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Amid rising attack costs estimated at £14.7 billion, breaches involving Microsoft, Jaguar Land Rover, the NHS, and the Ministry of Defence highlight concerns about organisational preparedness to cyber-attacks and the wider business continuity in the event of such an attack. Although cyber-attack techniques vary, the key issue is how well firms can manage and respond to cyber breaches swiftly, with minimal disruption to operations and stakeholder confidence. Recent updates and developments to UK cyber regulations and the government's approach reflect a growing commitment to cyber resilience. The government’s evolving stance and new requirements shape how organisations must approach their compliance and resilience efforts, from tick-box compliance to genuine, board-endorsed cyber resilience. As such, the Cyber Assessment Framework (CAF) plays a critical role in demonstrating baseline compliance for the expected Cyber Security and Resilience (Network and Information Systems) Bill across government, critical infrastructure, and regulated sectors. It now underpins the UK Government Cybersecurity Strategy 2022–2030. While the Bill focuses on network and information systems resilience, organisations must consider other legal touchpoints including aspects of data protection, operational resilience, AI governance, outsourcing rules, and sector‑specific supervisory frameworks. A fragmented compliance approach will be insufficient; the direction of travel clearly favours integrated risk management (particularly needed where you are looking to integrate these requirements as part of a wider, multi-jurisdictional framework). Increasingly, cyber resilience expectations are not confined to regulated entities alone, but are cascading across supply chains, creating indirect but material operational and commercial impacts. Forward‑looking organisations are therefore aligning cyber resilience efforts with privacy, compliance, legal, audit, and procurement functions to create a unified compliance model, reducing duplication and demonstrating a more mature regulatory posture. For organisations operating across multiple jurisdictions, the Bill heightens the operational challenge of harmonising cyber response processes. Divergences between the UK and the existing EU NIS2 regimes mean that a single global incident may trigger different notification obligations, risk thresholds, and governance requirements across regions. Organisations should ensure their incident frameworks are agile enough to handle multi‑regulatory reporting without causing operational delay or compliance conflicts. These changes are the latest in a long line of globally diverging cyber requirements that need to be understood and accounted for in a practical and defensible manner. Recent developments in the UK Cyber Resilience The Bill, which is currently before parliament as part of the approval and refinement process, represents a key regulatory step, signalling that the UK is raising the bar to counter escalating digital risks. The Bill builds on the UK’s 2018 NIS Regulations, integrates lessons learned and recent technological advancements and the types of sophisticated threats, and aligns with the EU's NIS 2 Directive, aiming to build a robust digital ecosystem. CAF version 4.0 is the most significant update since its 2018 launch. The updated CAF captures cyber security risk management outcomes across cyber domains and contains over 100 new indicators of good practice which organisations should aim to achieve in a manner that can be demonstrated to regulators. The UK Government has announced a £210 million Cyber Action Plan2 to boost the public sector and its cyber posture by pushing accountability to EXCO-level leadership, making cyber a board agenda item, and treating it as a national issue that requires a more coordinated response across the organisation. The emphasis on multidisciplinary teams working on cyber preparedness as more businesses move digital is prudent, helping them be better prepared for unavoidable cyber incidents. To tackle this more effectively, the UK government has created a new Cyber Unit to govern the strategic direction of cyber resilience management. Lastly, the latest National Cyber Security Centre (NCSC) alerts and guidance published in the past few months including: rising state-aligned hacktivist disruption (Jan 2026)3, new joint CISA–NCSC guidance for operational technology (OT) security (Sept 2025)4, Cyber Essentials Supply Chian Playbook (Dec 2025)5 updated Cyber Essentials6 requirements effective April 2026 and the heightened severe-threat environment impacting UK critical national infrastructure (Feb 2026)7. Deep Dive: The Bill Expanded Regulatory Scope The new Bill has expanded in scope and now covers a broader range of organisations that need to demonstrate compliance with cyber resilience requirements. The extended scope of organisations now includes: Data centre operators above specified capacity thresholds; Managed service providers providing ongoing connected IT management; Organisations designated as critical suppliers due to the potential impact of their disruption on essential services; and A clearer and modernised set of regulated digital service providers. This expansion introduces new obligations for a wider set of organisations (and is extra-territorial in scope where services are being provided into the UK). As a result, more entities must now regard the CAF as a baseline to demonstrate cyber resilience compliance. Previously, this requirement applied mainly to government or critical national infrastructure. In practice, the impact of the Bill will extend beyond those directly in scope. Organisations operating within the supply chains of operators of essential services, managed service providers, and critical infrastructure entities will experience indirect regulatory pressure. This will manifest through enhanced: Customer-led due diligence and assurance requirements Contractual obligations relating to cyber controls and resilience Ongoing monitoring, audit and reporting expectations As a result, many organisations not formally classified as in-scope will need to align to similar resilience standards in order to remain commercially viable. Strengthened Duties and Enforcement Stricter incident reporting requirements: To showcase proactive threat intelligence and the business's wider preparedness for detecting and resolving cyber incidents, organisations should notify the applicable regulator as soon as possible, or within 24 hours, whichever is sooner, and also provide a full investigation report within 72 hours. An increasingly scrutinised area is expected to be how organisations assess whether an incident meets the statutory reporting threshold. Misclassifying an incident may constitute a regulatory breach in itself. As international