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January 31, 2024

How Darktrace Defeated SmokeLoader Malware

Read how Darktrace's AI identified and neutralized SmokeLoader malware. Gain insights into their proactive approach to cybersecurity.
Inside the SOC
Darktrace cyber analysts are world-class experts in threat intelligence, threat hunting and incident response, and provide 24/7 SOC support to thousands of Darktrace customers around the globe. Inside the SOC is exclusively authored by these experts, providing analysis of cyber incidents and threat trends, based on real-world experience in the field.
Written by
Patrick Anjos
Senior Cyber Analyst
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31
Jan 2024

What is Loader Malware?

Loader malware is a type of malicious software designed primarily to infiltrate a system and then download and execute additional malicious payloads.

In recent years, loader malware has emerged as a significant threat for organizations worldwide. This trend is expected to continue given the widespread availability of many loader strains within the Malware-as-a-Service (MaaS) marketplace. The MaaS marketplace contains a wide variety of innovative strains which are both affordable, with toolkits ranging from USD 400 to USD 1,650 [1], and continuously improving, aiming to avoid traditional detection mechanisms.

SmokeLoader is one such example of a MaaS strain that has been observed in the wild since 2011 and continues to pose a significant threat to organizations and their security teams.

How does SmokeLoader Malware work?

SmokeLoader’s ability to drop an array of different malware strains onto infected systems, from backdoors, ransomware, cryptominers, password stealers, point-of-sale malware and banking trojans, means its a highly versatile loader that has remained consistently popular among threat actors.

In addition to its versatility, it also exhibits advanced evasion strategies that make it difficult for traditional security solutions to detect and remove, and it is easily distributed via methods like spam emails or malicious file downloads.

Between July and August 2023, Darktrace observed an increasing trend in SmokeLoader compromises across its customer base. The anomaly-based threat detection capabilities of Darktrace, coupled with the autonomous response technology, identified and contained the SmokeLoader infections in their initial stages, preventing attackers from causing further disruption by deploying other malicious software or ransomware.

SmokeLoader Malware Attack Details

PROPagate Injection Technique

SmokeLoader utilizes the PROPagate code injection technique, a less common method that inserts malicious code into existing processes in order to appear legitimate and bypass traditional signature-based security measures [2] [3]. In the case of SmokeLoader, this technique exploits the Windows SetWindowsSubclass function, which is typically used to add or change the behavior of Windows Operation System. By manipulating this function, SmokeLoader can inject its code into other running processes, such as the Internet Explorer. This not only helps to disguise  the malware's activity but also allows attackers to leverage the permissions and capabilities of the infected process.

Obfuscation Methods

SmokeLoader is known to employ several obfuscation techniques to evade the detection and analysis of security teams. The techniques include scrambling portable executable files, encrypting its malicious code, obfuscating API functions and packing, and are intended to make the malware’s code appear harmless or unremarkable to antivirus software. This allows attackers to slip past defenses and execute their malicious activities while remaining undetected.

Infection Vector and Communication

SmokeLoader typically spreads via phishing emails that employ social engineering tactics to convince users to unknowingly download malicious payloads and execute the malware. Once installed on target networks, SmokeLoader acts as a backdoor, allowing attackers to control infected systems and download further malicious payloads from command-and-control (C2) servers. SmokeLoader uses fast flux, a DNS technique utilized by botets whereby IP addresses associated with C2 domains are rapidly changed, making it difficult to trace the source of the attack. This technique also boosts the resilience of attack, as taking down one or two malicious IP addresses will not significantly impact the botnet's operation.

Continuous Evolution

As with many MaaS strains, SmokeLoader is continuously evolving, with its developers regularly adding new features and techniques to increase its effectiveness and evasiveness. This includes new obfuscation methods, injection techniques, and communication protocols. This constant evolution makes SmokeLoader a significant threat and underscores the importance of advanced threat detection and response capabilities solution.

Darktrace’s Coverage of SmokeLoader Attack

Between July and August 2023, Darktrace detected one particular SmokeLoader infection at multiple stages of its kill chain on a customer network. This detection was made possible by Darktrace DETECT’s anomaly-based approach and Self-Learning AI that allows it to identify subtle deviations in device behavior.

