The UK's Cybersecurity Landscape: Strategic Priorities for 2025

In response, the UK government has discussed new legislation aimed at enhancing national cyber resilience. These initiatives include expanding regulatory oversight, introducing mandatory incident reporting requirements, and enabling more agile responses to emerging threats. At the same time, organizations from all sectors need to reassess their cybersecurity governance to keep pace with an increasingly complex threat environment.

The National Cyber Security Centre (NCSC) helps organizations build more robust cyber defenses. Its Cyber Essentials certification is becoming a foundational standard, particularly as the government explores new measures to safeguard critical infrastructure and ensure cross-sector alignment with best practices.

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Major Cyberattacks in the UK (2024)

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Southern Water Black Basta Ransomware Attack – January 2024

In January 2024, Southern Water, a UK utility provider serving 2.5 million customers, suffered a ransomware attack attributed to the Black Basta group. The attackers exfiltrated sensitive customer and employee data before leaking it online. Southern Water disclosed in their financial report that the incident incurred approximately £4.5 million in costs, including external cybersecurity experts, legal advisers, and contacting all victims who were affected. The attack underscores the significant financial and operational toll that ransomware can impose, particularly on critical infrastructure providers.

UK Ministry of Defence Payroll Data Breach – May 2024

In May 2024, the UK Ministry of Defence disclosed a significant data breach affecting approximately 270,000 current and former armed forces personnel. The breach originated from a third-party payroll system managed by SSCL, an arm of the French tech company Sopra Steria, which is separate from the Ministry of Defence's core network. The compromised information included names, bank details, and, in some cases, addresses. While the UK government did not officially attribute the attack, sources indicated potential involvement by Chinese state-affiliated actors. The incident prompted immediate action to secure the affected systems and raised concerns about the cybersecurity of external service providers handling sensitive military data. And government officials were concerned that SSCL was slow to respond to the hack.

NHS Ransomware Attack on Synnovis – June 2024

In early June 2024, Russian cybercriminal group Qilin launched a ransomware attack on Synnovis, a diagnostic, testing and digital pathology services provider for the NHS and several major London hospitals. The attack disrupted IT systems, leading to the postponement of more than 10,000 outpatient appointments and 1,700 elective procedures , including critical procedures like cancer treatments and organ transplants. Blood transfusion laboratory IT systems were severely impacted leading to a shortage of type-O blood supplies.

At least two patients suffered long-term or permanent damage to their health, as a result of the cyberattack as well as at least 11 cases of moderate harm and 120 cases of low harm. In their financial report published on January 7, 2025, Synnovis estimated the financial impact of the attack to be £32.7 million.

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Transport for London Cyberattack – September 2024

On September 1, 2024, Transport for London (TfL) detected suspicious activity on its network, prompting immediate shutdowns of several systems to mitigate potential ransomware threats. While the transportation services, like buses and the Tube, remained operational, the cyberattack significantly disrupted customer-facing platforms. Customers were unable to access their accounts for payment services, third-party applications experienced outages, and the Dial-a-Ride service for disabled passengers was temporarily suspended.

Financially, the attack has cost TfL over £30 million to date. The organization reported spending £5 million on incident response and cybersecurity enhancements. Additionally, its projected operating surplus for the fiscal year was reduced from £61 million to £23 million, largely due to the incident's impact.

Since early 2025, TfL has restored most affected services, including online journey histories and Oyster photocard applications. However, customers could still face potential delays in obtaining refunds and data updates as TfL continues recovery efforts.

The UK's Cybersecurity Regulatory Framework

The national focus on cybersecurity regulation in the UK has evolved in recent years, reflecting recent cybersecurity incidents that led to critical sectors being negatively affected, the growing threat landscape.

Current Regulatory Environment

UK Network and Information Systems (NIS) Regulations

The NIS Regulations, introduced in 2018 and updated in 2022, establish cybersecurity requirements for operators of essential services (OES) and relevant digital service providers (RDSPs). These regulations:

• Require organizations to implement appropriate security measures to manage risks
• Mandate incident reporting procedures for significant cybersecurity events
• Establish competent authorities for each sector to oversee compliance
• Impose substantial penalties for non-compliance, up to £17 million for the most serious breaches

The 2022 amendments expanded the scope to include managed service providers and streamlined reporting requirements, reflecting lessons learned from major incidents in the intervening years.

UK General Data Protection Regulation (UK GDPR)

Following Brexit, the UK incorporated the EU GDPR into domestic law, creating the UK GDPR alongside the Data Protection Act 2018.

Some of the key aspects of these two pieces of legislation:

• Requirements for organizations to implement "appropriate technical and organizational measures" to protect personal data
• 72-hour breach notification requirements for incidents affecting personal data
• Potential fines of up to £17.5 million or 4% of annual global turnover
• Explicit requirements for data processors to ensure adequate security measures

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The Information Commissioner's Office (ICO) serves as the enforcement body for this legislation. The ICO’s key responsibilities include:

• Monitoring and enforcing compliance with data protection laws
• Investigating data breaches and complaints from the public
• Issuing fines and enforcement notices where necessary
• Providing guidance to organizations on best practices for data protection and privacy

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For example, in the TfL cyberattack, where personal data was compromised, the ICO would investigate whether there was a failure in data protection obligations and decide on any enforcement actions or penalties.