regulators adopt a more assertive supervisory stance, organisations will need a defensible methodology for incident triage, documentation, and escalation supported by legal and forensic advisors. Strengthened supply chain security: Supply-chain resilience becomes a statutory obligation. Regulators will get new powers to identify and designate specific high-impact suppliers as ‘critical suppliers’, with obligations equivalent to those of Operators of Essential Services (OES). Enhanced enforcement powers: OES also face broader oversight, as regulators gain new powers to request information proactively, conduct inspections, and issue turnover-based penalties for serious failings. The Bill also elevates resilience expectations, requiring operators to demonstrate robust business continuity planning, risk management, and governance aligned to national standards. Developing a roadmap for effective cyber resilience compliance A practical phased pathway to align with emerging cyber regulatory expectations is outlined below. Phase 1: Baseline and Discovery 1. Applicability of scope and current state view Identify how the recent changes in the Bill and wider regulatory changes impact your organisation. For instance, are you in the newly scoped categories under the Bill, such as a managed service provider, data centre operator, or critical supplier? This includes interpreting the thresholds under the Bill and assessing corresponding regulatory exposure (not solely in the UK but within your existing global cyber threat management framework). Integration of the requirements of all applicable regulations into an overarching cyber security framework remains a key step for all businesses. Much of the operational detail of the Bill will be delivered through secondary legislation and sector‑specific guidance. Organisations should expect further clarity on reporting formats, thresholds, audit criteria, and technical standards. Early alignment with legal counsel enables a more agile response as these additional materials are released. 2. Conduct a CAF 4.0 gap assessment Evaluate your cybersecurity landscape, including your governance, controls, threat understanding, asset management, software development, monitoring, and recovery capabilities. Ensure you use the updated CAF version 4.0 controls and implementation guidelines as your benchmark to document the gaps and the effort required to remediate them. Do so considering a risk-based approach, immediate priorities, budget considerations, and the extent to which you will need external support from advisors and expert consultants. Meet all the objectives of the updated CAF including: an explicit requirement to understand adversary threats and integrate threat intelligence into risk decisions; a dedicated outcome for secure software development and lifecycle management; furthermore, expectations have increased for monitoring behavioural analytics, conducting threat hunting, and providing enriched logging; in addition, there are now stronger requirements for realistically tested response and recovery plans that include suppliers; integration of AI-related risk across the framework; and finally, CAF now demands real-world performance maturity and measurable outcomes, moving beyond checklist compliance. Where applicable, involve data protection, legal and AI governance teams to ensure a more holistic coverage of gaps during the assessment. 3. Map critical supply chain dependencies Identify which suppliers in your business are critical and assess their cyber maturity using a risk triage method, classifying suppliers as high, medium, or low risk. Ensure the definition of the categories of risks attached to a supplier aligns with business-critical and IT/Cyber-critical definitions. Do so by aligning with the business stakeholders, including relevant business functions and support functions such as procurement, IT, and Cyber. Conduct an overall supplier due diligence exercise (starting with your most material contracts, on a risk-prioritised basis thereafter), including a legal review of supplier contracts to identify gaps in audit rights, notification duties, liability allocation, and minimum-security standards that may require renegotiation under the new regime. Phase 2: Capability Uplift 4. Establish threat-informed governance As part of the existing cyber resilience governance forum, integrate threat intelligence into wider risk decisions and the business's risk appetite, and ensure senior leadership including legal, risk, data protection and compliance have visibility into cyber risk aligned with the Cyber Assessment Framework expectations. 5. Enhance monitoring and detection capabilities Adopt behavioural baselining correlation and proactive threat hunting, moving beyond basic log collection. Use of technology, where applicable, with an effective security operations centre is key to ensure proactive threat detection, vulnerability and patch management, and overall strengthening of the cyber posture. 6. Implement secure development lifecycle practices Introduce or strengthen existing processes for code scanning, dependency identification and management, provenance checks, and structured software maintenance throughout the lifecycle, especially if you are using emerging technologies like Cloud and AI and relying heavily on third-party suppliers to provide such support to the business. 7. Update and test incident response and recovery plans Direct leadership with support from IT and Cyber to ensure response and recovery plans are realistic, tested regularly, and fully engage all suppliers and partners. Create regulator‑ready templates and legal guidance for meeting mandatory 24‑hour and 72‑hour incident reporting deadlines, including supporting escalation and communication protocols (including regulators). Carry out a regulatory notification mapping exercise to clearly identify all regulators that may fall within scope, together with their respective incident‑reporting obligations. Doing so enables organisations to streamline their response processes and avoid unnecessary delay or duplication when managing a cyber‑attack. 8. Update functional and scenario based cyber playbooks Update existing playbooks for business functions, documenting critical data and systems in scope, delegation of authority, emergency contacts, a list of critical suppliers, and a RACI matrix for working collaboratively with wider business stakeholders. Where needed, create and update an emerging and common cybersecurity incident scenario guide explaining how your business would respond to different types of attack and the immediate steps to follow. This would include identifying the appropriate expert third parties to support your organisation in the event of a cyber-attack such as legal counsel, public relations firms, forensic and cyber insurance specialists. Ensure incident‑response plans and crisis‑communications procedures are structured to maintain privilege, protect the organisation’s legal position, and support coordination with regulators. Where applicable, ensure the legal function reviews and advises on ransom legality. 