Purpose and Scope

The Cyber Security and Resilience (Network and Information Systems) Bill (Bill 329, first read on 12 November 2025) is designed to modernise and extend the United Kingdom’s legal framework for protecting essential digital infrastructure. It builds upon and significantly strengthens the Network and Information Systems Regulations 2018 (the “NIS Regulations”), which were originally introduced under EU law. The new Bill represents a domestically updated framework intended to safeguard critical sectors against an evolving and increasingly complex cyber threat landscape.

The Bill’s central aim is to ensure that essential services, public authorities, and digital infrastructure across the UK are secure, resilient, and capable of responding effectively to cyber incidents and operational disruptions. It achieves this by expanding the categories of organisations that must comply with cybersecurity and resilience obligations, increasing the powers of government and regulators to direct and enforce compliance, and creating mechanisms for cost recovery and coordinated response.

This framework applies not only to Operators of Essential Services (OES)—such as those in energy, transport, water, health, and digital infrastructure—but also to Relevant Digital Service Providers (RDSPs) such as online marketplaces, search engines, and cloud computing platforms. In addition, it extends regulation to Managed Service Providers (MSPs)—companies that manage, monitor, or deliver IT and cybersecurity services on behalf of others—and to critical suppliers that underpin essential or digital services through supply chains or system dependencies. The Bill also imposes specific duties on public authorities that act as competent authorities or regulators, ensuring consistency across oversight and enforcement.

The legislation therefore represents a shift from a narrow focus on “essential operators” toward a comprehensive national approach that recognises the interconnectedness of modern digital infrastructure and the cascading impact of supply-chain vulnerabilities.

Structure of the Bill

The Bill is divided into four principal parts, each of which updates or supplements a distinct aspect of the UK’s cybersecurity regime.

Part 1 – Introduction

Part 1 sets out key definitions and establishes how the new Act interacts with existing cybersecurity law. It clarifies that all subsequent provisions amend or supplement the NIS Regulations 2018 and ensures legal continuity for organisations already regulated under those rules. This section provides the legal foundation for the expanded framework and confirms that all references to “the NIS Regulations” henceforth include the amendments introduced by the CSBR Bill.

Part 2 – Amendments to the NIS Regulations

Part 2 delivers the substance of the Bill by revising the 2018 Regulations to reflect new realities in digital infrastructure and threat management.

New Regulated Entities

A major change introduced by the Bill is the expansion of who counts as a regulated entity. Data centres, previously outside the scope of the NIS Regulations, are now formally designated as “operators of essential services.” This recognises the critical role that large-scale data storage and processing play in economic continuity and national security. Similarly, “large load controllers”—systems responsible for managing energy distribution and grid stability—are brought under regulation due to their central role in maintaining essential energy operations.

The Bill also revises the definitions of digital service providers, creating a broader category of “relevant digital services” to encompass not only online marketplaces and search engines but also evolving forms of cloud and platform infrastructure. Importantly, it adds managed service providers as a new regulated group. This reflects the reality that many businesses outsource critical IT and security functions, making MSPs potential points of systemic vulnerability. The inclusion of critical suppliers gives regulators the flexibility to bring high-risk third parties under oversight where their disruption would endanger essential services.

Incident Reporting and Information Sharing

The Bill introduces much stricter requirements for incident reporting and transparency. Regulated entities must now report cybersecurity or service incidents to their competent authority—and, where applicable, to affected customers—within a defined window, typically 24 to 72 hours depending on severity. These requirements aim to ensure timely awareness of potential disruptions and to enable coordinated national responses.

The Information Commissioner and CSIRT UK (Computer Security Incident Response Team) are granted enhanced coordination powers, ensuring that incident data can be aggregated, analysed, and acted upon quickly. Entities must also notify customers or users when their data or service access could be compromised, increasing accountability and trust.

Enforcement and Cost Recovery

Regulators are given explicit statutory authority to impose charging schemes to recover the costs of supervision and enforcement. This ensures that compliance oversight is sustainably funded. Enforcement powers are clarified and strengthened, allowing competent authorities to carry out investigations, issue compliance notices, and impose financial penalties for non-compliance. The Bill also standardises appeal routes for regulated entities, ensuring transparency and due process.

