October 9, 2022

Piloting Airline Cyber Security With Artificial Intelligence (AI)

The airline industry is constantly exposed to cyber threats. Darktrace has some tips to help airline professionals bolster their cyber-security efforts.

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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.

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Oct 2022

A Thin Margin for Error

The airline industry has long been known for its thin profit margins, and the high costs of unexpected downtime. 2010’s Eyjafjallajökull eruption in Iceland and the resulting six-day airspace ban across Europe cost airlines $1.7 billion, just a taste of the impact that would come ten years later as a result of the pandemic. The industry collectively amassed more than $180 billion in debt in 2020, and some predictions suggest that by 2024 the industry's debt could exceed its revenue.

Given the impact that further sustained downtime could have on an already ailing industry, airlines are having to take cyber security seriously. Last year’s Colonial Pipeline ransomware attack in the US led to a six-day shutdown of pipeline operations – the same length of time that flights were grounded by the Eyjafjallajökull eruption. But while the industry hasn’t seen a volcanic eruption on that scale in over twelve years, ransomware attacks are striking airlines weekly. Just this year a ransomware attack on SpiceJet left hundreds of passengers stranded at airports across India, despite being contained relatively quickly.

Fraud, Fines and Safety Risks

It isn’t just ransomware which is concerning many in the industry. Data breaches remain one of the biggest threats to airlines, organizations which are responsible at any one time for the personal and financial information of millions of customers. In 2019, British Airways had the data of 380,000 customers stolen, including addresses, birth dates and credit card information, and was fined £20 million (reduced from £183 million due in part to the impact of the pandemic) by the UK’s Information Commissioner’s Office (ICO), the largest issued fine in the ICO’s history. The European airline EasyJet is currently facing a class-action suit seeking £18 billion in damages after failing to properly disclose the loss of 2,208 customers’ credit-card information in 2020.

Airlines are also losing out to card and air mile fraud, with thousands of fraudulent loyalty program accounts being sold on the dark web, as well as the usual roster of attacks including phishing and insider threats which affect businesses of every size and industry. The airlines themselves are not being complacent. In a 2021 report by SITA, 100% of airlines surveyed named cyber security as a key investment for the next three years. Making sure that those investments count will be the next challenge.

There are few industries for which safety and security measures are so important, and while no impact on flight safety as a result of a cyber-attack has yet been reported, agencies like Eurocontrol are already urging caution. Airlines and airports should look at smarter ways to proactively protect their digital environments.

As attacks grow faster and less predictable, organizations are increasingly turning to preventative AI security measures. For airlines, which operate with broad attack surfaces and plenty of valuable data, using tools which can identify and monitor every asset and potential attack path in an organization and take the necessary steps to secure them is the best way to stay ahead of attackers.

Securing Airspace, Securing Cyberspace

As a recreational pilot myself, I understand the extent of the safety measures that go into every flight: the flight plans, pre-flight checks and all of the long-practiced, deep-embedded knowledge. It is this comprehensive and meticulous approach which ought to be reflected in organizations’ cyber security efforts – whether they be airlines, airports or any other type of business. The parallels between the processes of flying and running a digital organization safely give us a helpful way to understand what proper, AI-driven cyber security can do for any organization, airlines included.

Cleared for Takeoff

For the pilot, safety measures start long before they’re sat in the cockpit. Flight planning, which includes planning heading and bearing, taking things like elevation, terrain, and weather conditions into consideration, must be completed in addition to plenty of pre-flight checks. The checklist the pilot works through when performing a walk around and pre-flight inspection will often be ordered so that they work in a circle around the perimeter of the whole plane. These checks prevent potential threats, covering everything from water having mixed with the fuel to birds making nests inside the engine cowling.

Darktrace PREVENT, released in July 2022, serves a similar purpose. The AI autonomously identifies and tests every single user and asset that makes up a business in order to spot potential vulnerabilities and harden defenses where necessary. Like a walk around, PREVENT/Attack Surface Management examines the full range of external assets for threats. Then, by identifying and testing potential attack pathways and mitigating against weak points and worst-case scenarios, PREVENT/End-to-End takes steps to win the fight before an attack has been launched.

