The Big Shift - UK Cybersecurity Resilience Bill
Why the Cybersecurity and Resilience Bill is Your 2025 Wake-Up Call
As the dust settles on the UK Government’s announcement of the Cyber Security and Resilience Bill, it’s clear that 2025 isn’t just another year; it’s the inflexion point.
This post kicks off “The Big Shift” blog series, designed to guide you whether you’re in IT, security, or leadership through the evolving compliance landscape. We’ll demystify the UK’s move toward NIS2 alignment, decode what it could potentially mean in practical terms and equip you with a roadmap to readiness.
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The UK’s Intent to Align with NIS2 – Decoded
While the bill isn’t a direct copy of the EU’s NIS2 Directive, one could assume it’s heavily influenced by it. Why? Because cyber risks don’t respect borders. This leads me to believe the UK’s approach appears to be: “NIS2-inspired, UK-tailored.”
Key Drivers:
- Rising threat landscape (think ransomware-as-a-service, supply chain breaches).
- Ever-growing number of state-sponsored threat actors.
- Economic impact of cyber incidents.
- A need for harmonisation with global standards — to avoid becoming the weakest link.
Expect:
- Broader sector coverage (beyond traditional ‘critical infrastructure’).
- Tighter reporting timelines (within 24–72 hours).
- Greater executive accountability (directors, this one’s for you).
- Potential for fines
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Why NCSC CAF Will Be the Framework of Choice
Unlike the EU, the UK has a powerful in-house capability: the NCSC Cyber Assessment Framework (CAF).
Why CAF?
- It’s already used by key sectors.
- Health care, Energy, Government
- Mapped to NIST, ISO 27001, and now increasingly aligned with NIS2 expectations.
- Flexible and risk-based, not just checkbox-driven.
Pro tip: CAF is not a standard. It’s an outcomes-based model. Expect more questions like: “Can you demonstrate that your supply chain is resilient?” rather than “Do you have antivirus?”
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What About ISO 27001 and CIS Controls?
If your organisation is already ISO 27001 or CIS Top 18 aligned, you’re not starting from scratch but don’t get complacent.
ISO 27001:
- Focused on management systems and policy.
- Less explicit on operational outcomes or supply chain due diligence.
CIS Controls:
- Technically strong but may lack governance focus required by NIS2 and potentially the UK Cybersecurity Resilience Bill.
CAF bridges both marrying strategy with operational resilience.
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What’s Changing in Scope? (Spoiler: Everything)
We’re not just talking about power grids or nuclear power stations anymore.
Who’s now in scope:
- Data Centres: Especially colocation and IaaS providers.
- Managed Service Providers (MSPs): If you support others’ critical functions, you’re likely caught.
- Cloud Providers, SaaS Vendors, and Connectivity Providers.
New risk categories could include:
- Disruptions to digital infrastructure
- Dependencies on foreign-hosted services
- Vulnerabilities in shared platforms
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Supply Chain Resilience is Non-Negotiable
The biggest shift? It’s not just about you anymore.
The bill explicitly raises the bar on third-party risk management. That means:
- Mapping your entire digital supply chain
- Regular cyber due diligence on suppliers
- Clauses in contracts mandating security baselines
- Ability to demonstrate supplier compliance (not just trust)
The NCSC CAF even includes a specific objective:
“Organisations should ensure the security of their supply chains and understand the risks posed by third parties.”
This is where the real work begins.
Coming Up in This Series
Over the next few weeks, we’ll dive into:
- How to Map CAF Outcomes to Your Existing Controls
- How MSPs and Cloud Vendors Can Get Ahead of Compliance
- Creating a CAF-based Risk Dashboard in Microsoft Purview
- Senior Level Accountability: What You Need to Know
- Free & Microsoft-based Tooling to Kickstart Readiness