9. Training and awareness As part of the existing effort on cyber training and awareness, ensure your training curriculum is updated to reflect changes in the UK and global cyber regulatory landscape, where applicable. Ensure the training plan is tailored to business functions heavily involved in cyber resilience, such as IT, Cyber, and other technical teams. Additionally, ensure such training extends to legal business functions who would interface with regulators where required. Awareness campaigns should be run on a periodic basis and documented on how the organisation is keeping up with developments in cyberspace. Awareness comes from wider policy updates and accessibility. Existing policies are only as good as they are understood by the wider business. Each review of existing processes and governance to factor in new legal changes should ensure, on a holistic basis, that not only are the policies clear and available, but they are also understood and operationalised. These factors remain a key part of organisational security obligations under applicable data protection and cyber security law. 10. Change management Change management as a trigger for culture and behaviour change should follow the existing change management procedure, with the right people involved in reviewing and signing off changes before implementation. 11. Tabletop exercises and crisis simulation Conduct tabletop exercises and crisis simulations to test the awareness, accountability and preparedness of key stakeholders, including all business functions and technical teams, in the event of a cyber-attack. Key stakeholders in such exercises would typically include IT, cyber, legal, finance, data protection, human resources, etc. Again, the key outputs here are lessons learned to feed into clearer, more accessible and more fully understood processes and policies in these key areas. 12. Cyber insurance It is important to review your cyber insurance arrangements, including reviewing policy wording to ensure adequate coverage for evolving cyber threats, aligning incident‑response procedures with policy conditions, and engaging counsel to advise on disclosure obligations during underwriting to avoid gaps or challenges at claims stage. Legal can also help interpret insurer requirements during and after an incident, such that during a regulatory notification, evidence gathering, and communications are handled in a way that preserves coverage and supports a smooth claims process. 13. Data protection From a data protection perspective, organisations should ensure that their cyber‑resilience programme is closely aligned with UK data protection obligations, particularly where incidents involve personal data. This includes maintaining well tested procedures for managing data subject rights requests during periods of operational disruption and ensuring that statutory response timelines can still be met even when systems are under strain. Phase 3: Assurance and Continuous Improvement 14. Effective cyber compliance documentation Develop artefacts and a broader document to capture the cyber program, progress, key decision-making, and the roadmap, demonstrating the intention to do the right thing. The starting point of such a journey is key to showcasing maturity, traceability, and continuous improvement aligned to CAF outcomes. The internal audit function of your business is a key in-house function that should monitor ongoing cyber controls and plans to be an effective third line of defence. Verify that your internal audit personnel have the correct expertise and experience in auditing internal processes to identify gaps in your cyber-attack preparedness. As a best practice, internal audits should include cyber audits as part of their plan and conduct such audits on periodic basis. 15. Establish continuous improvement cycles Adopt threat-led testing, scenario-based exercises, and annual review cycles to progressively strengthen resilience. Ensure continuous monitoring and interpretation of further updates to the Bill, secondary legislation, and sector-specific guidance to help ensure that you stay aligned to evolving requirements. Final key takeaways The recent developments in the UK cyber regulatory landscape represent a proactive stance by the UK government to strengthen the economy's cyber posture. Regulators are providing guidance and documentation on appropriate channels; use it to keep your business updated and to develop and strengthen your existing cyber preparedness, rather than reinventing the wheel. Maintain open dialogue with key regulators on matters requiring further clarification, – they welcome it. A cyber resilience program must be proportionate to your business's size, operations, jurisdictional footprint, and risk appetite. Do not over-engineer or waste resources and budget on areas that do not meaningfully move the dial on risk. Keep it simple and pragmatic. Demonstrate the right intention and support an economy where cybersecurity underpins critical sectors and data flows. Where needed, engage specialist legal and regulatory advisors – including firms like Eversheds Sutherland and Konexo – to support the effective implementation of cyber resilience. At the same time, do not treat cybersecurity as a mere compliance obligation. Rather, embed a culture of cyber resilience into your business's DNA and treat it as business-as-usual, not a cumbersome regulatory burden. The materials on the Eversheds Sutherland website are for general information purposes only and do not constitute legal advice. While reasonable care is taken to ensure accuracy, the materials may not reflect the most current legal developments. Eversheds Sutherland disclaims liability for actions taken based on the materials. Always consult a qualified lawyer for specific legal matters. To view the full disclaimer, see our Terms and Conditions or Disclaimer section in the footer. 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The UK’s cyber threat landscape has generated significant headlines, with high-profile incidents exposing significant operational, financial, and reputational risks for organisations across various sectors and impacting the wider UK economy. Amid rising attack costs estimated at £14.7 billion, breaches involving Microsoft, Jaguar Land Rover, the NHS, and the Ministry of Defence highlight concerns about organisational preparedness to cyber-attacks and the wider business continuity in the event of such an attack. Although cyber-attack techniques vary, the key issue is how well firms can manage and respond to cyber breaches swiftly, with minimal disruption to operations and stakeholder confidence.