Maintaining Good Visibility

When you’re piloting a plane, first and foremost you need a way to detect key variables. Your fundamental flight instruments in the cockpit are known as the six pack:

1. Airspeed Indicator
2. Attitude Indicator or Artificial Horizon
3. Altimeter
4. Turn Coordinator
5. Heading Indicator
6. Vertical Speed Indicator

These six instruments provide the critical information needed by any pilot to safely fly the aircraft. While additional instruments are required to conduct flights In low-visibility or ‘Instrument Meteorological Conditions’ (IMC) conditions, these will be essential when getting out of dangerous situations such as inadvertently flying into cloud.

Understanding an environment and adapting to its changes is also fundamental to Darktrace DETECT: an AI-driven technology which focuses on building a comprehensive knowledge of an organization’s environment in order to spot threats the moment they appear. Because it understands what is ‘normal’ for the organization, Darktrace DETECT is able to correlate multiple subtle anomalies in order to expose emerging attacks – even those which have never been seen before. Like those essential flight instruments, DETECT offers visibility into otherwise obscure regions of the environment, and ensures that any potential problems are spotted as early as possible.

Mayday, Mayday

In aviation and security, moving quickly once a threat has been detected is critical. When an engine stalls at 3,000 feet above ground level, you don’t have time to get the training books out and start figuring out what to do. Pilots are taught to “always have an out” and be ready to use it.

In aviation, an effective response relies for the most part on the knowledge and quick reactions of the pilot, but in cyber security, AI is making response faster and more effective than ever. Darktrace RESPOND uses DETECT’s contextual understanding in order to take the optimum action to mitigate a threat. Adaptability of this response is crucial: a single cyber-attack can come in any number of configurations, and Darktrace RESPOND is able to tailor its actions appropriately. Attacks today move too fast for human teams to be expected to keep up, but with AI taking actions at machine speed organizations can remain protected.

Always Learning

One of the best pieces of advice a pilot can take is to always be learning. Every flight is an opportunity to learn something new and become a better and safer pilot.

Darktrace DETECT, RESPOND, and PREVENT are all driven by Self-Learning AI, a technology which not only builds but continuously evolves its understanding of each business. This means that as an organization grows, adding more users, assets, or applications, its Darktrace coverage grows too, using each new data point to enhance its understanding and the accuracy of its actions and detections. Darktrace’s separate technologies also learn from each other. Each of the three product families continuously feeds data into the others, helping to enhance their capabilities and improving their ability to keep organizations secured against threats.

As cyber-attacks proliferate and increase in sophistication, they will continue to target organizations like airlines, which have large attack surfaces and copious amounts of customer data, and which cannot afford to weather sustained downtime. But with AI offering effective, proactive measures and clear-sky visibility, security teams can be confident in their ability to fight back.

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June 5, 2025

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June 16, 2025

Tracking CVE-2025-31324: Darktrace’s detection of SAP Netweaver exploitation before and after disclosure

Introduction: Exploiting SAP platforms

Global enterprises depend extensively on SAP platforms, such as SAP NetWeaver and Visual Composer, to run critical business processes worldwide. These systems; however, are increasingly appealing targets for well-resourced adversaries:

In March 2025, CISA issued an alert confirming active exploitation of a 2017 SAP NetWeaver vulnerability (CVE‑2017‑12637), enabling attackers to perform directory traversal and exfiltrate sensitive files, including credentials, from internet-facing systems
In April–May 2025, public reporting revealed that a high‑severity zero-day in SAP Visual Composer (CVE‑2025‑31324, CVSS 10.0) has been used in the wild by threat actors deploying web‑shells and achieving full system compromise
Moreover, CISA has added both NetWeaver and Visual Composer flaws to its Known Exploited Vulnerabilities (KEV) catalog, marking them as verified active threats due to widespread abuse

What is CVE-2025-31324?

CVE-2025-31324 affects SAP’s NetWeaver Visual Composer, a web-based software modeling tool. SAP NetWeaver is an application server and development platform that runs and connects SAP and non-SAP applications across different technologies [2]. It is commonly used by process specialists to develop application components without coding in government agencies, large enterprises, and by critical infrastructure operators [4].

CVE-2025-31324 affects SAP’s Netweaver Visual Composer Framework 7.1x (all SPS) and above [4]. The vulnerability in a Java Servlet (/irj/servlet_jsp) would enable an unauthorized actor to upload arbitrary files to the /developmentserver/metadatauploader endpoint, potentially resulting in remote code execution (RCE) and full system compromise [3]. The issue stems from an improper authentication and authorization check in the SAP NetWeaver Application Server Java systems [4].

