UK Ransomware Payment Ban Confirmed… What It Means for the Public Sector and Beyond
Earlier in the year, we at Cyro Cyber wrote about the proposed ban on ransomware payments for those in the public sector.
In late July, the UK Government has confirmed that it will move forward with legislation banning ransomware payments across public sector organisations and operators of critical national infrastructure. This policy shift follows a public consultation conducted earlier this year, in which 72% of respondents supported the proposal. Among public sector and CNI respondents specifically, that number rose to 82%1.
A Response to Growing Threats
This decision comes amid a rise in cyber-attacks targeting public services, including hospitals, councils, transport systems, and energy providers. These organisations are often seen as the most vulnerable due to limited resources, yet they bear the greatest consequences when disrupted. For example, in June 2024, the Qilin ransomware group attacked Synnovis, a pathology provider for London hospitals including King’s College and Guy’s and St Thomas’, leading to over 1,300 outpatient appointment cancellations, more than 800 postponed operations, and this incident being linked to the UK’s first ever death attributed to a cyber-attack2.
Furthermore, in March, Leicester City Council fell victim to a breach by the INC Ransom group, which posted around 25 confidential documents online, including housing, identification, and financial data, and prompted a full shutdown of council systems.3
Until now, the UK’s position on ransomware payments has been shaped largely by guidance from the National Cyber Security Centre (NCSC)4, which has consistently advised organisations not to pay. This guidance is now being backed with enforceable legislation.
Who Does It Affect?
The ban will apply to any publicly funded entity or regulated CNI operator and will make it illegal to transfer ransom payments to attackers. This removes ambiguity and sets a new legal standard for how organisations should respond under pressure.
Mandatory Reporting Requirements
The Government will introduce a mandatory reporting framework that applies to both public and private sector organisations.
For public sector bodies and operators of critical national infrastructure, the legislation will make it illegal to pay ransoms under any circumstances. These organisations must report any ransomware incident within 72 hours, followed by a more detailed account within 28 days. This marks a significant shift from advisory guidance to enforceable legal obligation.
Private sector organisations, while not subject to the payment ban, will also face new expectations. If a company intends to pay a ransom, it must notify the Government before any funds are transferred. This step is intended to reduce the risk of violating sanctions by unknowingly engaging with blacklisted groups. Like the public sector, private firms will be required to submit incident reports within the same timelines.
These, combined measures intended to increase national visibility of ransomware activity, disrupt the financial drivers behind attacks, and support more coordinated law enforcement action. The Government has made clear that the goal is not to criminalise victims, but to improve awareness, offer support, and strengthen defences. In the early phase, enforcement is expected to prioritise education and collaboration over penalties.
What Does This Mean for Public Sector Organisations?
Many in the public sector welcomed the clarity that legislation would bring, with respondents to the consultation highlighting that a clear legal position would simplify decision making and remove uncertainty in high pressure situations. Now, this legislative shift calls for a re-evaluation of operational readiness.
The payment ban removes one possible response from the table, and organisations must be prepared to respond effectively without that option. Incident response plans must be revisited. Backup strategies must be tested and hardened. Supply chain partners should be reviewed to ensure alignment with the same principles and expectations.
Additionally, implications of this policy extend beyond IT and security teams. Executive leaders, Boards, and front line staff all have a role to play in ensuring their organisation is ready to act decisively in the event of a ransomware incident. The clarity introduced by the legislation will help simplify decision making under pressure, but it also raises the bar for what effective preparation looks like. Updated NCSC guidance will follow to reflect the legislative changes, helping organisations align operational procedures with new legal expectations.
Implications for the Private Sector
While the ban does not currently apply to private sector organisations, its effects will still be felt, particularly in light of the upcoming Cyber Security and Resilience Bill, which sets out new security and reporting obligations for a broad range of UK businesses5.
Private companies, especially those operating in regulated industries or supplying services to public sector clients, should anticipate increased scrutiny of their ransomware preparedness and broader cyber resilience posture. The combined effect of the ransomware payment restrictions and forthcoming legislation means that expectations around transparency, incident reporting, and operational resilience are rising across the board.
The government’s proposal to require organisations to notify authorities before making any ransom payment introduces a new layer of oversight and risk management for businesses outside the public sector. Additionally, as attackers adjust their tactics, the private sector may face heightened risk - particularly those firms that have not previously been targeted or have minimal internal capacity to respond. In this context, many organisations will need to reassess their current security controls, incident response procedures, and executive level decision-making frameworks to ensure they are aligned with emerging legal and regulatory standards.
Complexities Still to Be Addressed
While the policy is clear in its intent, several complexities remain. Many public services rely on private sector providers, and it is not yet clear how the legislation will apply in these cases (pending better definition under the Cyber Security and Resilience Bill of CNI and its tiering for MSPs etc.). The private sector also remains a likely target for attackers who seek payment, and there is a risk that criminal groups may shift focus accordingly. These dynamics will need ongoing attention as the policy is implemented and tested in real world scenarios.
We asked our GRC expert, Gareth Roberts, for his perspective on the Government’s latest ransomware measures:
“Introducing mandatory reporting is a necessary and positive step forward, but how enforcement is implemented will be critical to its success. Applying penalties too early risks discouraging disclosure at a time when trust and transparency need to be built. Many organisations are still grappling with the fundamentals without a clear picture of the scale and impact of ransomware across the sector, early punitive measures could be counterproductive.
There is also a risk in granting and publicising exemptions to the payment ban for critical services, national security, or life dependent systems. These could inadvertently make high risk, legacy reliant systems even more attractive to threat actors.
As always, prevention must be prioritised. Raising the baseline across the public sector with mandatory frameworks like Cyber Essentials or ISO27001 would be a meaningful step, but in the meantime, organisations can take their own initiative. Strengthening controls around backups, access management, supply chain due diligence and user awareness training are immediate areas to focus on. Rather than waiting for enforcement, we should be embedding resilience now and recognising those who invest in doing so.”
A Step Toward Long Term Resilience
The Government’s response recognises that ransomware is a long term threat and that disruption of its financial model is only one part of a broader solution. This ban is designed to reduce harm and deny attackers the payouts they rely on, but it must be supported by continued investment in cyber defences, collaboration with all partners, and a commitment to shared intelligence across sectors.
From a security perspective, the ban reinforces the growing emphasis on preparation, resilience, and accountability. For organisations that have delayed investment in these areas, it presents a clear impetus for change.
How Cyro Cyber Can Help
At Cyro Cyber, we work closely with public sector and CNI organisations to strengthen their resilience against ransomware and other evolving cyber threats, preparing for the worst before it happens.
Our services include cyber incident policies, preparation and planning, risk assessments, supply chain reviews, tabletop exercises, ongoing advisory support and incident response. As new legislation comes into force, we’re here to help you prepare, rehearse, and respond with confidence, ensuring your organisation meets its obligations with clarity and control.
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