the service organisation and the period it names

Editions referenced: Directive (EU) 2022/2555 (NIS2); Regulation (EU) 2022/2554 (DORA); Regulation (EU) 2016/679 (GDPR); NIST CSF 2.0; ISO/IEC 27001:2022 incl. Amd 1:2024 (by number and title only); CSA CCM, CAIQ and STAR, the Shared Assessments SIG, and SOC 2 (by name and title only), as their publishers state them; as published and read on 9 October 2026

Directive (EU) 2022/2555 is addressed to the Member States, and binds essential and important entities through their national law. Article 21(2)(d) and 21(3) ask a customer that is such an entity to manage the security of its direct suppliers and service providers, and to take into account the quality of their cybersecurity practices. They bind the customer. They do not give it a right to an answer from you. ENISA's guidance for hospitals says the Directive does not directly impose requirements on ICT suppliers and that its obligations take effect through national law. A questionnaire is the customer's way of meeting its own duty, and what you owe it comes from your contract. A supplier that is itself an essential or important entity has its own Article 21 duties, which this pack does not restate.

Regulation (EU) 2022/2554 binds the financial entities of its Article 2. Articles 28 to 30 say what a financial entity does about ICT third-party risk and what its contract with an ICT third-party service provider holds. A provider is bound to them through that contract. Article 30(3) asks for more where the service supports a critical or important function of the financial entity. A customer that is not a financial entity cannot rely on Article 30 to ask the same of you. Counsel confirms whether a customer is a financial entity and whether a service supports a critical or important function of it.

Regulation (EU) 2016/679 binds controllers and processors. Where you process personal data on a customer's behalf you act as its processor, and Article 28(3) sets what the contract holds, including information to show compliance and audits. Where you decide the purposes and means yourself, you are a controller of that data. The role depends on the facts for each processing, and counsel confirms it. Article 32 asks both roles for security that is appropriate to the risk.

ENISA's guidance and the NCSC's principles are guidance for buyers. They are not law, and they do not say what the contract between you and a customer must hold. ENISA says its publication does not endorse a regulatory obligation.

The CSA CAIQ, CCM and STAR, the Shared Assessments SIG and the certificates and reports a customer may ask for are industry practice and voluntary guidance. They are not law. No law named here requires you to complete a customer's form, and completing one, or holding a certificate or report, is not a statement that you comply with NIS2, DORA, the GDPR or any standard. This pack cites each as its publisher states it.

This pack does not say which certificate, report or form meets a requirement of NIS2, DORA or the GDPR. Each reference says what its source asks of the customer or the provider and which CISO Times document helps with that work. Using a document does not by itself show that a requirement is met.

ISO/IEC 27001 references name the clause or control this document relates to, by number and title only. No text of the standard is reproduced. A reference does not say that meeting a clause or control meets any requirement of NIS2, DORA or the GDPR, or that your organisation holds a certificate.

These references show where this document supports an external framework. They indicate relevance only and do not reproduce the text of any standard.

Prepared by Zero One Cybersecurity · Published by CISO Times

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