One of the key components of this process is the classification of endpoint rarity and determining whether an endpoint is new or unusual for any given network. This classification is applied to various aspects of observed endpoints, such as domains, IP addresses, or hostnames within the network. It thereby plays a vital role in identifying SmokeLoader activity, such as the initial infection vector or C2 communication, which typically involve a device contacting a malicious endpoint associated with SmokeLoader.

The First Signs of Infection SmokeLoader Infection

Beginning in July 2023, Darktrace observed a surge in suspicious activities that were assessed with moderate to high confidence to be associated with SmokeLoader malware.

For example on July 30, a device was observed making a successful HTTPS request to humman[.]art, a domain that had never been seen on the network, and therefore classified as 100% rare by DETECT. During this connection, the device in question received a total of 6.0 KiB of data from the unusual endpoint. Open-source intelligence (OSINT) sources reported with high confidence that this domain was associated with the SmokeLoader C2 botnet.

The device was then detected making an HTTP request to another 100% rare external IP, namely 85.208.139[.]35, using a new user agent. This request contained the URI ‘/DefenUpdate.exe’, suggesting a possible download of an executable (.exe) file. This was corroborated by the total amount of data received in this connection, 4.3 MB. Both the file name and its size suggest that the offending device may have downloaded additional malicious tooling from the SmokeLoader C2 endpoint, such as a trojan or information stealer, as reported on OSINT platforms [4].

Figure 1: Device event log showing the moment when a device made its first connection to a SmokeLoader associated domain, and the use of a new user agent. A few seconds later, the DETECT model “Anomalous Connection / New User Agent to IP Without Hostname” breached.

The observed new user agent, “Mozilla/5.0 (Windows NT 10.0; Win64; x64; Trident/7.0; rv:11.0) like Gecko” was identified as suspicious by Darktrace leading to the “Anomalous Connection / New User Agent to IP Without Hostname” DETECT model breach.

As this specific user agent was associated with the Internet Explorer browser running on Windows 10, it may not have appeared suspicious to traditional security tools. However, Darktrace’s anomaly-based detection allows it to identify and mitigate emerging threats, even those that utilize sophisticated evasion techniques.

This is particularly noteworthy in this case because, as discussed earlier, SmokeLoader is known to inject its malicious code into legitimate processes, like Internet Explorer.

Figure 2: Darktrace detecting the affected device leveraging a new user agent and establishing an anomalous HTTP connection with an external IP, which was 100% rare to the network.

C2 Communication

Darktrace continued to observe the device making repeated connections to the humman[.]art endpoint. Over the next few days. On August 7, the device was observed making unusual POST requests to the endpoint using port 80, breaching the ‘Anomalous Connection / Multiple HTTP POSTs to Rare Hostname’ DETECT model. These observed POST requests were observed over a period of around 10 days and consisted of a pattern of 8 requests, each with a ten-minute interval.

Figure 3: Model Breach Event Log highlighting the Darktrace DETECT model breach ‘Anomalous Connection / Multiple HTTP POSTs to Rare Hostname’.

Upon investigating the details of this activity identified by Darktrace DETECT, a particular pattern was observed in these requests: they used the same user-agent, “Mozilla/5.0 (Windows NT 10.0; Win64; x64; Trident/7.0; rv:11.0) like Gecko”, which was previously detected in the initial breach.

Additionally, they the requests had a constantly changing  eferrer header, possibly using randomly generated domain names for each request. Further examination of the packet capture (PCAP) from these requests revealed that the payload in these POST requests contained an RC4 encrypted string, strongly indicating SmokeLoader C2 activity.

Figure4: Advanced Search results display an unusual pattern in the requests made by the device to the hostname humman[.]art. This pattern shows a constant change in the referrer header for each request, indicating anomalous behavior.
Figure 5: The PCAP shows the payload seen in these POST requests contained an RC4 encrypted string strongly indicating SmokeLoader C2 activity.  

Unfortunately in this case, Darktrace RESPOND was not active on the network meaning that the attack was able to progress through its kill chain. Despite this, the timely alerts and detailed incident insights provided by Darktrace DETECT allowed the customer’s security team to begin their remediation process, implementing blocks on their firewall, thus preventing the SmokeLoader malware from continuing its communication with C2 infrastructure.

