As the UK prepares to introduce the Cyber Security & Resilience Bill (CSRB), organisations face a major regulatory shift that will reshape how they manage cyber risk and resilience.
Expected to be introduced to Parliament in 2025, this landmark legislation will replace the existing Network and Information Systems (NIS) Regulations 2018, broadening scope and accountability across the UK’s digital and operational ecosystem.
The upcoming Bill is not just another compliance hurdle; it’s a strategic wake-up call for every organisation connected to the UK’s digital infrastructure.
In our recent webinar, Cyber Security & Resilience Bill: What Does It Mean for Your Business? Philip Ridley, CyberOne’s Director of Cyber Risk Management, set out what’s changing and how to respond with practical steps that build compliance and resilience.
A New Era for UK Cyber Resilience
The CSRB is a core component of the government’s National Cyber Strategy, designed to strengthen resilience across critical infrastructure, public services and the wider digital economy.
It reflects the government’s recognition that secure digital infrastructure is fundamental to economic stability, innovation and investor confidence.
While the NIS Regulations provided a baseline for essential services such as transport, energy and healthcare, the CSRB extends further, covering a broader set of organisations, including Managed Service Providers (MSPs), data centres, cloud platforms and critical suppliers.
This wider scope reflects a hard truth: resilience can only be achieved when every link in the supply chain is secure.
“Resilience is the keyword that keeps coming up. The Bill is about ensuring organisations are not just reacting to incidents but anticipating and managing risk intelligently.”
– Philip Ridley, Director of Cyber Risk Management, CyberOne
Key Changes Businesses Need to Prepare For
1. Stronger Regulatory Powers
Regulators across sectors (from the ICO to Ofgem) will gain enhanced powers to monitor, investigate and enforce compliance.
Expect more frequent assessments, higher expectations for evidence and greater financial penalties for failure to comply.
2. Expanded Scope and Supply Chain Accountability
The Bill brings more entities into scope and introduces direct accountability for supply chain cyber risk.
If your organisation provides critical services to regulated sectors, you’ll need to demonstrate proactive security controls, not just within your own systems but throughout your extended digital ecosystem.
3. Stricter Incident Reporting
A new two-stage reporting framework will apply:
- Initial report within 24 hours of identifying a significant cyber incident (to both your regulator and the NCSC)
- Detailed report within 72 hours
Incidents affecting confidentiality, integrity or availability, not just service continuity, will trigger reporting obligations.
4. Alignment with NIS2
The Bill takes cues from the EU’s NIS2 Directive, ensuring consistency for UK businesses operating internationally.
Both frameworks emphasise:
- Broader inclusion of entities in scope
- Supply chain security
- Faster incident reporting timelines
- Greater financial penalties for non-compliance
This alignment means UK organisations already preparing for NIS2 will have a clear head start on CSRB readiness.
Demonstrating Compliance: The NCSC Cyber Assessment Framework
The NCSC’s Cyber Assessment Framework (CAF) will become the yardstick for demonstrating compliance.
CAF focuses on outcomes rather than checklists, enabling organisations to prove real-world cyber resilience rather than paper compliance.
It aligns with recognised standards like ISO 27001, NIST SP 800-53 and other frameworks, so existing governance and certification efforts can be leveraged.
Learning from Recent Incidents
Recent breaches underline why this Bill is so necessary:
|
Incident & Date |
What Happened |
Why It Matters |
Under CSRB (Implications) |
|
Synnovis |
Ransomware on NHS pathology supplier; stolen data later published online; NHS trusts impacted |
Classic third-party dependency risk across healthcare operations |
24-hour initial and 72-hour detailed reporting to the regulator and NCSC; stronger evidence of supplier risk assessment and visibility; likely customer notification duties for digital providers |
|
Collins Aerospace (September 2025) |
Cyber attack on airport software supplier disrupted check-in and baggage at Heathrow, Brussels and Berlin (delays rather than full outage) |
Supply chain weakness is causing CNI disruption at scale |
Airports must show proactive, threat-informed supplier risk management; if a supplier falls in scope, for rapid incident reporting; the regulator may issue remediation directions |
|
Capita |
£14m ICO fine for failures linked to a 2023 breach affecting millions of records |
Signals regulator's appetite to penalise weak monitoring and controls |
Beyond data-protection action, sector regulators could recover investigation costs and impose directions; reporting triggers include confidentiality and integrity impacts, not just outages |
Each of these incidents demonstrates the rising risk within interconnected supply chains. Under the CSRB, both the service operator and their suppliers could face regulatory consequences.
“The CSRB shifts cyber security from a reactive exercise to a proactive discipline. It demands visibility, preparedness and accountability at every level of the supply chain.”
– Philip Ridley, CyberOne, Director of Cyber Risk Management
Preparing for the CSRB:
3 Actions to Take Now
1. Understand Your Exposure
Determine whether you or your suppliers will fall under CSRB scope. Review contracts for audit rights, information-sharing clauses and incident-response obligations.
2. ModerniseRisk Management
Replace static annual reviews with threat-informed, continuous risk assessments
Include critical suppliers in your risk register and ensure assessments are evidence-based and regularly updated.
3. Strengthen Detection and Response Capabilities
Test incident response playbooks against the 24- and 72-hour reporting windows.
Ensure your teams can detect, triage and report incidents swiftly and that suppliers can do the same.
The Bigger Picture
The Cyber Security & Resilience Bill is more than compliance. It’s a signal that resilience is now a board-level business imperative.
Organisations that adapt early will be able to demonstrate trust, meet customer expectations and stay ahead of regulatory enforcement.
CyberOne is helping Managed Service Providers comply to the CSRB and ensure organisations are able to understand and assess the supply chain risk by navigating these changes with Microsoft-aligned, outcome-driven security services, turning regulation into resilience.
Stay Ahead of the Bill
CyberOne is hosting a series of expert sessions to help organisations prepare:
- Microsoft Ignite to Security Insight – 4th December, 14:00 UK Time
- Boardroom Briefing: The Imperative for Managed Security – Series running 27 thNovember – 11 December
Book your free 30-minute consultation with us to assess your exposure, understand your regulatory obligations and build a practical roadmap to compliance.