Recent updates and developments to UK cyber regulations and the government's approach reflect a growing commitment to cyber resilience. The government’s evolving stance and new requirements shape how organisations must approach their compliance and resilience efforts, from tick-box compliance to genuine, board-endorsed cyber resilience. As such, the Cyber Assessment Framework (CAF) plays a critical role in demonstrating baseline compliance for the expected Cyber Security and Resilience (Network and Information Systems) Bill across government, critical infrastructure, and regulated sectors. It now underpins the UK Government Cybersecurity Strategy 2022–2030.

While the Bill focuses on network and information systems resilience, organisations must consider other legal touchpoints including aspects of data protection, operational resilience, AI governance, outsourcing rules, and sector‑specific supervisory frameworks. A fragmented compliance approach will be insufficient; the direction of travel clearly favours integrated risk management (particularly needed where you are looking to integrate these requirements as part of a wider, multi-jurisdictional framework). Increasingly, cyber resilience expectations are not confined to regulated entities alone, but are cascading across supply chains, creating indirect but material operational and commercial impacts. Forward‑looking organisations are therefore aligning cyber resilience efforts with privacy, compliance, legal, audit, and procurement functions to create a unified compliance model, reducing duplication and demonstrating a more mature regulatory posture.

For organisations operating across multiple jurisdictions, the Bill heightens the operational challenge of harmonising cyber response processes. Divergences between the UK and the existing EU NIS2 regimes mean that a single global incident may trigger different notification obligations, risk thresholds, and governance requirements across regions. Organisations should ensure their incident frameworks are agile enough to handle multi‑regulatory reporting without causing operational delay or compliance conflicts. These changes are the latest in a long line of globally diverging cyber requirements that need to be understood and accounted for in a practical and defensible manner.