Darktrace RESPOND Halting Potential Threats from the Initial Stages of Detection

With Darktrace RESPOND, organizations can move beyond threat detection to proactive defense against emerging threats. RESPOND is designed to halt threats as soon as they are identified by DETECT, preventing them from escalating into full-blown compromises. This is achieved through advanced machine learning and Self-Learning AI that is able to understand  the normal ‘pattern of life’ of customer networks, allowing for swift and accurate threat detection and response.

One pertinent example was seen on July 6, when Darktrace detected a separate SmokeLoader case on a customer network with RESPOND enabled in autonomous response mode. Darktrace DETECT initially identified a string of anomalous activity associated with the download of suspicious executable files, triggering the ‘Anomalous File / Multiple EXE from Rare External Locations’ model to breach.

The device was observed downloading an executable file (‘6523.exe’ and ‘/g.exe’) via HTTP over port 80. These downloads originated from endpoints that had never been seen within the customer’s environment, namely ‘hugersi[.]com’ and ‘45.66.230[.]164’, both of which had strongly been linked to SmokeLoader by OSINT sources, likely indicating the initial infection stage of the attack [5].

Figure 6: This figure illustrates Darktrace DETECT observing a device downloading multiple .exe files from rare endpoints and the associated model breach, ‘Anomalous File / Multiple EXE from Rare External Locations’.

Around the same time, Darktrace also observed the same device downloading an unusual file with a numeric file name. Threat actors often employ this tactic in order to avoid using file name patterns that could easily be recognized and blocked by traditional security measures; by frequently changing file names, malicious executables are more likely to remain undetected.

Figure 7: Graph showing the unusually high number of executable files downloaded by the device during the initial infection stage of the attack. The orange and red circles represent the number of model breaches that the device made during the observed activity related to SmokeLoader infection.
Figure 8: This figure illustrates the moment when Darktrace DETECT identified a suspicious download with a numeric file name.

With Darktrace RESPOND active and enabled in autonomous response mode, the SmokeLoader infection was thwarted in the first instance. RESPOND took swift autonomous action by blocking connections to the suspicious endpoints identified by DETECT, blocking all outgoing traffic, and enforcing a pre-established “pattern of life” on offending devices. By enforcing a patten of life on a device, Darktrace RESPOND ensures that it cannot deviate from its ‘normal’ activity to carry out potentially malicious activity, while allowing the device to continue expected business operations.

Figure 9:  A total of 8 RESPOND actions were applied, including blocking connections to suspicious endpoints and domains associated with SmokeLoader.

In addition to the autonomous mitigative actions taken by RESPOND, this customer also received a Proactive Threat Notification (PTN) informing them of potentially malicious activity on their network. This prompted the Darktrace Security Operations Center (SOC) to investigate and document the incident, allowing the customer’s security team to shift their focus to remediating and removing the threat of SmokeLoader.

Conclusion

Ultimately, Darktrace showcased its ability to detect and contain versatile and evasive strains of loader malware, like SmokeLoader. Despite its adeptness at bypassing conventional security tools by frequently changing its C2 infrastructure, utilizing existing processes to infect malicious code, and obfuscating malicious file and domain names, Darktrace’s anomaly-based approach allowed it to recognize such activity as deviations from expected network behavior, regardless of their apparent legitimacy.

Considering SmokeLoader’s wide array of functions, including C2 communication that could be used to facilitate additional attacks like exfiltration, or even the deployment of information-stealers or ransomware, Darktrace proved to be crucial in safeguarding customer networks. By identifying and mitigating SmokeLoader at the earliest possible stage, Darktrace effectively prevented the compromises from escalating into more damaging and disruptive compromises.

With the threat of loader malware expected to continue growing alongside the boom of the MaaS industry, it is paramount for organizations to adopt proactive security solutions, like Darktrace DETECT+RESPOND, that are able to make intelligent decisions to identify and neutralize sophisticated attacks.