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Emerging Regulatory Developments

The Cyber Security and Resilience Bill

The government's proposed Cyber Security and Resilience Bill, expected to be enacted in 2025, is a significant overhaul of the UK's cybersecurity regulatory landscape since 2022.

 Key provisions include:

• Enhanced requirements for critical infrastructure providers, including regular security audits and penetration testing
• Mandatory security by design principles for connected devices and systems
• Expanded incident reporting obligations with shorter timeframes for notification
• Cross-sector minimum security baselines to ensure consistent protection standards
• New powers for regulators to conduct proactive assessments rather than reactive investigations

The bill aims to address fragmentation in the current regulatory landscape by establishing more consistent requirements across sectors while allowing for industry-specific considerations.

Compliance Trends and Challenges

The Cyber Security Breaches Survey 2024 notes that "a sizable proportion of organizations, including larger organizations, continue to be unaware of government guidance such as the 10 Steps to Cyber Security, and the government-endorsed Cyber Essentials standard."

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This awareness gap highlights a key challenge for regulators: ensuring that existing requirements are effectively communicated and implemented before introducing new obligations. The government has responded with expanded outreach efforts through the National Cyber Security Centre, including sector-specific guidance and more accessible resources for smaller organizations.

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As the regulatory landscape continues to evolve, UK organizations face the dual challenge of addressing current compliance requirements while preparing for the more stringent obligations on the horizon.

Strategic Priorities for UK Organizations

In the face of increasingly sophisticated cyber threats and a complex regulatory landscape, UK organizations need to adopt comprehensive cybersecurity governance that is more than a compliance exercise. The following strategic priorities represent critical focus areas for organizations seeking to enhance their cyber resilience in 2025.

Cybersecurity Governance Perspectives

Effective cybersecurity begins with robust governance structures that establish clear accountability and oversight:

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Board-Level Engagement

Cybersecurity has become a board-level concern, with directors increasingly held accountable for security failures. Organizations should ensure regular reporting to the board on cyber risks, including quantitative metrics that translate technical vulnerabilities into business impacts.

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CISO Role Enhancement

The Chief Information Security Officer position continues to evolve, with successful organizations elevating this role to report directly to the CEO or board rather than through IT leadership. This structural change reflects the strategic business importance of cybersecurity beyond technical operations.

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Risk Appetite Definition

Organizations should formally define their cybersecurity risk appetite in financial terms, documenting acceptable levels of risk across different business functions and data classifications.

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Third-Party Risk Management

As the Southern Water and Ministry of Defence breaches demonstrated, supply chain vulnerabilities represent significant risks. Organizations should implement comprehensive vendor security assessment processes, continuous monitoring, and contractual security requirements.

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Building Organizational Resilience

The frequency and impact of successful cyberattacks make resilience capabilities as important as preventive measures:

• Business Continuity Planning
• Incident Response Capabilities
• Ransomware-Specific Preparations
• Cyber Insurance

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Implementing NCSC's Recommendations

10 Steps to Cyber Security

The NCSC's 10-step framework offers a structured approach to security improvement. The 10 steps focus on understanding organizational risks, implementing appropriate mitigations and preparing for incidents:

• Risk management
• Engagement and training
• Asset management
• Architecture and configuration
• Vulnerability management
• Identify and access management
• Data security
• Logging and monitoring
• Incident management
• Supply chain security

Cyber Essentials

The Cyber Essentials is a UK government-backed certification scheme that provides a baseline of security measures that help keep organizations and their customers’ data safe from cyberattacks. There are two levels of certification – Cyber Essentials and Cyber Essentials Plus. The Cyber Essentials Plus scheme combines a self-assessment and independent audit as well as with more rigorous testing.

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The Cyber Essentials certification is increasingly becoming a requirement for government contracts and is recognized as a fundamental starting point for cybersecurity programs. According to Cyber Essentials documentation, organizations with the certification are 92% less likely to make a claim on their cyber insurance.

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Quantitative Risk Management

Moving beyond compliance-focused approaches, leading organizations are adopting more sophisticated quantitative risk management methodologies. The NCSC has provided guidance on why adopting a quantitative, data-driven approach to risk management improves resilience and security.

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Reasons to adopt cybersecurity risk quantification according to the NCSC:

• Improved communication in terms that stakeholders care about
• Enabling cost-benefit analysis and risk comparison/prioritization
• Increased transparency

By adopting these strategic priorities, UK organizations can move beyond checkbox compliance to develop genuine cyber resilience, the ability to withstand, respond to, and recover from cyber incidents while maintaining critical functions and protecting sensitive information.

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Moving Beyond Compliance to Resilience

As demonstrated by the major incidents from Southern Water, the Ministry of Defence, the NHS and Transport for London, cyberattacks are causing unprecedented operational disruption, financial losses, and in some cases, harm to individuals.

The financial impact alone is staggering: £32.7 million for Synnovis, over £30 million for Transport for London, and £4.5 million for Southern Water. These figures underscore that cybersecurity is no longer just an IT concern but a fundamental business risk that demands board-level attention and strategic investment.

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Cybersecurity must evolve from a compliance exercise to a strategic business function that enables organizations to understand, communicate, and manage digital risk in business terms. By adopting data-driven approaches to risk quantification, UK organizations can build the resilience needed to thrive.

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C-Risk can help your organization successfully navigate this challenging environment with our expertise in data-driven risk management and CRQ. If you would like to discuss your cybersecurity or risk management strategy, schedule a meeting here.

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