Recent developments in the UK Cyber Resilience

The Bill, which is currently before parliament as part of the approval and refinement process, represents a key regulatory step, signalling that the UK is raising the bar to counter escalating digital risks. The Bill builds on the UK’s 2018 NIS Regulations, integrates lessons learned and recent technological advancements and the types of sophisticated threats, and aligns with the EU's NIS 2 Directive, aiming to build a robust digital ecosystem.

CAF version 4.0 is the most significant update since its 2018 launch. The updated CAF captures cyber security risk management outcomes across cyber domains and contains over 100 new indicators of good practice which organisations should aim to achieve in a manner that can be demonstrated to regulators.

The UK Government has announced a £210 million Cyber Action Plan2 to boost the public sector and its cyber posture by pushing accountability to EXCO-level leadership, making cyber a board agenda item, and treating it as a national issue that requires a more coordinated response across the organisation. The emphasis on multidisciplinary teams working on cyber preparedness as more businesses move digital is prudent, helping them be better prepared for unavoidable cyber incidents. To tackle this more effectively, the UK government has created a new Cyber Unit to govern the strategic direction of cyber resilience management.

Lastly, the latest National Cyber Security Centre (NCSC) alerts and guidance published in the past few months including: rising state-aligned hacktivist disruption (Jan 2026)3, new joint CISA–NCSC guidance for operational technology (OT) security (Sept 2025)4, Cyber Essentials Supply Chian Playbook (Dec 2025)5 updated Cyber Essentials6 requirements effective April 2026 and the heightened severe-threat environment impacting UK critical national infrastructure (Feb 2026)7.

Deep Dive: The Bill

Expanded Regulatory Scope

The new Bill has expanded in scope and now covers a broader range of organisations that need to demonstrate compliance with cyber resilience requirements. The extended scope of organisations now includes:

Data centre operators above specified capacity thresholds;
Managed service providers providing ongoing connected IT management;
Organisations designated as critical suppliers due to the potential impact of their disruption on essential services; and
A clearer and modernised set of regulated digital service providers.

This expansion introduces new obligations for a wider set of organisations (and is extra-territorial in scope where services are being provided into the UK). As a result, more entities must now regard the CAF as a baseline to demonstrate cyber resilience compliance. Previously, this requirement applied mainly to government or critical national infrastructure.

In practice, the impact of the Bill will extend beyond those directly in scope. Organisations operating within the supply chains of operators of essential services, managed service providers, and critical infrastructure entities will experience indirect regulatory pressure.

This will manifest through enhanced:

Customer-led due diligence and assurance requirements
Contractual obligations relating to cyber controls and resilience
Ongoing monitoring, audit and reporting expectations

As a result, many organisations not formally classified as in-scope will need to align to similar resilience standards in order to remain commercially viable.

Strengthened Duties and Enforcement

Stricter incident reporting requirements: To showcase proactive threat intelligence and the business's wider preparedness for detecting and resolving cyber incidents, organisations should notify the applicable regulator as soon as possible, or within 24 hours, whichever is sooner, and also provide a full investigation report within 72 hours.

An increasingly scrutinised area is expected to be how organisations assess whether an incident meets the statutory reporting threshold. Misclassifying an incident may constitute a regulatory breach in itself. As international regulators adopt a more assertive supervisory stance, organisations will need a defensible methodology for incident triage, documentation, and escalation supported by legal and forensic advisors.

Strengthened supply chain security: Supply-chain resilience becomes a statutory obligation. Regulators will get new powers to identify and designate specific high-impact suppliers as ‘critical suppliers’, with obligations equivalent to those of Operators of Essential Services (OES).

Enhanced enforcement powers: OES also face broader oversight, as regulators gain new powers to request information proactively, conduct inspections, and issue turnover-based penalties for serious failings.

The Bill also elevates resilience expectations, requiring operators to demonstrate robust business continuity planning, risk management, and governance aligned to national standards.

Developing a roadmap for effective cyber resilience compliance

A practical phased pathway to align with emerging cyber regulatory expectations is outlined below.

Phase 1: Baseline and Discovery

1. Applicability of scope and current state view

Identify how the recent changes in the Bill and wider regulatory changes impact your organisation. For instance, are you in the newly scoped categories under the Bill, such as a managed service provider, data centre operator, or critical supplier? This includes interpreting the thresholds under the Bill and assessing corresponding regulatory exposure (not solely in the UK but within your existing global cyber threat management framework). Integration of the requirements of all applicable regulations into an overarching cyber security framework remains a key step for all businesses.

