When I first saw the headlines about the UK’s upcoming Cyber Security & Resilience Bill, I couldn’t help but draw parallels to a recurring theme in our industry: alignment without obligation. The UK, now outside the EU, isn’t bound by the NIS2 Directive—but it’s clearly not opting out of the broader game. Instead, it’s rewriting its rules with the CSR Bill, an ambitious reform that echoes NIS2 in its scope and urgency.
This article explores the technical, regulatory, and operational implications of this reform. We’ll unpack how it compares to the EU model, what it means for UK companies, and how it will shape the country’s cyber posture through 2025 and beyond.
A legislative evolution with global echoes
While NIS2 UK requirements don’t formally exist under EU law, the UK government is modernizing its cybersecurity regime by revising the retained NIS Regulations 2018. The mechanism for this is the Cyber Security & Resilience Bill, announced in the July 2024 King’s Speech. The CSR Bill won’t copy NIS2 verbatim, but it builds on the same risk-based principles—widening sector scope, tightening reporting duties, and increasing regulatory teeth.
This hybrid approach reflects the UK’s ambition to maintain cyber alignment with the EU for international operators, while also asserting national sovereignty over regulatory pace and focus.
Here’s a snapshot of the CSR Bill’s journey so far:
CSR Bill timeline and status (as of April 2025)
| Date | Milestone | Status |
| 10 May 2018 | NIS Regulations 2018 (SI 2018/506) come into force | ✔︎ Enacted |
| 19 Jan – Apr 2022 | Public consultation: “Improve UK Cyber Resilience” | ✔︎ Completed |
| 30 Nov 2022 | Government response confirms reform pillars | ✔︎ Finalized |
| 17 Jul 2024 | CSR Bill announced in King’s Speech | ✔︎ Delivered |
| 1 Apr 2025 | Policy statement published | ✔︎ Issued |
| Q3 2025 | Bill expected to be introduced in Parliament | ✖︎ Pending |
| H2 2026 | Go-live via commencement regulations and guidance | ✖︎ Projected |
The UK is clearly moving toward a more proactive, scalable cybersecurity governance framework—one that mirrors the structure and urgency of the NIS2 regulations UK model.
What’s actually changing: the pillars of the CSR Bill
The CSR Bill introduces sweeping updates that realign the UK’s cyber laws with evolving risks, particularly around supply chain interdependencies and critical digital services. It retains familiar language—like the duty to maintain “appropriate and proportionate” security—but adds depth, especially around technical baselines and accountability.
Here’s what the proposed reform entails:
Key CSR Bill reforms by policy pillar
| Pillar | Summary of changes |
| Scope | Includes MSPs, SOCs, MSSPs, data-centres; small digital firms no longer exempt |
| Resilience duties | Must align with NCSC’s Cyber Assessment Framework (CAF) |
| Reporting | 24-hour early alert + 72-hour full report; covers ransomware and near-misses |
| Enforcement | Audits, improvement notices, cost-recovery; emergency powers for ministers |
| Sanctions | Up to £17m static; or £100k/day or 10% daily turnover for ignored orders |
The shift to a 24-hour early warning requirement is particularly notable, as it sets a stricter bar than NIS2’s 72-hour threshold. That alone signals a strong emphasis on speed and transparency.
Sanctions and compliance: what’s at stake
Perhaps the most attention-grabbing element of the CSR Bill is its sanction structure. While the maximum fine under the NIS 2018 Regulations remains at £17 million, the new proposal introduces daily fines for non-compliance with ministerial orders—either £100,000 per day or 10% of daily turnover. That’s not just a financial penalty; it’s a reputational threat.
The UK isn’t following the EU’s model of executive liability under NIS2, which mandates board-level accountability, but companies should not mistake this for leniency. Corporate law will still hold senior management responsible for gross failures in governance or oversight.
Who is affected: sector-by-sector breakdown
The CSR Bill dramatically broadens the scope of covered entities. Many businesses that previously operated under the radar of cybersecurity regulation—particularly managed service providers and co-location operators—are about to come under direct regulatory scrutiny.
Sector-specific impacts of the CSR Bill
| Sector | Current status | Under CSR Bill |
| Managed IT/Security Services | Generally exempt | Fully regulated; must report incidents, align with CAF |
| Data-centres & Co-location | Voluntary frameworks (e.g., Co-Lan) | Mandatory SOCs, cyber-physical integration, sovereign-hosting assurance |
| Digital Services | Exempt if under 50 employees | No exemptions; must appoint CISO, file annual CAF report |
| Healthcare Supply Chain | Only NHS and large pharma covered | Extends to pathology labs, EHR vendors, outsourced diagnostic services |
| Critical National Infrastructure | Already in scope | Maintains status; regulators gain power to impose technical mandates |
This expansion is expected to triple the in-scope population to approximately 2,500 entities, according to DSIT. The estimated initial cost of compliance? Somewhere between £350 million and £600 million.
Comparing UK CSR Bill and EU NIS2: where divergence meets convergence
While the NIS2 directive doesn’t apply to the UK directly, the UK’s CSR Bill runs parallel to it in key areas. Still, there are some important divergences—especially in enforcement and governance.
Comparative overview of CSR Bill vs. EU NIS2
| Topic | UK CSR Bill | EU NIS2 |
| Early incident notice | 24 hours | 72 hours |
| Maximum static fine | £17 million | €10 million (essential) / €7 million (important) |
| Daily fines | £100k or 10% of turnover (ministerial) | Not specified in directive; left to national law |
| Executive liability | Not explicit; covered by company law | Mandatory under “management accountability” requirement |
| Dynamic scope | Ministers can add sectors | Commission can extend scope via delegated acts |
This table reinforces the need for dual-operating companies to maintain compliance on two fronts. For these firms, NIS2 UK compliance is not merely theoretical—it’s a logistical reality.
Preparing for what’s ahead
For companies that might fall under the CSR Bill, the message is clear: don’t wait for the ink to dry. Regulatory change at this scale demands proactive preparation, especially in terms of operational maturity and incident response capability.
Regulators will evaluate companies using the NCSC’s CAF, so running a gap analysis against that framework is a smart starting point. Similarly, having a crisis playbook that includes legal, communications, and technical escalation paths will be essential to meet the 24-hour notification rule.
Companies should also budget for regulatory engagement. The cost-recovery model means that compliance won’t just involve internal controls—it will require actual financial allocation, with mid-sized firms expected to pay £10,000 to £20,000 annually in regulator fees.
Are you ready for a dual-track cyber regime?
The UK’s approach to cybersecurity regulation post-Brexit is not to go it alone, but to go smart. With the CSR Bill, the UK is aligning itself with the principles of NIS2, while maintaining flexibility to tailor enforcement to its own strategic interests.
For industry leaders, this means preparing for a world where NIS2 UK government actions—though not EU-mandated—are no less impactful. Whether you’re managing data centres, running managed services, or operating across borders, it’s time to assess your exposure, plan for scrutiny, and raise your resilience baseline.
Because when it comes to regulatory risk, the clock is already ticking.
