The UK Government has announced that it intends to introduce the Cyber Security and Resilience Bill (the “Bill”) to Parliament in 2025. Formally proposed as part of the King’s Speech in July, this Bill is intended to strengthen the UK’s cross-sectoral cyber security legislation to better protect the UK’s economy and infrastructure. This Bill will update the existing NIS Regulations, which derive from EU law. Part of the UK Government’s motivation seems to be to keep pace with updates to EU law in this area, specifically relating to the NIS2 Directive that starts to apply this month (see our blog post on this, here).

A draft of the Bill has not yet been published, but the Government has indicated that this new Bill will, as compared to the existing NIS Regulations:

  • Expand the scope of entities captured, “to protect more digital services and supply chains”.
  • Impose more stringent reporting requirements on covered entities, including where companies are held to ransom.
  • Put regulators on a “stronger footing”, for example by introducing cost recovery mechanisms to ensure regulators are better funded, and providing regulators with the power to proactively investigate potential vulnerabilities.

Further detail about the Bill is limited, but the previous Government’s response to a consultation on amending the NIS Regulations suggested that:

  • Digital managed services (such as IT outsourcing services or threat and vulnerability management services) would be brought within scope of the regime.
  • Incident reporting obligations would be expanded to include incidents that do not directly affect the continuity of a service.
  • A risk-based approach to regulation would be adopted (but that the legislation itself would not create a two-tier system whereby some entities are proactively regulated and others only reactively).
  • A new power would be created, to bring into scope critical suppliers or services on which covered services depend.

If the new Labour Government takes inspiration from the EU’s NIS2 Directive it could, for example, expand the sectors within scope of the law even further.

The Government has stated that it is “working with key stakeholders to gather input” and will in due course publish further communications on how stakeholders can provide their views on the Bill’s content. Once introduced to Parliament, we expect that the Government will look to pass the Bill through the legislative process as quickly as possible. The Government’s announcements on the Bill have emphasised its urgency in light of a number of recent high-profile cyber-attacks on important UK institutions. A swift passage could see the Bill becoming law in the first quarter of 2026 (or even sooner), depending on when it is introduced to Parliament.

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Photo of Mark Young Mark Young

Mark Young is an experienced tech regulatory lawyer and a vice-chair of Covington’s Data Privacy and Cybersecurity Practice Group. He advises major global companies on their most challenging data privacy compliance matters and investigations. Mark also leads on EMEA cybersecurity matters at the…

Mark Young is an experienced tech regulatory lawyer and a vice-chair of Covington’s Data Privacy and Cybersecurity Practice Group. He advises major global companies on their most challenging data privacy compliance matters and investigations. Mark also leads on EMEA cybersecurity matters at the firm. In these contexts, he has worked closely with some of the world’s leading technology and life sciences companies and other multinationals.

Mark has been recognized for several years in Chambers UK as “a trusted adviser – practical, results-oriented and an expert in the field;” “fast, thorough and responsive;” “extremely pragmatic in advice on risk;” “provides thoughtful, strategic guidance and is a pleasure to work with;” has “great insight into the regulators;” and “is technologically sophisticated and advises on true issues of first impression, particularly in the field of AI.”

Drawing on over 20 years of experience, Mark specializes in:

Providing practical guidance and advising on potential exposure under GDPR and international data privacy laws in relation to innovative products and services.
Handling complex regulatory investigations and enforcement actions involving data privacy regulators in the UK, EU and globally, and advising on follow-on litigation risk.
Helping clients respond to cybersecurity incidents, including ransomware, supply chain incidents, state-sponsored attacks, insider threats, personal data breaches, and IP and trade secret theft.
Advising various clients on the EU NIS2 Directive, Cyber Resilience Act (CRA), and other emerging EU, UK, and global cybersecurity laws and regulations.
Advising life sciences companies on industry-specific data privacy issues, including clinical trials, pharmacovigilance, and digital health products and services.
Advising on data privacy compliance in relation to employees and international transfers of data in connection with white collar investigations.
Providing strategic advice and advocacy on a range of UK and EU technology law reform issues relating to data privacy, cybersecurity, eIDs, and software.
Representing clients in connection with references to the Court of Justice of the EU.

Photo of Paul Maynard Paul Maynard

Paul Maynard is special counsel in the technology regulatory group in the London office. He focuses on advising clients on all aspects of UK and European privacy and cybersecurity law relating to complex and innovative technologies such as adtech, cloud computing and online…

Paul Maynard is special counsel in the technology regulatory group in the London office. He focuses on advising clients on all aspects of UK and European privacy and cybersecurity law relating to complex and innovative technologies such as adtech, cloud computing and online platforms. He also advises clients on how to respond to law enforcement demands, particularly where such demands are made across borders.

Paul advises emerging and established companies in various sectors, including online retail, software and education technology. His practice covers advice on new legislative proposals, for example on e-privacy and cross-border law enforcement access to data; advice on existing but rapidly-changing rules, such the GDPR and cross-border data transfer rules; and on regulatory investigations in cases of alleged non-compliance, including in relation to online advertising and cybersecurity.

Photo of Tomos Griffiths Tomos Griffiths

Tomos is an associate working across the firm’s technology regulatory and competition teams, based in the London office. His practice covers technology and digital markets regulation, competition law, and issues that span the two.

His recent experience includes providing regulatory advice on data…

Tomos is an associate working across the firm’s technology regulatory and competition teams, based in the London office. His practice covers technology and digital markets regulation, competition law, and issues that span the two.

His recent experience includes providing regulatory advice on data protection compliance, technology regulatory investigations, and transactional merger control and foreign direct investment screening matters, primarily in the technology and life sciences sectors.