Over the last year, a series of devastating cyber incidents have severely disrupted organisations across the UK, writes Ed Felix, Principal Consultant, Beyond Blue.
High-profile incidents, such as those impacting Jaguar Land Rover (JLR) and Marks & Spencer (pictured) have highlighted the scale of the threat, with the recently formed Cyber Monitoring Centre (CMC), defining the attack on JLR as a Category 3 systemic event, carrying the potential to cost the UK’s economy up to £2.1 billion. These events serve as a stark reminder of the critical need for the UK to become a more cyber resilient nation.
In response to these events, the Cyber Security Resilience Bill (CSRB) has recently been introduced to parliament. The goal of the regulation is to deliver stronger protections for the UK’s most critical services; seeking to address vulnerabilities and ensure that Operators of Essential Services(OES) are better equipped to withstand and respond to future cyber threats.
The CSRB is more than a mere revision of the NIS Regulations (2018); it is set to transform how critical infrastructure, Managed Services Providers (MSPs) and their critical suppliers will become more resilient against cyber-attacks. While the Bill is an amendment to the NIS Regulations (2018), it expands regulated entities and introduces new powers and duties for authorities, while shifting the focus from cyber risk to cyber resilience. Key changes include:
- Expansion of regulated entities: Data centres, managed service providers (MSPs), and critical suppliers are now explicitly in scope.
- New incident reporting obligations: Initial notification within 24 hours, full report within 72 hours, and mandatory customer notification for significant incidents.
- Board-level accountability: Directors and boards are now legally responsible for cyber risk oversight.
- Supply chain security: Regulators can designate “critical suppliers” (including SMEs) for direct regulation, closing previous loopholes.
- Powers of the Secretary of State: The Secretary of State can issue binding directions for national security, override other regulations, and expand the regulatory perimeter without further primary legislation.
- Significant penalties: Fines up to £17 million or 4% of global turnover for non-compliance.
Implications
The CSRB represents a decisive shift in the UK’s approach to national cyber defence, establishing resilience as a core pillar of both national security and economic stability. By empowering the Secretary of State and regulators with agile, delegated powers, the Bill enables a rapid and flexible response to evolving threats.
Regulators will play a pivotal role in translating the Bill’s intent into enforceable law, and it will be crucial to observe how they influence boards and executive teams to prioritise cyber resilience at the highest level. The government’s ability to expand the regulatory perimeter, designate new critical suppliers, and issue binding directions without further primary legislation introduces both significant opportunity and uncertainty.
Organisations must invest in regulatory intelligence to anticipate and adapt to these changes. Resilience will increasingly be shaped by how organisations adapt to the evolving nature of cyber risk. It is no longer sufficient to secure only internal systems; resilience must extend across all critical dependencies, including MSPs, data centres, and key suppliers. Enforcement is also set to become significantly more robust, with turnover-based penalties and rapid incident reporting requirements designed to drive meaningful behavioural change.
According to the government’s impact assessment, cyberattacks cost the UK economy approximately £14.7 billion annually. By fostering greater visibility of cyber threats and encouraging collective action, the Bill aims to reduce both the cost and impact of incidents.
For those already subject to operational resilience requirements, the challenge will be to align and integrate CSRB obligations with existing frameworks, avoiding duplication and ensuring a coherent, enterprise-wide approach to cyber risk. Ultimately, the CSRB demands leadership, sustained investment, and a culture of continuous improvement to build a truly resilient digital nation.
Path to resilience
To build true cyber resilience in line with the CSRB, organisations must embed cyber risk management within their risk frameworks, integrating cyber into corporate risk registers and planning cycles, while ensuring security initiatives fully align with business strategy. Strengthening governance structures is essential, and defined roles that link security to business leadership, which is underpinned by transparent reporting, is also vital. Board advisory and initiatives like VCISO can help leadership teams navigate emerging expectations and embed cyber risk across their organisation. Championing a security-led culture is equally important, as responsibility for cyber risk should be shared across all functions. Regular incident exercising, and assessing controls through security assessments helps embed this culture and tests organisational readiness.
Regulators are also increasingly looking to recent regulations, such as the EU NIS2 Directive and the EU Cyber Resilience Act (CRA), for guidance and best practice.
However, the intention is not to drive another round of compliance assessments for their own sake. Instead, these regulations provide a framework to guide organisations on where to start, with the ultimate goal of changing behaviours and embedding resilience into day-to-day operations. However, preparing for compliance requires more than just technical controls. Newly in-scope entities will benefit from independent reviews of their security posture to identify gaps and help demonstrate readiness to regulators.
Finally, while the Bill mandates enhanced monitoring and incident reporting, investment in tools alone is not sufficient. Organisations must focus on translating threat intelligence into actionable insights and identifying the cyber risks that truly matter to them, drawing on specialist regulatory experience to navigate these requirements with confidence. Overall, the CSRB is more than a compliance exercise; it’s a strategic reset for the UK’s digital future.
By expanding the regulatory perimeter, embedding supply chain security, accelerating incident reporting, and empowering regulators, the Bill lays the groundwork for a more resilient, responsive, and secure national infrastructure.