Credit to Patrick Anjos, Senior Cyber Analyst, Justin Torres, Cyber Analyst

Appendices

Darktrace DETECT Model Detections

- Anomalous Connection / New User Agent to IP Without Hostname

- Anomalous Connection / Multiple HTTP POSTs to Rare Hostname

- Anomalous File / Multiple EXE from Rare External Locations

- Anomalous File / Numeric File Download

List of IOCs (IOC / Type / Description + Confidence)

- 85.208.139[.]35 / IP / SmokeLoader C2 Endpoint

- 185.174.137[.]109 / IP / SmokeLoader C2 Endpoint

- 45.66.230[.]164 / IP / SmokeLoader C2 Endpoint

- 91.215.85[.]147 / IP / SmokeLoader C2 Endpoint

- tolilolihul[.]net / Hostname / SmokeLoader C2 Endpoint

- bulimu55t[.]net / Hostname / SmokeLoader C2 Endpoint

- potunulit[.]org / Hostname / SmokeLoader C2 Endpoint

- hugersi[.]com / Hostname / SmokeLoader C2 Endpoint

- human[.]art / Hostname / SmokeLoader C2 Endpoint

- 371b0d5c867c2f33ae270faa14946c77f4b0953 / SHA1 / SmokeLoader Executable

References:

[1] https://bazaar.abuse.ch/sample/d7c395ab2b6ef69210221337ea292e204b0f73fef8840b6e64ab88595eda45b3/#intel

[2] https://malpedia.caad.fkie.fraunhofer.de/details/win.smokeloader

[3] https://www.darkreading.com/cyber-risk/breaking-down-the-propagate-code-injection-attack

[4] https://n1ght-w0lf.github.io/malware%20analysis/smokeloader/

[5] https://therecord.media/surge-in-smokeloader-malware-attacks-targeting-ukrainian-financial-gov-orgs

MITRE ATT&CK Mapping

Model: Anomalous Connection / New User Agent to IP Without Hostname

ID: T1071.001

Sub technique: T1071

Tactic: COMMAND AND CONTROL

Technique Name: Web Protocols

Model: Anomalous Connection / Multiple HTTP POSTs to Rare Hostname

ID: T1185

Sub technique: -

Tactic: COLLECTION

Technique Name: Man in the Browser

ID: T1071.001

Sub technique: T1071

Tactic: COMMAND AND CONTROL

Technique Name: Web Protocols

Model: Anomalous File / Multiple EXE from Rare External Locations

ID: T1189

Sub technique: -

Tactic: INITIAL ACCESS

Technique Name: Drive-by Compromise

ID: T1588.001

Sub technique: - T1588

Tactic: RESOURCE DEVELOPMENT

Technique Name: Malware

Model: Anomalous File / Numeric File Download

ID: T1189

Sub technique: -

Tactic: INITIAL ACCESS

Technique Name: Drive-by Compromise

ID: T1588.001

Sub technique: - T1588

Tactic: RESOURCE DEVELOPMENT

Technique Name: Malware

Inside the SOC
Darktrace cyber analysts are world-class experts in threat intelligence, threat hunting and incident response, and provide 24/7 SOC support to thousands of Darktrace customers around the globe. Inside the SOC is exclusively authored by these experts, providing analysis of cyber incidents and threat trends, based on real-world experience in the field.
Written by
Patrick Anjos
Senior Cyber Analyst

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November 26, 2025

CastleLoader & CastleRAT: Behind TAG150’s Modular Malware Delivery System

CastleLoader & CastleRAT: Behind TAG150’s Modular Malware Delivery SystemDefault blog imageDefault blog image

What is TAG-150?

TAG-150, a relatively new Malware-as-a-Service (MaaS) operator, has been active since March 2025, demonstrating rapid development and an expansive, evolving infrastructure designed to support its malicious operations. The group employs two custom malware families, CastleLoader and CastleRAT, to compromise target systems, with a primary focus on the United States [1]. TAG-150’s infrastructure included numerous victim-facing components, such as IP addresses and domains functioning as command-and-control (C2) servers associated with malware families like SecTopRAT and WarmCookie, in addition to CastleLoader and CastleRAT [2].

As of May 2025, CastleLoader alone had infected a reported 469 devices, underscoring the scale and sophistication of TAG-150’s campaign [1].

What are CastleLoader and CastleRAT?

CastleLoader is a loader malware, primarily designed to download and install additional malware, enabling chain infections across compromised systems [3]. TAG-150 employs a technique known as ClickFix, which uses deceptive domains that mimic document verification systems or browser update notifications to trick victims into executing malicious scripts. Furthermore, CastleLoader leverages fake GitHub repositories that impersonate legitimate tools as a distribution method, luring unsuspecting users into downloading and installing malware on their devices [4].

CastleRAT, meanwhile, is a remote access trojan (RAT) that serves as one of the primary payloads delivered by CastleLoader. Once deployed, CastleRAT grants attackers extensive control over the compromised system, enabling capabilities such as keylogging, screen capturing, and remote shell access.