Much of the operational detail of the Bill will be delivered through secondary legislation and sector‑specific guidance. Organisations should expect further clarity on reporting formats, thresholds, audit criteria, and technical standards. Early alignment with legal counsel enables a more agile response as these additional materials are released.

2. Conduct a CAF 4.0 gap assessment

Evaluate your cybersecurity landscape, including your governance, controls, threat understanding, asset management, software development, monitoring, and recovery capabilities. Ensure you use the updated CAF version 4.0 controls and implementation guidelines as your benchmark to document the gaps and the effort required to remediate them. Do so considering a risk-based approach, immediate priorities, budget considerations, and the extent to which you will need external support from advisors and expert consultants. Meet all the objectives of the updated CAF including:

an explicit requirement to understand adversary threats and integrate threat intelligence into risk decisions;

a dedicated outcome for secure software development and lifecycle management;

furthermore, expectations have increased for monitoring behavioural analytics, conducting threat hunting, and providing enriched logging;

in addition, there are now stronger requirements for realistically tested response and recovery plans that include suppliers;

integration of AI-related risk across the framework; and

finally, CAF now demands real-world performance maturity and measurable outcomes, moving beyond checklist compliance.

Where applicable, involve data protection, legal and AI governance teams to ensure a more holistic coverage of gaps during the assessment.

3. Map critical supply chain dependencies

Identify which suppliers in your business are critical and assess their cyber maturity using a risk triage method, classifying suppliers as high, medium, or low risk. Ensure the definition of the categories of risks attached to a supplier aligns with business-critical and IT/Cyber-critical definitions. Do so by aligning with the business stakeholders, including relevant business functions and support functions such as procurement, IT, and Cyber. Conduct an overall supplier due diligence exercise (starting with your most material contracts, on a risk-prioritised basis thereafter), including a legal review of supplier contracts to identify gaps in audit rights, notification duties, liability allocation, and minimum-security standards that may require renegotiation under the new regime.

Phase 2: Capability Uplift

4. Establish threat-informed governance

As part of the existing cyber resilience governance forum, integrate threat intelligence into wider risk decisions and the business's risk appetite, and ensure senior leadership including legal, risk, data protection and compliance have visibility into cyber risk aligned with the Cyber Assessment Framework expectations.

5. Enhance monitoring and detection capabilities

Adopt behavioural baselining correlation and proactive threat hunting, moving beyond basic log collection. Use of technology, where applicable, with an effective security operations centre is key to ensure proactive threat detection, vulnerability and patch management, and overall strengthening of the cyber posture.

6. Implement secure development lifecycle practices

Introduce or strengthen existing processes for code scanning, dependency identification and management, provenance checks, and structured software maintenance throughout the lifecycle, especially if you are using emerging technologies like Cloud and AI and relying heavily on third-party suppliers to provide such support to the business.

7. Update and test incident response and recovery plans

Direct leadership with support from IT and Cyber to ensure response and recovery plans are realistic, tested regularly, and fully engage all suppliers and partners. Create regulator‑ready templates and legal guidance for meeting mandatory 24‑hour and 72‑hour incident reporting deadlines, including supporting escalation and communication protocols (including regulators). Carry out a regulatory notification mapping exercise to clearly identify all regulators that may fall within scope, together with their respective incident‑reporting obligations. Doing so enables organisations to streamline their response processes and avoid unnecessary delay or duplication when managing a cyber‑attack.

8. Update functional and scenario based cyber playbooks

Update existing playbooks for business functions, documenting critical data and systems in scope, delegation of authority, emergency contacts, a list of critical suppliers, and a RACI matrix for working collaboratively with wider business stakeholders. Where needed, create and update an emerging and common cybersecurity incident scenario guide explaining how your business would respond to different types of attack and the immediate steps to follow. This would include identifying the appropriate expert third parties to support your organisation in the event of a cyber-attack such as legal counsel, public relations firms, forensic and cyber insurance specialists. Ensure incident‑response plans and crisis‑communications procedures are structured to maintain privilege, protect the organisation’s legal position, and support coordination with regulators. Where applicable, ensure the legal function reviews and advises on ransom legality.

