Blog | Fitzrovia IT

Cyber Security and Resilience Bill 2025

Written by Henry | Jul 1, 2025 11:17:36 AM

 

Introduction


The Cyber Security and Resilience Bill marks a pivotal evolution in the UK's approach to national digital security. In an era where cyber threats are growing in frequency, scale, and sophistication, this legislation introduces a bold new framework designed to protect essential and digital services, manage supply chain risks, and ensure businesses are prepared to respond rapidly and effectively to incidents.

Who we are:

Fitzrovia IT is a leading provider of managed IT services and cybersecurity consultancy. We help organisations navigate complex regulatory environments and build cyber resilience through expert-led assessments, planning, and implementation.

What this guide covers:

This guide explains the rationale, scope, and requirements of the Cyber Security and Resilience Bill, breaking down its implications for UK businesses. It outlines key provisions, expected timelines, and the specific responsibilities organisations will need to adopt to comply with the new legal framework.

Why this bill matters to UK businesses:

The Bill expands regulation beyond traditional critical infrastructure, applying new obligations to managed service providers (MSPs), cloud services, and even small businesses designated as critical suppliers. It sets mandatory cybersecurity standards and formalises incident reporting, marking a decisive shift from voluntary compliance to enforceable requirements. Businesses that fail to adapt risk financial penalties, operational disruption, and reputational damage.

How prepared are you?

Many organisations, especially those outside the previously regulated sectors, are not yet equipped to meet the new demands. This guide provides practical guidance to assess your organisation’s readiness, mitigate cyber risks, and embed compliance into your operational strategy. With expert insights from Fitzrovia IT, we aim to help you move from reactive defence to proactive resilience.

 

Background: A Changing Cyber Threat Landscape


The frequency and severity of cyber incidents in the UK have grown significantly in recent years. The 2024 Cyber Security Breaches Survey found that half of all UK businesses experienced a cyber breach or attack in the past twelve months. Small and medium-sized enterprises (SMEs), which often lack advanced in-house defences, remain highly vulnerable, especially when integrated into larger digital supply chains.

Critical infrastructure has also come under direct threat. In 2023, a ransomware attack on an NHS supplier forced the postponement of over 11,000 outpatient appointments and procedures, putting patient safety at risk. Cyber attacks have also affected the Ministry of Defence’s payment network and local councils including Leicester City and St Helens Borough, demonstrating how widespread the problem has become.

According to the National Cyber Security Centre (NCSC), the threat landscape is both “diffuse and dangerous,” driven by hostile states such as Russia and China, as well as organised criminal groups. These actors are now leveraging artificial intelligence, off-the-shelf cyber tools, and increasingly sophisticated malware to target essential services.

The Government has accepted that voluntary compliance and existing frameworks are no longer adequate. While past legislation like the NIS Regulations 2018 and the GDPR established a baseline for digital security, new threats demand more active oversight and enforcement.

The Cyber Security and Resilience Bill is the most comprehensive legislative response to date. It not only updates the scope of regulation but also extends responsibilities to more organisations. This is including those that provide critical digital services, regardless of their size. This move reflects a broader understanding: national security and economic resilience are inseparable from digital resilience.

This legislation also draws on lessons from the EU’s NIS2 Directive, which similarly expands regulatory coverage and introduces more stringent cyber security requirements. The UK approach, while tailored to its threat profile, reflects the same urgency to modernise.

Precursor legislation to this bill:

  • GDPR (UK Data Protection Act 2018) focuses on data privacy and has limited scope when it comes to infrastructure and operational resilience.
  • NIS Regulations 2018 apply to five key sectors; transport, energy, drinking water, health, and digital infrastructure, but exempted many essential service providers, including Managed Service Providers (MSPs).

The new Bill fills these gaps by including data centres, MSPs, and key suppliers, and by enhancing regulator powers to enforce compliance across a wider range of sectors.

 

Overview of the Cyber Security and Resilience Bill


Key objectives of the bill:

The Cyber Security and Resilience Bill, as announced in the July 2024 King’s Speech, has three core aims:

  1. Expand the scope of regulated entities to include high-risk digital service providers, MSPs, and critical suppliers.
  2. Empower regulators with stronger oversight and cost recovery mechanisms to ensure more consistent and proactive enforcement.
  3. Improve national resilience by increasing the uptake of cyber defences and ensuring clearer, more timely incident reporting.

The Bill is designed to modernise the UK’s cyber security framework, aligning it more closely with current risks while maintaining a proportionate regulatory burden for industry.