TAG-150 leverages CastleLoader as its initial delivery mechanism, with CastleRAT acting as the main payload. This two-stage attack strategy enhances the resilience and effectiveness of their operations by separating the initial infection vector from the final payload deployment.

How are they deployed?

Castleloader uses code-obfuscation methods such as dead-code insertion and packing to hinder both static and dynamic analysis. After the payload is unpacked, it connects to its command-and-control server to retrieve and running additional, targeted components.

Its modular architecture enables it to function both as a delivery mechanism and a staging utility, allowing threat actors to decouple the initial infection from payload deployment. CastleLoader typically delivers its payloads as Portable Executables (PEs) containing embedded shellcode. This shellcode activates the loader’s core module, which then connects to the C2 server to retrieve and execute the next-stage malware.[6]

Following this, attackers deploy the ClickFix technique, impersonating legitimate software distribution platforms like Google Meet or browser update notifications. These deceptive sites trick victims into copying and executing PowerShell commands, thereby initiating the infection kill chain. [1]

When a user clicks on a spoofed Cloudflare “Verification Stepprompt, a background request is sent to a PHP script on the distribution domain (e.g., /s.php?an=0). The server’s response is then automatically copied to the user’s clipboard using the ‘unsecuredCopyToClipboard()’ function. [7].

The Python-based variant of CastleRAT, known as “PyNightShade,” has been engineered with stealth in mind, showing minimal detection across antivirus platforms [2]. As illustrated in Figure 1, PyNightShade communicates with the geolocation API service ip-api[.]com, demonstrating both request and response behavior

Packet Capture (PCAP) of PyNightShade, the Python-based variant of CastleRAT, communicating with the geolocation API service ip-api[.]com.
Figure 1: Packet Capture (PCAP) of PyNightShade, the Python-based variant of CastleRAT, communicating with the geolocation API service ip-api[.]com.

Darktrace Coverage

In mid-2025, Darktrace observed a range of anomalous activities across its customer base that appeared linked to CastleLoader, including the example below from a US based organization.

The activity began on June 26, when a device on the customer’s network was observed connecting to the IP address 173.44.141[.]89, a previously unseen IP for this network along with the use of multiple user agents, which was also rare for the user.  It was later determined that the IP address was a known indicator of compromise (IoC) associated with TAG-150’s CastleRAT and CastleLoader operations [2][5].

Figure 2: Darktrace’s detection of a device making unusual connections to the malicious endpoint 173.44.141[.]89.

The device was observed downloading two scripts from this endpoint, namely ‘/service/download/data_5x.bin’ and ‘/service/download/data_6x.bin’, which have both been linked to CastleLoader infections by open-source intelligence (OSINT) [8]. The archives contains embedded shellcode, which enables attackers to execute arbitrary code directly in memory, bypassing disk writes and making detection by endpoint detection and response (EDR) tools significantly more difficult [2].

 Darktrace’s detection of two scripts from the malicious endpoint.
Figure 3: Darktrace’s detection of two scripts from the malicious endpoint.

In addition to this, the affected device exhibited a high volume of internal connections to a broad range of endpoints, indicating potential scanning activity. Such behavior is often associated with reconnaissance efforts aimed at mapping internal infrastructure.

Darktrace / NETWORK correlated these behaviors and generated an Enhanced Monitoring model, a high-fidelity security model designed to detect activity consistent with the early stages of an attack. These high-priority models are continuously monitored and triaged by Darktrace’s Security Operations Center (SOC) as part of the Managed Threat Detection and Managed Detection & Response services, ensuring that subscribed customers are promptly alerted to emerging threats.

Darktrace detected an unusual ZIP file download alongside the anomalous script, followed by internal connectivity. This activity was correlated under an Enhanced Monitoring model.
Figure 4: Darktrace detected an unusual ZIP file download alongside the anomalous script, followed by internal connectivity. This activity was correlated under an Enhanced Monitoring model.

Darktrace Autonomous Response

Fortunately, Darktrace’s Autonomous Response capability was fully configured, enabling it to take immediate action against the offending device by blocking any further connections external to the malicious endpoint, 173.44.141[.]89. Additionally, Darktrace enforced a ‘group pattern of life’ on the device, restricting its behavior to match other devices in its peer group, ensuring it could not deviate from expected activity, while also blocking connections over 443, shutting down any unwanted internal scanning.

