The UK is entering a decisive phase in its cyber security evolution.

With cyber attacks escalating in scale, complexity, and national impact, the government has proposed a significant new piece of legislation aimed at strengthening the resilience of critical sectors - most notably the NHS, local government, energy sector, and transport. These proposals represent one of the most ambitious updates to UK cyber regulation in over a decade, designed to protect the systems that underpin national wellbeing, economic stability, and public safety.

For organisations across these sectors, the shift is profound. What was once considered best practice is now becoming a legal baseline, and security measures previously regarded as “enhanced” will soon be mandatory. This legislation goes well beyond technical expectations, seeking to transform governance, accountability, and supply chain oversight. As the UK’s threat environment intensifies, the new framework recognises that national resilience cannot rely on pockets of excellence, and should instead be an enforceable, systemic and consistent effort across the sector.

PureCyber has long championed this level of maturity across critical industries. The new legislation aligns closely with trends we see on the front line, particularly through our threat intelligence, governance practice, and supply chain risk work. Below, we break down the government’s proposals in comprehensive detail and examine their implications for organisations across the UK.

A Major Overhaul of Cyber Regulation in the UK

The proposed legislation marks a shift in how the UK defines “critical infrastructure.” Historically, cyber regulation focused primarily on the largest operators - major hospitals, grid operators, water authorities, and national transport networks. But threat actors have learned to exploit the interconnected nature of public services and the third parties that support them.

This legislation closes that gap by broadening the scope of regulation to include IT managed service providers, cloud platforms, digital service operators, and other key suppliers whose compromise could bring down essential systems. For many suppliers, this represents their first introduction to legally enforced cyber security obligations - and substantial penalties for failing to meet them.

Expanding the Definition of Critical Digital Infrastructure

One of the most important changes in the proposal is the formal inclusion of IT, cloud, and digital service providers within the nation’s critical infrastructure ecosystem. This means that organisations previously considered “support services” will now be directly regulated due to the potential national impact of their compromise.

While the legislation still retains structured lists of “in-scope” systems, the government has significantly widened the categories to reflect the reality of modern digital operations.

For example:

Systems supporting NHS care coordination, regional mental health networks, emergency service dispatch, or core local authority platforms for housing, safeguarding, and social care may all fall under the new rules.

This step reflects a core truth: attackers do not need to compromise a major hospital to cause national disruption - they can simply exploit a smaller third-party provider that services dozens of hospitals simultaneously.

Regulation of IT and Digital Service Providers

The government’s proposal introduces a more detailed and prescriptive set of obligations for suppliers. Rather than relying on voluntary frameworks, the legislation mandates that digital service providers adopt robust controls across governance, technical security, risk management, and incident response.

Mandatory Security Controls

Digital service providers will be required to implement a layered, risk-based security framework that covers the entire lifecycle of their services.

This includes:

Secure configuration
Proactive threat detection
Least-privilege access
Continuous monitoring
Vulnerability management

Crucially, providers must be able to demonstrate these practices through audit-ready evidence.

Governance and Accountability

Boards will be formally accountable for ensuring compliant security practices. This means strategic oversight of cyber risk must be integrated into corporate governance structures, with named accountable individuals, documented cyber strategies, and clear lines of responsibility extending from directors down to operational teams.

Rigorous Incident Reporting

Providers must maintain processes capable of identifying, containing, and reporting cyber incidents within legally defined timeframes. This includes the ability to rapidly assess the national significance of an incident and notify relevant authorities such as the National Cyber Security Centre (NCSC).

Resilience and Continuity Requirements

The government expects suppliers to prove that they can continue delivering services even under adverse cyber conditions.

Preparations that must be demonstrated:

Robust backup processes
Alternative operating modes
Tested recovery plans
The ability to isolate affected systems quickly to prevent cascaded damage to the healthcare, public sector, or utilities they support.

Data Protection and Access Controls

Suppliers must implement strict access governance:

Multi-factor authentication as standard
Privileged access monitoring
Lateral Movement prevention controls

Data must be protected both in transit and at rest using modern cryptographic standards.

Supply Chain Oversight

Digital service providers must also assess and monitor the security posture of their own suppliers - closing a major vulnerability that attackers have repeatedly used to propagate through interconnected networks.

Examples of Critical Suppliers

The legislation provides illustrative examples of third-party services whose compromise could result in serious national disruption.

Cloud Hosting and Compute Providers

Major cloud platforms hosting electronic health records, local authority case management systems, energy monitoring tools, or national service portals hold enormous concentrations of data and operational capability. A compromise affecting availability or integrity could have national consequences - disrupting care, delaying benefits, or preventing energy distribution.

Managed IT Service Providers (MSPs)

MSPs often hold privileged access into multiple client environments, including NHS Trusts, councils, or social care providers. If an attacker breaches a single MSP, they may gain simultaneous access to dozens of critical organisations. Historical attacks on MSPs globally have demonstrated this risk with devastating clarity.

Communications and Network Operators

Providers responsible for NHS paging systems, secure communication networks for emergency services, public sector WAN infrastructure, or local government telephony can directly influence operational continuity. A targeted cyber attack on these providers could disrupt patient care, frontline emergency response, or housing services.

Digital Health and Care Platforms

This includes software used for GP appointments, remote triage tools, medication management systems, or digital care apps used by councils and charities. A compromise could expose extremely sensitive data or disrupt community care operations.

