Domain · D4

Sustainability & supply-chain resilience

How robust is the technical and geopolitical supply chain?"

1. Strategic relevance§

Sustainability and supply-chain resilience extends the assessment beyond the provider to the entire ecosystem on which the service rests. Even a sovereignly run provider is vulnerable if it relies on monopolised semiconductors, individual open-source maintainers or geographically concentrated data centres.

This domain addresses geopolitical choke points and silent dependencies — components that remain invisible in normal operation and can bring the service to a halt in a crisis.

D4 is the domain of strategic foresight. It demands robust diversification and realistic recovery assumptions.

2. Core criteria§

  • Full SBOM of the software in use

    Components, versions, maintainers, countries of origin — continuously current.

  • Hardware supply chain

    Semiconductors, network and storage components with manufacturer, production location and alternative sources.

  • Code-base dependencies

    Identification of critical dependencies on individual repositories, registries or maintainers.

  • Geopolitical choke points

    Components with concentrated origin (semiconductor manufacturing, fibre routes, DNS resolvers) and fallback strategies.

  • Diversification of critical components

    At least two independent sources for every security- or availability-critical component.

  • Source-code escrow

    Deposit of critical components with a trusted third party for re-commissioning in a failure scenario.

  • Availability of European alternatives

    Documentation of for which components EU alternatives are available, partially available or not available.

3. Audit questions (excerpt)§

  1. Which supply-chain components are geographically or legally concentrated?
  2. Are there at least two independent sources for every critical component?
  3. Is the SBOM complete, current and machine-readable?
  4. Which open-source components depend on individual maintainers or a single code forge?
  5. Is there a documented recovery procedure in case of failure of a geopolitically critical component?
  6. Is there a source-code escrow agreement for security-critical components?
  7. Which EU alternatives can realistically substitute each component within which time frame?

4. Accepted evidence§

  • Current SBOM with maintainer and origin information
  • Hardware bill of materials with production locations and alternative suppliers
  • Risk assessment of geopolitical choke points
  • Source-code escrow agreements with the depository
  • Substitution plan for critical components

5. Level thresholds in this domain§

LevelMinimum requirement in D4
L0Supply chain largely undocumented; no SBOM.
L1Full SBOM and hardware supply chain documented; choke points identified.
L2Diversified sources for critical components; documented substitution strategy.
L3Resilient to geopolitical choke points; viable EU alternatives for every critical component.

6. Relation to existing standards§

StandardWhat is coveredWhere EDSO goes further
NIS2Supply-chain security requiredGeopolitical concentration risks not systematically audited
Cyber Resilience Act (CRA)Security requirements for componentsSovereignty aspects not addressed
Supply-chain due diligence lawsHuman-rights and environmental due-diligence dutiesTechnical sovereignty supply chain not covered

7. Typical audit findings§

  • SBOM only for in-house development, not for third-party components
  • Dual sourcing for semiconductors, but in fact from the same foundry
  • Critical open-source dependency on a single maintainer without a backup maintainer
  • Source-code escrow without a documented recovery exercise
  • EU alternatives named but functionally not equivalent

8. Cross-references§