Figure 5: Actions performed by Darktrace’s Autonomous Response to contain the ongoing attack.

Conclusion

The rise of the MaaS ecosystem, coupled with attackers’ growing ability to customize tools and techniques for specific targets, is making intrusion prevention increasingly challenging for security teams. Many threat actors now leverage modular toolkits, dynamic infrastructure, and tailored payloads to evade static defenses and exploit even minor visibility gaps. In this instance, Darktrace demonstrated its capability to counter these evolving tactics by identifying early-stage attack chain behaviors such as network scanning and the initial infection attempt. Autonomous Response then blocked the CastleLoader IP delivering the malicious ZIP payload, halting the attack before escalation and protecting the organization from a potentially damaging multi-stage compromise

Credit to Ahmed Gardezi (Cyber Analyst) Tyler Rhea (Senior Cyber Analyst)
Edited by Ryan Traill (Analyst Content Lead)

Appendices

Darktrace Model Detections

  • Anomalous Connection / Unusual Internal Connections
  • Anomalous File / Zip or Gzip from Rare External Location
  • Anomalous File / Script from Rare External Location
  • Initial Attack Chain Activity (Enhanced Monitoring Model)

MITRE ATT&CK Mapping

  • T15588.001 - Resource Development – Malware
  • TG1599 – Defence Evasion – Network Boundary Bridging
  • T1046 – Discovery – Network Service Scanning
  • T1189 – Initial Access

List of IoCs
IoC - Type - Description + Confidence

  • 173.44.141[.]89 – IP – CastleLoader C2 Infrastructure
  • 173.44.141[.]89/service/download/data_5x.bin – URI – CastleLoader Script
  • 173.44.141[.]89/service/download/data_6x.bin – URI  - CastleLoader Script
  • wsc.zip – ZIP file – Possible Payload

References

[1] - https://blog.polyswarm.io/castleloader

[2] - https://www.recordedfuture.com/research/from-castleloader-to-castlerat-tag-150-advances-operations

[3] - https://www.pcrisk.com/removal-guides/34160-castleloader-malware

[4] - https://www.scworld.com/brief/malware-loader-castleloader-targets-devices-via-fake-github-clickfix-phishing

[5] https://www.virustotal.com/gui/ip-address/173.44.141.89/community

[6] https://thehackernews.com/2025/07/castleloader-malware-infects-469.html

[7] https://www.cryptika.com/new-castleloader-attack-using-cloudflare-themed-clickfix-technique-to-infect-windows-computers/

[8] https://www.cryptika.com/castlebot-malware-as-a-service-deploys-range-of-payloads-linked-to-ransomware-attacks/

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Tyler Rhea
Senior Cyber Analyst

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November 26, 2025

UK Cyber Security & Resilience Bill: What Organizations Need to Know

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Why the Bill has been introduced

The UK’s cyber threat landscape has evolved dramatically since the 2018 NIS regime was introduced. Incidents such as the Synnovis attack against hospitals and the British Library ransomware attack show how quickly operational risk can become public harm. In this context, the UK Department for Science, Innovation and Technology estimates that cyber-attacks cost UK businesses around £14.7 billion each year.

At the same time, the widespread adoption of AI has expanded organisations’ attack surfaces and empowered threat actors to launch more effective and sophisticated activities, including crafting convincing phishing campaigns, exploiting vulnerabilities and initiating ransomware attacks at unprecedented speed and scale.  

The CSRB responds to these challenges by widening who is regulated, accelerating incident reporting and tightening supply chain accountability, while enabling rapid updates that keep pace with technology and emerging risks.

Key provisions of the Cyber Security and Resilience Bill

A wider set of organisations in scope

The Bill significantly broadens the range of organisations regulated under the NIS framework.

  • Managed service providers (MSPs) - medium and large MSPs, including MSSPs, managed SOCs, SIEM providers and similar services,will now fall under NIS obligations due to their systemic importance and privileged access to client systems. The Information Commissioner’s Office (ICO) will act as the regulator. Government analysis anticipates that a further 900 to 1,100 MSPs will be in scope.
  • Data infrastructure is now recognised as essential to the functioning of the economy and public services. Medium and large data centres, as well as enterprise facilities meeting specified thresholds, will be required to implement appropriate and proportionate measures to manage cyber risk. Oversight will be shared between DSIT and Ofcom, with Ofcom serving as the operational regulator.
  • Organisations that manage electrical loads for smart appliances, such as those supporting EV charging during peak times, are now within scope.