Information Sharing and Guidance

To promote consistency across sectors, the Bill authorises wider data-sharing between enforcement authorities, GCHQ, the Secretary of State, and approved foreign partners. This coordinated approach aims to improve situational awareness across interconnected networks and international borders, while still requiring that sharing be proportionate and confidential. Regulators must also issue or align with national codes of practice that set out detailed guidance for compliance, bringing much-needed clarity to industry obligations.

Part 3 – Security and Resilience of Systems (Secretary of State Functions)

Part 3 centralises strategic oversight of cybersecurity and resilience within government. It empowers the Secretary of State to define what constitutes “essential activities”—those services or functions considered critical to the economy, national security, or daily life. This definition can evolve over time, allowing the regime to adapt to technological and sectoral changes.

The Secretary of State is also required to issue a Statement of Strategic Priorities (SSP) outlining the UK’s long-term cybersecurity objectives. Regulators must align their activities and regulatory decisions with this statement, ensuring coherence across sectors. The SSP thereby becomes the guiding framework through which the government can steer national cyber-resilience policy.

Part 3 further establishes the authority to make secondary legislation covering the security of systems, regulatory powers, penalties, and cost recovery mechanisms. This flexible legislative tool allows government to respond rapidly to emerging technologies or threats without requiring an entirely new Act of Parliament.

In essence, Part 3 provides the legal foundation for a whole-of-government approach to resilience—allowing the UK to coordinate oversight of digital infrastructure across both public and private sectors, from data centres and communications networks to cloud ecosystems.

Part 4 – Directions for National Security Purposes

Part 4 introduces new powers enabling the Secretary of State to issue binding directions to any regulated entity when a cyber or operational threat presents a risk to national security. These directions may compel or restrict particular actions, technologies, or business relationships in order to mitigate or eliminate risk.

Such directions can require the removal of specific hardware or software, prohibit the use of certain suppliers or technologies, or mandate security-enhancing measures. The Secretary of State may also require that a “skilled person”—an independent technical expert—be appointed to monitor or oversee compliance with these directions.

To balance these far-reaching powers, the Bill imposes safeguards: all directions must be necessary and proportionate, subject to internal and Parliamentary scrutiny, and limited to cases where national security considerations genuinely justify intervention. In highly sensitive cases, some details may be withheld from Parliament to prevent disclosure of classified information.

Part 4 therefore serves as the government’s direct intervention mechanism, allowing it to act quickly to protect the national interest during serious cyber crises or systemic risks.

Oversight, Enforcement, and Cooperation

The CSBR Bill formalises the roles of multiple oversight bodies. Sectoral regulators—such as Ofcom, Ofgem, and NHS England—retain responsibility for enforcing compliance within their respective sectors, while the Information Commissioner continues to oversee cross-sector information and data-related obligations. The National Cyber Security Centre (NCSC) and GCHQ play a central coordinating role, receiving periodic incident data and providing technical support to regulators.

The Bill enables regulators to levy annual charges or fees on regulated entities to fund ongoing supervision. These funds support continuous monitoring, capability development, and joint incident exercises. It also streamlines the flow of intelligence between authorities, establishing lawful gateways for sharing information both domestically and internationally.

By encouraging cooperation between the UK and overseas regulators, the Bill acknowledges that many cyber threats cross borders and that resilient systems depend on international coordination. It thus embeds a network of information-exchange mechanisms to facilitate rapid cross-jurisdictional response.

Impact and Beneficiaries

For government, the Bill consolidates cybersecurity policy and oversight under a clearer national framework. It empowers the Secretary of State to define priorities and direct responses, enabling faster decision-making during crises and improved strategic coordination across departments and regulators.

For critical infrastructure operators and private industry, the Bill brings both new obligations and greater clarity. Businesses operating in sectors newly classified as essential—such as managed service providers and data-centre operators—must now meet regulated standards for risk management, incident response, and resilience planning. At the same time, the new structure clarifies what is expected of them and provides unified guidance that replaces the fragmented landscape of voluntary standards and inconsistent regulatory expectations.

Consumers and end users stand to benefit through faster notification and remediation of service-disrupting or data-compromising incidents. The mandatory customer-notification requirement ensures that individuals and organisations receive timely information to take protective measures when a service they rely on has been compromised.

For regulators, the Bill formalises funding and authority, allowing consistent enforcement across sectors. Cost-recovery mechanisms relieve government budgets while ensuring that oversight is properly resourced. Enhanced coordination with GCHQ and other authorities improves threat intelligence sharing and resilience planning.

