The increasing scale and sophistication of cyber threats has prompted the UK government to propose wide ranging reform through the Cyber Security and Resilience Bill. The Bill, currently progressing through Parliament, is expected to significantly raise cybersecurity and resilience standards across the UK economy, with implementation anticipated from 2026 onwards. For businesses operating in digital environments, critical sectors or complex supply chains, this legislation marks an important shift in regulatory expectations.
Cybersecurity is no longer treated as a purely technical issue. Regulators now view cyber risk as a core business governance concern, comparable to financial, operational and compliance risk. The proposed reforms aim to ensure that organisations take a more proactive and structured approach to preventing, managing and responding to cyber incidents.
Scope and regulatory direction of the Cyber Security and Resilience Bill
The Cyber Security and Resilience Bill builds on existing UK frameworks, including the Network and Information Systems Regulations, but significantly expands their reach. The intention is to cover a broader range of organisations whose services are essential to the functioning of the economy, even if they are not traditionally viewed as part of critical national infrastructure.
Managed service providers, data centres, cloud service providers and technology suppliers are expected to fall squarely within the scope of the new regime. Businesses operating in sectors such as finance, energy, transport, healthcare and digital services are also likely to face enhanced obligations. Importantly, organisations outside these sectors may still be affected indirectly through contractual requirements imposed by regulated clients and supply chain partners.
The direction of travel is clear. Businesses will be expected to demonstrate robust cybersecurity governance, effective risk management and resilience planning. Regulators are likely to be given stronger investigative and enforcement powers, alongside the ability to impose higher financial penalties where organisations fail to meet required standards.
Key compliance expectations for businesses ahead of 2026
Although the final form of the Bill is still subject to parliamentary scrutiny, businesses should anticipate a number of practical compliance requirements. These are expected to include clearer duties to assess and manage cyber risk, improved incident detection and response processes, and mandatory reporting of significant cyber incidents within specified timeframes.
There is also an increased focus on supply chain security. Businesses will be expected to understand and manage the cyber risks posed by third party providers, particularly where those providers have access to sensitive systems or data. This reflects a growing regulatory concern that vulnerabilities often arise not within organisations themselves but through interconnected digital ecosystems.
From a governance perspective, senior management and boards are expected to play a more active role in overseeing cyber resilience. This includes ensuring that appropriate policies, controls and resources are in place, and that cyber risk is integrated into wider enterprise risk management frameworks.
How Penerley can help businesses prepare
Preparing for the Cyber Security and Resilience Bill requires more than technical fixes. It requires a coordinated legal, governance and commercial response. Penerley advises businesses on the legal and regulatory implications of cybersecurity reform, helping clients understand how forthcoming obligations apply to their operations and risk profile.
Our team supports clients with reviewing and updating internal policies, contracts and supplier arrangements to reflect evolving regulatory expectations. We also advise on incident response planning, regulatory notification obligations and governance frameworks to ensure senior leadership oversight is properly structured.
By engaging early, businesses can reduce regulatory risk, strengthen operational resilience and demonstrate compliance readiness well ahead of enforcement in 2026. Penerley works with clients across sectors to deliver practical, commercially focused advice that supports long term compliance and business continuity.
