The Cyber Security & Resilience Bill is being talked about as a major update to the UK’s regulatory landscape, but its impact won’t be felt in policy documents or compliance dashboards. It will be felt in the quiet corners of essential services where technology, process and people collide — places where systems were never designed with modern cyber threats in mind, and where resilience isn’t an abstract principle but something that keeps water flowing, turbines stable and transport moving.
Most commentary so far has focused on governance, scope and reporting. Necessary conversations, but safe ones. The more difficult discussion — and the one that will ultimately shape the success of the Bill — sits in operational technology, industrial control systems and the human routines built around them. This is where the UK’s essential services are genuinely exposed, and where resilience will be won or lost.
OT and ICS: the part of the national picture that can’t be tidied with policy
If you think of a critical service as a clean digital stack, you miss the reality entirely. Beneath almost every essential function lies a mixture of proprietary systems, legacy hardware, vendor-specific protocols, segmented networks, patches that can’t always be applied, and operational constraints that have far more to do with safety and continuity than with cyber security.
These environments weren’t built to be agile. They weren’t built to be inspected by regulators. In many cases, they weren’t built to be connected at all.
The CSRB, understandably, stops short of dictating how to secure a treatment plant, signalling system or control room. But by broadening responsibility for resilience, it draws a circle around these OT ecosystems — a recognition that essential services aren’t just digital services. They’re physical processes controlled by systems that don’t neatly align with the expectations placed on modern IT.
This is where the real complexity sits, and it’s the part of the conversation that remains largely unspoken.
When IT expectations meet operational reality
One of the enduring tensions in CNI is the gulf between IT-led security expectations and the practicalities of running industrial systems.
In theory, good cyber practice means regular patching, continuous monitoring, predictable change, and the comfort of knowing every asset is accounted for. In practice, OT environments live by a different rhythm. They value stability above speed. They tolerate risk when alternatives threaten uptime. They depend on vendor support cycles that have little in common with modern software release patterns. They often run equipment that has been safe and functional for decades and is still expected to remain so.
The point isn’t that OT resists security — it’s that OT operates within constraints IT rarely encounters.
Recent guidance from the National Cyber Security Centre reinforces this gap between expectation and reality. Its work on designing safer connectivity for OT doesn’t try to impose IT-style controls onto industrial systems. Instead, it focuses on principles that reflect operational truth: carefully weighing the risks of connectivity, limiting exposure, hardening boundaries, ensuring visibility of connections, and planning for isolation when things go wrong. It’s a pragmatic acknowledgement that resilience in OT isn’t achieved through policy extension or perfect compliance, but through decisions shaped by how systems actually operate. That thinking sits comfortably alongside the intent of the Cyber Security & Resilience Bill, even if the Bill itself stops short of prescribing how those decisions should be made.
The Bill won’t erase that tension, but it will make it harder to hide behind it. Boards will need to understand these realities rather than assume operational environments can be secured by policy extension.
This is where the subtle influence of CAF becomes helpful. Its focus on essential functions, dependencies, detection and recovery provides a way to think about OT/ICS resilience without forcing unrealistic IT controls into systems that won’t support them.
The human layer: still the missing piece in most resilience conversations
For all the technology that underpins essential services, people and processes remain the defining factor in whether systems hold or fail under pressure.
CNI environments rely on operators who understand the quirks and behaviours of their systems intuitively. They rely on informal routines, tacit knowledge, manual interventions and decades of experience carried in people’s heads rather than documentation. These habits are invaluable for continuity, but they also create fragility.
Teams often sit in silos with different goals:
- Engineers optimising for stability
- IT teams for security
- Suppliers for availability
- and governance functions for assurance
When something goes wrong, these worlds collide. The Bill’s emphasis on clearer responsibility and faster incident reporting will bring this tension into sharper focus. Resilience depends on collaboration long before it depends on compliance.
This is an area where defence and government programmes are slightly ahead of the curve. Their operational models already require cross-team alignment, rehearsed incident handling and evidence-led assurance. Those same disciplines will now be expected in CNI environments that haven’t had to operate at that level before.
A more honest way to talk about resilience
The temptation with any new regulation is to reach for frameworks, maturity models and technical controls. They’re tidy and reassuring. But essential services don’t fail in tidy ways. They fail because someone couldn’t apply a patch, because an ICS engineer didn’t recognise a network anomaly, because a vendor integration no one had thought about became the single point of failure, or because an incident plan didn’t match the realities of how the plant was actually being run.
The CSRB creates an opportunity to talk about resilience more honestly.
Not as a checklist, but as the lived interaction between technology, process and people.
Not as something added after the fact, but as something shaped by how the service works day to day.
Why this matters now
The Bill won’t reshape OT or ICS overnight. But it does force organisations to acknowledge them — not as legacy systems or specialist domains, but as core components of national resilience.
For consultancies working in high-assurance environments, this is familiar territory. Secure-by-design thinking, dependency mapping, cross-team alignment, evidence-led assurance: these are approaches that have been proven in defence and government contexts for years. CNI operators will now face similar expectations, often without the structures or habits to support them yet.
That leaves a space for leadership, clarity and realism. And it’s a space Logiq is well placed to speak into.