Overall Meaning and Implications

The Cyber Security and Resilience (Network and Information Systems) Bill represents the next phase of the UK’s cybersecurity evolution. It moves the legal framework beyond compliance for “essential operators” to a proactive model of national cyber-resilience governance. By embedding supply-chain regulation, cross-sector coordination, and strategic oversight, the Bill recognises that modern digital risks are systemic, not isolated.

Its provisions allow the UK to adapt to emerging technologies—such as AI-driven infrastructure, distributed cloud environments, and global managed-service ecosystems—while maintaining public trust and national security. In doing so, it reinforces the UK’s position as one of the leading jurisdictions globally to integrate cyber risk, operational resilience, and national-security policy within a single legislative framework.

In summary, the CSBR Bill provides government with the tools to protect the nation’s critical systems, gives regulators the authority to act decisively, and establishes clear, enforceable expectations for the private sector. It is therefore both a continuation and a transformation of the UK’s cybersecurity law—shifting the focus from compliance to resilience, from isolated oversight to unified national strategy.

Anticipated Industry Pushback and Enforcement Challenges

While the CSBR Bill has been broadly welcomed as a long-overdue modernisation of the UK’s cyber-resilience regime, many of its provisions are likely to encounter strong resistance as it progresses through Parliament. Several affected industries are already signalling concerns about compliance costs, the scope of regulation, and the potential for overreach.

Areas of Likely Pushback

Managed Service Providers and Data Centres – These sectors are being newly brought under direct statutory control. MSPs argue that they already comply with demanding contractual standards and international frameworks such as ISO 27001 and SOC 2. They contend that additional regulation could create duplicative audits and disproportionate cost burdens, especially for small and mid-tier service providers. Data-centre operators have raised similar objections, warning that mandatory registration, compliance reporting, and customer-notification requirements could deter foreign investment in UK-based facilities.

Cloud and Digital Platforms – Revised definitions of “relevant digital services” have expanded the regulatory perimeter to include a wide array of cloud and platform businesses. Many firms believe that the Bill fails to distinguish adequately between infrastructure providers, resellers, and hybrid services, potentially capturing businesses that are not truly critical. Ambiguity over scope could cause inconsistent enforcement, with similar companies being treated differently depending on regulator interpretation.

Energy and Load-Control Systems – Energy-sector intermediaries and technology firms involved in load balancing and smart-grid operations argue that they are being placed under obligations designed for large utilities. They fear that the Bill could stifle innovation in distributed energy technology by imposing industrial-scale compliance regimes on relatively small operators that enable smart-energy ecosystems.

Critical Suppliers and Supply Chains – The new ability for regulators to designate “critical suppliers” raises predictable anxiety among subcontractors and technology vendors. Suppliers that do not interact directly with end-users could suddenly become subject to full regulatory duties if their services are deemed essential to national continuity. Without clear designation criteria or consultation procedures, industry bodies warn of regulatory uncertainty and market distortion.

Cross-Border Providers and Information-Sharing Provisions – The Bill’s authorisation of information exchange between UK authorities and overseas regulators has prompted concern among multinational firms regarding commercial confidentiality and data-protection conflicts. Businesses fear that sensitive technical or contractual details could be shared without adequate safeguards or redress, exposing them to competitive disadvantage or legal risk in other jurisdictions.

Compliance Friction Points

The Bill’s new 24- to 72-hour incident-reporting windows are viewed as particularly challenging. Large multi-tenant service providers note that attribution and scoping often take several days, meaning that early reports may be incomplete or inaccurate. There is concern that the obligation to notify customers “likely to be affected” could force premature or overly broad disclosure, causing reputational damage and confusion.

Mandatory customer-notification duties also expose companies to new liability risks. Many firms are pressing for safe-harbour provisions protecting those that report incidents in good faith based on preliminary data.

The national-security direction powers given to the Secretary of State may become contentious. Businesses are wary of directives compelling them to remove products, sever vendor relationships, or adopt specific technologies, especially when decisions are taken on classified grounds without full parliamentary transparency. They will likely lobby for clear necessity tests, independent review, and appeal mechanisms.

Finally, charging schemes allowing regulators to recover supervision costs could face challenge as an unfair levy. Industry groups will seek transparency on how fees are calculated and assurances that charges remain proportionate to actual oversight effort.