The Bill will apply to:

  • Operators of essential services across sectors such as energy, transport, water, healthcare, and now data infrastructure.
  • Managed Service Providers (MSPs) and cloud service providers, which have previously been outside the regulatory scope.
  • Digital service providers, including online marketplaces, search engines, and relevant small-scale providers where their role is critical. 
  • Critical suppliers are identified by regulators as having a significant impact on the continuity of essential or digital services.

The legislation introduces a new designation for ‘designated critical suppliers’ (DCS), allowing regulators to impose cyber security requirements even on small businesses where appropriate.

  • April 2025 – Policy statement released and published in Parliament.
  • Late 2025 – Early 2026 – Expected to pass into law and enter implementation phase.
  • Phased rollout – Some requirements, especially those involving reporting obligations and supply chain security, will be subject to secondary legislation and industry consultation, with expected timelines running into 2026–27.


Key Provisions and Requirements


The Cyber Security and Resilience Bill introduces a set of new legal obligations designed to improve the UK's overall cyber resilience. It focuses on protecting essential services, managing digital risks across supply chains, and ensuring swift responses to cyber incidents. The following are the key areas addressed by the Bill:

Mandatory cybersecurity standards and controls

The Bill requires organisations, particularly those providing essential services or operating in critical sectors (such as energy, transport, health, and communications), to implement specific cybersecurity measures. These are not optional best practices, but legal requirements that include protecting IT systems from threats, managing who has access to sensitive data, keeping software up to date, and regularly checking systems for vulnerabilities. The goal is to ensure that core services remain operational and secure even in the face of cyber threats.

Supply chain risk management obligations

Modern businesses rely on complex networks of suppliers and partners, which can create hidden vulnerabilities. The Bill introduces a duty for organisations to understand and manage cybersecurity risks within their supply chains. This includes vetting third-party providers, adding cybersecurity clauses to contracts, and monitoring the security of suppliers on an ongoing basis. Organisations must take reasonable steps to ensure their partners do not become a weak link in their defences.

Incident reporting requirements

Under the new legislation, organisations will need to report significant cybersecurity incidents to the UK’s National Cyber Security Centre (NCSC) within a set timeframe, likely within 72 hours. These incidents might include serious data breaches, system outages caused by cyberattacks, or attempts to compromise critical infrastructure. The reports must include relevant details about what happened, the impact, and how the organisation is responding. Prompt reporting allows national authorities to provide support and better understand emerging threats.

Role of the UK Cyber Security Council and NCSC

The Bill formally recognises the roles of two key national bodies:

  • The UK Cyber Security Council will set professional standards for cybersecurity roles and promote the development of skilled experts across the industry.
  • The National Cyber Security Centre (NCSC) will remain the UK’s lead authority on cyber threats, offering guidance, support, and technical expertise to help organisations stay protected.

Together, these bodies will support organisations in meeting their obligations and improving overall resilience.

Enforcement powers and penalties

To ensure compliance, the Bill gives regulators stronger enforcement powers. These include the ability to carry out inspections, require organisations to make improvements, and issue penalties for serious failures. In extreme cases, fines could reach up to £17.5 million or 4% of global annual turnover, whichever is higher. The intention is to make sure that cybersecurity is taken seriously at the highest levels of leadership, and that organisations are held accountable for protecting their systems and services.

 

Implications for Businesses


Businesses operating in or supporting essential services will face expanded legal duties to protect digital infrastructure. This includes:

  • Implementing technical and organisational security measures.
  • Monitoring and reporting significant cyber incidents within 24 hours.
  • Managing risks in your supply chain, including conducting due diligence on vendors and possibly being designated as a critical supplier.

The Bill reflects a shift from broad recommendations to mandatory compliance with defined standards.

The operational impact will vary depending on your sector and size, but key changes will include:

  • Formalisation of cyber risk management practices across IT, procurement, and legal teams.
  • Adoption of frameworks such as the NCSC’s Cyber Assessment Framework (CAF).
  • Designation of internal roles for cyber security governance and incident response.
  • Possible restructuring of vendor contracts to meet new supply chain security obligations.

Area

GDPR

NIS Regulations 2018

Cyber Security and Resilience Bill

Scope

Personal Data

Essential services

Essential & digital services + MSPs

Incident Reporting

72 hours

Continuity-related only

24hr early alert + 72hr full report

Supply Chain

Limited

Minimal

Specific duties & designation powers

SME Exemptions

Some

Most small providers

Exemptions removed for high-risk SMEs

 

The Bill introduces a more risk-based and proactive approach, closing the regulatory gaps that previously allowed vulnerabilities to go unmanaged.