Specialist Operational Technology Suppliers

Suppliers supporting laboratory diagnostics, pharmacy automation, clinical devices, or building management systems within hospitals or care homes play a vital role in safety and operational resilience.

Incident Reporting Requirements

Under the new framework, incident reporting evolves from a regulatory formality into a core national defence mechanism.

Organisations will need the ability to:

Identify and Categorise Incidents Rapidly

Rather than waiting until a breach is fully understood, organisations must report incidents based on potential national significance. This includes suspected breaches affecting patient safety, public services, energy generation, or data integrity - even if the breach is not yet confirmed.

Provide Detailed, Actionable Information

Reports must include technical indicators, suspected attack vectors, potential systemic impacts, mitigation steps taken, and any risk of propagation through supply chains or interconnected systems.

Maintain Transparent Ongoing Communication

Initial reporting is not sufficient. Organisations must provide regular updates as investigations progress, ensuring authorities can coordinate national-level responses if needed.

Meet Strict Legal Timeframes

Delays in reporting; even when caused by investigation complexities - may result in legal penalties. The legislation emphasises the importance of rapid sharing of threat intelligence to prevent further exploitation.

Mandatory Resilience and Response Capabilities

Organisations will be legally required to maintain tested and demonstrable capabilities that ensure continuity of critical services during cyber incidents.

This includes the ability to isolate compromised systems without compromising essential functions, operate in degraded modes when necessary, and restore normal operations rapidly and securely.

Resilience will not be determined by documentation alone. Organisations must prove operational readiness through:

Executed disaster recovery tests
Evidence of offline or immutable backups
Practiced crisis management exercises
Simulated cyber attack scenarios
Regular reviews of recovery time objectives (RTOs) and recovery point objectives (RPOs)

The government emphasises that true resilience stems from real-world capability, not policy statements.

Why the UK Is Acting Now: Diving into the Threat Landscape

Over the past five years, the UK has experienced a surge in cyber activity targeting sectors essential to national wellbeing. The NHS has faced ransomware incidents impacting hospital operations, diagnostics, and community care. Local authorities have seen entire networks shut down for weeks. Energy providers and water companies have been probed by nation-state actors seeking access to operational systems.

The war in Ukraine, escalating geopolitical tensions, and the rise of AI-powered cyber tools have reshaped the risk environment. Attackers can now generate highly convincing phishing campaigns, automate reconnaissance, and mimic system behaviour in ways that evade traditional security tools.

Furthermore, the public sector continues to rely heavily on legacy systems, underfunded IT estates, and stretched cyber teams. Many rely on third-party providers who themselves vary widely in maturity and capability.

The convergence of these factors has made systemic disruption a genuine national risk.

The legislation is therefore not reactive, and instead acts as a significant preventative move, designed to future-proof the UK’s resilience before attackers can exploit these weaknesses further.

Sector Impacts: Healthcare, Local Government, and Energy

Healthcare

The NHS remains one of the UK’s most targeted sectors due to the sensitivity and value of patient data, reliance on interconnected systems, and the critical nature of clinical operations.

The legislation will require Trusts, ICSs, and digital health suppliers to adopt rigorous cyber controls, reduce legacy risk, enforce supply chain oversight, and demonstrate resilience in clinical environments where downtime is not an option.

Local Government

Councils manage systems that range from housing and benefits to social care and safeguarding. Many still rely on legacy platforms, fragmented supply chains, and overstretched IT teams.

The legislation will require councils to adopt more standardised security frameworks, monitor suppliers more aggressively, and ensure they can sustain essential services even during cyber disruption.

Energy and Utilities

Energy providers face increasing nation-state interest, with attackers seeking access to both IT and OT systems.

The legislation reinforces the need for strong segmentation, advanced detection, robust supplier management, and clear incident reporting protocols that prevent national impact.

Challenges Ahead

The new legislation will impose significant challenges across public and private sectors. Many organisations struggle with outdated infrastructure, limited budgets, and a shortage of cyber talent.

Implementing mandatory controls - especially around continuous monitoring, supply chain oversight, and rapid incident reporting, will require investment, cultural change, and sustained operational discipline.

Third-party suppliers may face a steep learning curve as they transition from voluntary standards to legally enforced compliance regimes. Meanwhile, regulatory bodies will need resources and capacity to oversee, audit, and enforce the expanded legal framework.

How PureCyber Can Help Organisations Meet the New Requirements

PureCyber provides end-to-end cyber security capabilities designed to align directly with the expectations of the new legislation.

Our CREST Certified SOC & human-led MXDR platform delivers 24/7 threat detection, investigation, and response - ensuring organisations can identify incidents quickly and meet strict legal reporting deadlines and offering supply chain risk management to help organisations assess, monitor, and uplift third-party providers to required standards, ensuring compliance across complex ecosystems.

PureCyber is recognised as an Assured Service Provider by the NCSC, and our governance and compliance specialists guide organisations through the development of cyber policies, accountability structures, and board-level reporting frameworks that align with regulatory expectations.

Our holistic model allows organisations to not only achieve compliance - but build genuine cyber resilience that reduces risk, protects operations, and supports long-term digital transformation.

Get in touch or book a demo for more information on our services and how we can safeguard your organisation with our expert cyber security solutions.

Email: info@purecyber.com Call: 0800 368 9397

The Future of National Cyber Defence: Inside the UK’s New Critical Infrastructure Cyber Security Legislation