The “Pay-the-Fine” Dilemma

A recurring criticism is that the Bill could create economic incentives for non-compliance if penalties remain lower than the cost of full remediation. Some firms may opt to treat fines as a manageable business expense rather than overhaul legacy systems. The draft legislation leaves fine levels and escalators to be defined later by regulations, raising concern that enforcement may lack deterrent force.

This risk is heightened by the fact that regulators can recover supervision costs regardless of compliance outcomes, which sustains oversight activity but not necessarily deterrence. To counter this, Parliament may be urged to introduce turnover-linked penalties, repeat-offender multipliers, and the possibility of temporary suspension of service licences for egregious cases. Clear linkage between compliance and access to public-sector contracts could also provide a stronger behavioural driver than monetary fines alone.

Enforcement Capacity and Consistency

Even the strongest legal tools depend on execution. There are doubts about whether all regulators possess the technical depth, staffing, and forensic capability to perform the sophisticated cyber oversight envisioned by the Bill. Unless adequately funded, smaller regulators may struggle to apply the law consistently, creating the risk of regulatory arbitrage—where firms focus on less-active sectors to minimise scrutiny.

Consistency in interpretation and penalty setting will therefore be critical to credibility. Regulators will need to collaborate closely with the NCSC and GCHQ to share expertise, coordinate investigations, and develop uniform codes of practice.

Implications for DFIR under a Tougher Regime

For the Digital Forensics and Incident Response community, tighter enforcement and faster reporting timelines will translate into a sustained rise in demand for forensic readiness planning, evidence preservation, and compliance-aligned response documentation. Organisations will increasingly require forensic specialists to validate incident records before submission to regulators and to manage the interface between regulatory disclosure and legal privilege.

DFIR professionals will also play a critical role in implementing the “skilled person” oversight provisions—acting as independent assessors during post-incident reviews. However, they will need to balance investigative thoroughness with rapid operational recovery, a tension that will define the new compliance landscape.

Conclusions and Implications

The CSBR Bill therefore stands as both a milestone and a test for the UK’s cyber-governance model. It provides government and regulators with unprecedented authority to safeguard critical systems, yet it also challenges them to wield that authority fairly, consistently, and proportionately.

For Regulators

They emerge as central actors in the national resilience framework, but their success will depend on adequate resourcing, consistent interpretation, and the ability to attract and retain technical expertise. Regulators must avoid becoming reactive enforcers; instead, they should function as strategic partners that guide industries toward verifiable resilience.

For Government

The Bill gives ministers a powerful command structure but also increases political accountability. Each major cyber incident will now test not only corporate defences but also the government’s ability to coordinate and direct an integrated national response. Transparent criteria for directions and penalties will be essential to maintain industry trust.

For Industry

While compliance will be costly, resistance carries greater long-term risk. Firms that treat cybersecurity as a regulatory checkbox may face cumulative penalties, procurement exclusion, or reputational decline. Those that embed resilience into governance and culture, however, may find themselves at a competitive advantage as trust and reliability become market differentiators.

For Consumers

Greater transparency and faster notification enhance digital trust and empower users to protect themselves. The regime should, over time, reduce large-scale service disruptions and improve confidence in cloud and digital infrastructure—provided enforcement remains credible and proportionate.

For the DFIR Community

Digital forensics and incident response move from peripheral technical services to strategic compliance functions. The profession will be pivotal in helping organisations meet statutory reporting obligations, conduct defensible investigations, and liaise effectively with regulators and law-enforcement partners.

Overall Conclusion

The Cyber Security and Resilience Bill is both a strengthening and a stress test of the UK’s cybersecurity ecosystem. If implemented thoughtfully—with balanced penalties, transparent oversight, and genuine collaboration—it could set a new international benchmark for cyber-resilience governance. If handled poorly, it risks burdening innovation, encouraging minimal compliance, and over-centralising decision-making power.

The months ahead in Parliament will therefore determine whether the Bill becomes a model of progressive cyber governance—or a cautionary tale of regulatory overreach. Either way, it has already shifted the national conversation from cybersecurity as a technical challenge to resilience as a shared public responsibility.

References

• UK Parliament, Cyber Security and Resilience (Network and Information Systems) Bill, Bill 329 (2025).
• Network and Information Systems Regulations 2018 (NISR 2018).
• National Cyber Security Centre (NCSC) guidance on cyber resilience and incident reporting.
• Department for Science, Innovation and Technology (DSIT) and related policy papers on NIS reforms.
• Industry consultations and public responses from managed service providers, cloud platforms, and critical infrastructure operators.