 

Preparing for Compliance: Recommendations from Fitzrovia IT


With the introduction of the Cyber Security and Resilience Bill, organisations across all sectors will need to take meaningful steps to align with new legal and regulatory expectations. While some organisations may already have strong cybersecurity foundations, others will need to take urgent action to identify and address gaps. Fitzrovia IT recommends the following practical measures to help organisations prepare for compliance.

Conducting a Cyber Risk Assessment

A cyber risk assessment is the first and most important step in understanding your organisation’s current security setup. This process involves identifying your critical systems and data, understanding how they might be targeted by cyber threats, and assessing the potential impact of an incident. It also helps you prioritise actions based on risk, ensuring that your resources are focused where they are most needed. At Fitzrovia IT, we can support this with structured assessments tailored to your size, sector, and level of cyber maturity.

Enhancing Incident Response Planning

Having a well-prepared incident response plan is essential for meeting the Bill’s reporting requirements and minimising disruption during a cyber event. This plan should clearly outline how your organisation will detect, contain, and recover from an incident, and who is responsible for each stage of the response. Regular testing, through simulated exercises, can reveal weaknesses and build staff confidence. An effective response plan not only protects your organisation but demonstrates accountability to regulators.

Reviewing Third-Party and Vendor Risk Frameworks

Many cyber incidents originate from outside the organisation, often via suppliers, partners, or service providers. That’s why it’s crucial to evaluate and, if necessary, strengthen the way you manage third-party risks. This might include updating supplier contracts with clear security expectations, conducting regular reviews of vendor practices, and limiting external access to sensitive systems. Fitzrovia IT can assist in reviewing your current frameworks and identifying areas where supplier-related risks can be better controlled.

Staff Training and Awareness

Human error remains one of the most common causes of security breaches. Building a strong culture of cyber awareness across your organisation is therefore vital. All staff understand how to spot common threats like phishing emails, know what to do in the event of a suspected breach, and feel confident using your internal reporting channels. Training should be engaging, practical, and refreshed regularly to keep up with evolving threats.

Documentation and Audit Readiness

Regulatory compliance doesn’t just depend on having the right processes in place, it also requires being able to prove it. This means documenting your security policies, procedures, risk assessments, incident response actions, and staff training records. Being "audit-ready" helps you respond quickly to any regulatory enquiries and shows that your organisation takes its obligations seriously. Fitzrovia IT provides guidance and templates to help make this process straightforward and scalable.

 

How Fitzrovia IT Can Support You



We provide a full range of services to help businesses meet the requirements of the Cyber Security and Resilience Bill:

  • Security audits
  • Compliance readiness planning
  • Incident response capability reviews
  • NCSC Cyber Essentials and Cyber Essentials Plus certification

Our team brings deep sector experience and stays aligned with the latest government guidance.

  • Tailored resilience strategies

No two businesses face the same risks. That’s why we design bespoke cyber resilience strategies, addressing your:

  • Sector-specific vulnerabilities
  • Internal IT governance structures
  • Regulatory exposure and readiness

We ensure your business isn’t just compliant but also prepared to withstand attacks and respond effectively.

  • Gap analysis and readiness assessments

Our cyber readiness assessments help you identify:

  • Where do you currently stand vs. the new legal requirements
  • What tools and practices need to be implemented
  • How to prioritise remediation without disrupting business

We provide a practical roadmap tailored to your risk level and industry.

  • Ongoing monitoring and support

We offer continuous support services, including:

  • Security Operations Centre (SOC) integration
  • Threat detection and response
  • Policy and documentation updates as laws evolve
  • Annual compliance reviews

Our goal is not just to help you pass an audit, but to build sustainable cyber resilience into the fabric of your organisation.

 

Conclusion

The Cyber Security and Resilience Bill represents more than a regulatory change, it is a call to action. As the threat landscape continues to evolve, the UK Government is making it clear: cybersecurity is no longer optional, and resilience must be built into the core of every organisation that supports essential services or digital infrastructure.

Why proactive preparation is critical:

Waiting until the Bill becomes law is not an option. The requirements around incident reporting, supply chain management, and designated critical supplier obligations are complex and demand time to implement. Proactive preparation allows organisations to assess gaps, build capacity, and develop a coherent response strategy before enforcement begins.

The business case for building resilience now:

Investing in cybersecurity is not just about compliance -it’s about continuity, reputation, and trust. A resilient organisation can withstand disruption, safeguard its clients and partners, and respond with confidence in the face of an attack. The steps you take today, whether assessing third-party risks, developing incident response plans, or training your staff, will directly impact your ability to protect assets and meet future legal expectations.

At Fitzrovia IT, we believe that building resilience is not just a regulatory necessity but a competitive advantage. With the right support, organisations can turn compliance into capability, and capability into confidence. Contact us today.