These additions sit alongside existing NIS-regulated sectors such as transport, energy, water, health, digital infrastructure, and certain digital services (including online marketplaces, search engines, and cloud computing).

Stronger supply chain requirements

Under the CSRB, regulators can now designate third-party suppliers as ‘designated critical suppliers’ (DCS) when certain threshold criteria are met and where disruption could have significant knock-on effects. Designated suppliers will be subject to the same security and incident-reporting obligations as Operators of Essential Services (OES) and Relevant Digital Service Providers (RDSPs).

Government will scope the supply chain duties for OES and RDSPs via secondary legislation, following consultation. infrastructure incidents where a single supplier’s compromise caused widespread disruption.

Faster incident reporting

Sector-specific regulators, 12 in total, will be responsible for implementing the CSRB, allowing for more effective and consistent reporting. In addition, the CSRB introduces a two-stage reporting process and expands incident reporting criteria. Regulated entities must submit an initial notification within 24 hours of becoming aware of a significant incident, followed by an incident report within 72 hours. Incident reporting criteria are also broadened to capture incidents beyond those which actually resulted in an interruption, ensuring earlier visibility for regulators and the National Cyber Security Centre (NCSC). The importance of information sharing across agencies, law enforcement and regulators is also facilitated by the CSRB.

The reforms also require data centres and managed service providers to notify affected customers where they are likely to have been impacted by a cyber incident.

An agile regulatory framework

To keep pace with technological change, the CSRB will enable the Secretary of State to update elements of the framework via secondary legislation. Supporting materials such as the NCSC Cyber Assessment Framework (CAF) are to be "put on a stronger footing” allowing for requirements to be more easily followed, managed and updated. Regulators will also now be able to recover full costs associated with NIS duties meaning they are better resourced to carry out their associated responsibilities.

Relevant Managed Service Providers must identify and take appropriate and proportionate measures to manage risks to the systems they rely on for providing services within the UK. Importantly, these measures must, having regard to the state of the art, ensure a level of security appropriate to the risk posed, and prevent or minimise the impact of incidents.

The Secretary of State will also be empowered to issue a Statement of Strategic Priorities, setting cross-regime outcomes to drive consistency across the 12 competent authorities responsible for implementation.

Penalties

The enforcement framework will be strengthened, with maximum fines aligned with comparable regimes such as the GDPR, which incorporate maximums tied to turnover. Under the CSRB, maximum penalties for more serious breaches could be up to £17 million or 4% of global turnover, whichever is higher.

Next steps

The Bill is expected to progress through Parliament over the course of 2025 and early 2026, with Royal Assent anticipated in 2026. Once enacted, most operational measures will not take immediate effect. Instead, Government will bring key components into force through secondary legislation following further consultation, providing regulators and industry with time to adjust practices and prepare for compliance.

Anticipated timeline

  • 2025-2026: Parliamentary scrutiny and passage;
  • 2026: Royal Assent;  
  • 2026 consultation: DSIT intends to consult on detailed implementation;
  • From 2026 onwards: Phased implementation via secondary legislation, following further consultation led by DSIT.

How Darktrace can help

The CSRB represents a step change in how the UK approaches digital risk, shifting the focus from compliance to resilience.

Darktrace can help organisations operationalise this shift by using AI to detect, investigate and respond to emerging threats at machine speed, before they escalate into incidents requiring regulatory notification. Proactive tools which can be included in the Darktrace platform allow security teams to stress-test defences, map supply chain exposure and rehearse recovery scenarios, directly supporting the CSRB’s focus on resilience, transparency and rapid response. If an incident does occur, Darktrace’s autonomous agent, Cyber AI Analyst, can accelerate investigations and provide a view of every stage of the attack chain, supporting timely reporting.  

Darktrace’s AI can provide organisations with a vital lens into both internal and external cyber risk. By continuously learning patterns of behaviour across interconnected systems, Darktrace can flag potential compromise or disruption to detect supply chain risk before it impacts your organisation.

In a landscape where compliance and resilience go hand in hand, Darktrace can equip organisations to stay ahead of both evolving threats and evolving regulatory requirements.

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