9. Training and awareness

As part of the existing effort on cyber training and awareness, ensure your training curriculum is updated to reflect changes in the UK and global cyber regulatory landscape, where applicable. Ensure the training plan is tailored to business functions heavily involved in cyber resilience, such as IT, Cyber, and other technical teams. Additionally, ensure such training extends to legal business functions who would interface with regulators where required. Awareness campaigns should be run on a periodic basis and documented on how the organisation is keeping up with developments in cyberspace.

Awareness comes from wider policy updates and accessibility. Existing policies are only as good as they are understood by the wider business. Each review of existing processes and governance to factor in new legal changes should ensure, on a holistic basis, that not only are the policies clear and available, but they are also understood and operationalised. These factors remain a key part of organisational security obligations under applicable data protection and cyber security law.

10. Change management

Change management as a trigger for culture and behaviour change should follow the existing change management procedure, with the right people involved in reviewing and signing off changes before implementation.

11. Tabletop exercises and crisis simulation

Conduct tabletop exercises and crisis simulations to test the awareness, accountability and preparedness of key stakeholders, including all business functions and technical teams, in the event of a cyber-attack. Key stakeholders in such exercises would typically include IT, cyber, legal, finance, data protection, human resources, etc. Again, the key outputs here are lessons learned to feed into clearer, more accessible and more fully understood processes and policies in these key areas.

12. Cyber insurance

It is important to review your cyber insurance arrangements, including reviewing policy wording to ensure adequate coverage for evolving cyber threats, aligning incident‑response procedures with policy conditions, and engaging counsel to advise on disclosure obligations during underwriting to avoid gaps or challenges at claims stage. Legal can also help interpret insurer requirements during and after an incident, such that during a regulatory notification, evidence gathering, and communications are handled in a way that preserves coverage and supports a smooth claims process.

13. Data protection

From a data protection perspective, organisations should ensure that their cyber‑resilience programme is closely aligned with UK data protection obligations, particularly where incidents involve personal data. This includes maintaining well tested procedures for managing data subject rights requests during periods of operational disruption and ensuring that statutory response timelines can still be met even when systems are under strain.

Phase 3: Assurance and Continuous Improvement

14. Effective cyber compliance documentation

Develop artefacts and a broader document to capture the cyber program, progress, key decision-making, and the roadmap, demonstrating the intention to do the right thing. The starting point of such a journey is key to showcasing maturity, traceability, and continuous improvement aligned to CAF outcomes.

The internal audit function of your business is a key in-house function that should monitor ongoing cyber controls and plans to be an effective third line of defence. Verify that your internal audit personnel have the correct expertise and experience in auditing internal processes to identify gaps in your cyber-attack preparedness. As a best practice, internal audits should include cyber audits as part of their plan and conduct such audits on periodic basis.

15. Establish continuous improvement cycles

Adopt threat-led testing, scenario-based exercises, and annual review cycles to progressively strengthen resilience. Ensure continuous monitoring and interpretation of further updates to the Bill, secondary legislation, and sector-specific guidance to help ensure that you stay aligned to evolving requirements.

Final key takeaways

The recent developments in the UK cyber regulatory landscape represent a proactive stance by the UK government to strengthen the economy's cyber posture. Regulators are providing guidance and documentation on appropriate channels; use it to keep your business updated and to develop and strengthen your existing cyber preparedness, rather than reinventing the wheel. Maintain open dialogue with key regulators on matters requiring further clarification, – they welcome it.

A cyber resilience program must be proportionate to your business's size, operations, jurisdictional footprint, and risk appetite. Do not over-engineer or waste resources and budget on areas that do not meaningfully move the dial on risk. Keep it simple and pragmatic. Demonstrate the right intention and support an economy where cybersecurity underpins critical sectors and data flows.

Where needed, engage specialist legal and regulatory advisors – including firms like Eversheds Sutherland and Konexo – to support the effective implementation of cyber resilience. At the same time, do not treat cybersecurity as a mere compliance obligation. Rather, embed a culture of cyber resilience into your business's DNA and treat it as business-as-usual, not a cumbersome regulatory burden.

The materials on the Eversheds Sutherland website are for general information purposes only and do not constitute legal advice. While reasonable care is taken to ensure accuracy, the materials may not reflect the most current legal developments. Eversheds Sutherland disclaims liability for actions taken based on the materials. Always consult a qualified lawyer for specific legal matters. To view the full disclaimer, see our Terms and Conditions or Disclaimer section in the footer.