The introduction of the Cyber Security and Resilience (Network and Information Systems) Bill to the UK Parliament on 12 November 2025 marks a decisive moment for the nation’s digital infrastructure. For healthtech companies and suppliers to the NHS, this legislation is not a routine update; it is a fundamental shift in how cyber risk, accountability, and supply-chain security are governed.
Driven by a rise in high-impact attacks, the Bill aims to modernise the UK’s cyber defence framework by replacing and expanding the existing Network and Information Systems (NIS) Regulations 2018. The urgency behind this shift was underscored by the June 2024 ransomware attack on Synnovis, a major pathology supplier to the NHS. The incident disrupted more than 11,000 appointments and procedures, caused an estimated £32.7 million in financial damage, and was later linked to a patient death during the period of disruption. New government research published alongside the Bill estimates the annual cost of significant cyber attacks at £14.7 billion, signalling the scale of the economic threat the UK now faces.
The message from the government is clear: the threat landscape has outpaced current regulation, and the health and care sector must adapt.
The Bill can be understood through three major themes: expanded scope, stronger regulators, and a more adaptive, resilient national framework.
| Pillar of Reform | Key Provisions | Impact on Healthtech & NHS Suppliers |
|---|---|---|
| 1. Expanded Scope | Regulation extended to medium and large Managed Service Providers (MSPs), data centres, and suppliers that could pose systemic risk. | IT service providers, cloud platforms, and high-impact vendors are now likely to fall directly within the regulatory perimeter. |
| 2. Effective Regulators | New enforcement powers, turnover-based fines, cost-recovery mechanisms, and strengthened incident reporting rules. | Non-compliance becomes a board-level risk. A 24-hour initial reporting requirement elevates the importance of well-rehearsed incident response. |
| 3. Enabling Resilience | Government powers to issue binding directions during national security threats; the ability to update technical requirements more frequently. | Suppliers must stay continuously prepared for updated standards and rapid changes during crises. |
One of the most consequential changes is the direct regulation of medium and large Managed Service Providers (MSPs)—a long-standing blind spot in UK cyber policy. MSPs are broadly defined as providers that manage, monitor, or administer a customer’s IT systems and maintain a connection to those systems. This definition captures IT helpdesks, infrastructure management providers, outsourced cybersecurity teams, cloud hosting services, and many digital health vendors.
These organisations often hold the “keys to the kingdom,” making them prime targets for supply-chain attacks. Under the Bill, MSPs will be required to:
Notify regulators and affected customers of significant cyber incidents within 24 hours,
Provide a full incident report within 72 hours.
Maintain demonstrably robust incident-response plans.
For healthtech companies that either rely on MSPs or act as MSPs themselves, this change demands immediate reassessment of contracts, liabilities, incident reporting workflows, and shared-responsibility models.
The Bill also introduces a new designation: “critical supplier.” Regulators will gain the power to identify suppliers whose disruption could have significant national-level consequences. A healthtech company that provides essential diagnostics software or clinical decision-support services could easily fall into this category.
A critical-supplier designation would trigger mandatory minimum security requirements, similar in intent to the EU’s NIS2 regime and the financial sector’s Critical Third Parties framework. While a consultation and impact-assessment process will accompany any designation, the purpose is clear: eliminate weak links in essential digital supply chains.
For many digital health companies, this could mean preparing for a step up in scrutiny and assurance expectations.
The Bill replaces fixed penalties with turnover-based fines, which may reach up to 4% of global annual revenues or a multimillion-pound cap, whichever is higher. This removes the possibility of treating cyber risk as a tolerable compliance cost.
Combined with escalated reporting obligations, this creates a regulatory environment where poor preparation becomes an existential threat. As Phil Huggins, National CISO for Health and Care, noted, the reforms aim to “drive a step change in cyber maturity” across health and care.
Although the Bill does not directly amend or reference the NHS Data Security and Protection Toolkit (DSPT), its wider context matters:
NHS England is transitioning DSPT to a CAF-aligned model (based on the NCSC Cyber Assessment Framework).
Regulators and NHS organisations will expect stronger evidence of assurance, especially for high-impact suppliers.
Suppliers in scope under the new Bill will face significantly heightened oversight around cyber maturity.
In this environment, a self-assessed "Standards Met" DSPT will increasingly be seen as a baseline, not a differentiator. An independent DSPT assessment provides credible, external assurance that security controls are robust, effective, and aligned with evolving national expectations. While not mandated by the Bill, it is one of the most practical ways suppliers can demonstrate resilience to NHS customers, commissioners, and regulators.
While the Bill will still progress through Parliament before becoming law, the direction of travel is unmistakable. Healthtech leaders should act now to prepare:
Determine whether you qualify as an MSP, a high-impact supplier, or could be designated a critical supplier.
Ensure your organisation can meet the 24-hour initial reporting deadline. Practice until your process is reliable and repeatable.
Conduct thorough due diligence on all third parties. Update contracts to reflect shared responsibilities and reporting obligations.
Move beyond tick-box compliance. Strengthen your controls and consider a DSPT independent assessment to validate your maturity.
The UK government has redrawn the cybersecurity baseline. The era of implicit trust and light-touch oversight is ending. Healthtech suppliers that embrace verifiable resilience, transparency, and stronger supply-chain governance will be best placed to thrive in the NHS ecosystem of the future.