Back Brownejacobson What does the Cyber Security and Resilience Bill mean for higher education providers?
The Cyber Security and Resilience (Network and Information Systems) Bill is the government's most significant reform of UK cyber legislation since the NIS Regulations 2018. The Bill will expand scope, strengthen regulators, and future-proof the regime against evolving threats.
It’s currently progressing through Parliament – but where do higher education providers sit within it?
The short answer: Not directly in scope, but don’t stop reading
The Bill brings data centre services and large load controller services into the regulated regime alongside existing operators of essential services such as energy, transport, health and water.
Alongside the relevant digital service providers (online marketplaces, platforms and cloud computing services) recognised under the existing regime, the Bill also creates a new category of regulated organisation: managed service providers.
Universities are not expressly recognised as organisations regulated under the existing or new regime. However, a university could come into scope if, for example, it:
(i) Operates a significant commercial data centre used by third parties.
(ii) Provides managed IT or cloud services to NHS trusts or other critical infrastructure operators.
(iii) Runs research facilities designated as critical suppliers to government or critical national infrastructure bodies.
Why the Bill matters to all higher education institutions
The National Cyber Security Centre (NCSC) has warned that the cyber threat facing the UK is growing significantly, and higher education providers are firmly in its sights.
The NCSC has identified higher education as a sector facing considerable cyber risk, given the volume of personal data, research data and intellectual property that universities hold. Many institutions are already voluntarily adopting standards comparable to those required of regulated entities.
The real exposure for most providers lies in the supply chain. Managed service providers often have extensive access to their customers' systems and will now fall within scope, required to meet robust cyber security standards regulated by the ICO.
If your outsourced IT provider, cloud platform or core application supplier becomes a regulated entity under the Bill, the expectations placed on them will flow directly into your institution's risk profile.
Practical steps for universities
Audit your supply chain: Identify which managed service providers and IT suppliers are likely to fall within scope of the Bill and ask them now what steps they are taking to prepare.
Update procurement and due diligence processes: Ensure that cyber security compliance with the Bill's requirements forms part of your standard supplier assessment.
Review template contracts and procurement frameworks: Contracts with managed service providers should be updated to require compliance, incident notification, and evidence of adequate cyber security measures.
Raise cyber governance at board level: The Bill signals a step change in expectations. Universities should ensure cyber resilience is a standing item at senior level, not just an IT matter.
The Bill does not directly regulate higher education providers, but the standards it sets, and the obligations it places on your suppliers, will shape the cyber security environment in which every university operates.
For further guidance on how the Cyber Security and Resilience Bill may affect your institution, please our specialist Data, privacy and cybersecurity team.
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