What is the severity rating of CVE-2025-31324?

The vulnerability, first disclosed on April 24, 2025, carries the highest severity rating (CVSS v3 score: 10.0) and could allow remote attackers to upload malicious files without requiring authentication [1][5]. Although SAP released a workaround on April 8, many organizations are hesitant to take their business-critical SAP NetWeaver systems offline, leaving them exposed to potential exploitation [2].

How is CVE-2025-31324 exploited?

The vulnerability is exploitable by sending specifically crafted GET, POST, or HEAD HTTP requests to the /developmentserver/metadatauploader URL using either HTTP or HTTPS. Attackers have been seen uploading malicious files (.jsp, .java, or .class files to paths containing “\irj\servlet_jsp\irj\”), most of them being web shells, to publicly accessible SAP NetWeaver systems.

External researchers observed reconnaissance activity targeting this vulnerability in late January 2025, followed by a surge in exploitation attempts in February. The first confirmed compromise was reported in March [4].

Multiple threat actors have reportedly targeted the vulnerability, including Chinese Advanced Persistent Threats (APTs) groups Chaya_004 [7], UNC5221, UNC5174, and CL-STA-0048 [8], as well as ransomware groups like RansomEXX, also known as Storm-2460, BianLian [4] or Qilin [6] (the latter two share the same indicators of compromise (IoCs)).

Following the initial workaround published on April 8, SAP released a security update addressing CVE-2025-31324 and subsequently issued a patch on May 13 (Security Note 3604119) to resolve the root cause of the vulnerability [4].

Darktrace’s coverage of CVE-2025-31324 exploitation

Darktrace has observed activity indicative of threat actors exploiting CVE-2025-31324, including one instance detected before the vulnerability was publicly disclosed.

In April 2025, the Darktrace Threat Research team investigated activity related to the CVE-2025-31324 on SAP devices and identified two cases suggesting active exploitation of the vulnerability. One case was detected prior to the public disclosure of the vulnerability, and the other just two days after it was published.

Early detection of CVE 2025-31324 by Darktrace

Figure 1: Timeline of events for an internet-facing system, believed to be a SAP device, exhibiting activity indicative of CVE-2025-31324 exploitation.

On April 18, six days prior to the public disclosure of CVE-2025-31324, Darktrace began to detect unusual activity on a device belonging to a logistics organization in the Europe, the Middle East and Africa (EMEA) region. Multiple IoCs observed during this incident have since been linked via OSINT to the exploitation of CVE-2025-31324. Notably, however, this reporting was not available at the time of detection, highlighting Darktrace’s ability to detect threats agnostically, without relying on threat intelligence.

The device was observed making domain name resolution request for the Out-of-Band Application Security Testing (OAST) domain cvvr9gl9namk9u955tsgaxy3upyezhnm6.oast[.]online. OAST is often used by security teams to test if exploitable vulnerabilities exist in a web application but can similarly be used by threat actors for the same purpose [9].

Four days later, on April 22, Darktrace observed the same device, an internet-facing system believed to be a SAP device, downloading multiple executable (.exe) files from several Amazon Simple Storage Service (S3). Darktrace’s Threat Research team later found these files to be associated with the KrustyLoader malware [23][24][25].

KrustyLoader is known to be associated with the Chinese threat actor UNC5221, also known as UTA0178, which has been reported to aggressively target devices exposed to the internet [10] [14] [15]. It is an initial-stage malware which downloads and launches a second-stage payload – Sliver C2. Sliver is a similar tool to Cobalt Strike (an open-source post-exploitation toolkit). It is used for command-and-control (C2) connections [11][12]13]. After its successful download, KrustyLoader deletes itself to evade detection. It has been reported that multiple Chinese APT groups have deployed KrustyLoader on SAP Netweaver systems post-compromise [8].

The actors behind KrustyLoader have also been associated with the exploitation of zero-day vulnerabilities in other enterprise systems, including Ivanti devices [12]. Notably, in this case, one of the Amazon S3 domains observed (abode-dashboard-media.s3.ap-south-1.amazonaws[.]com ) had previously been investigated by Darktrace’s Threat Research team as part of their investigation into Ivanti Connect Secure (CS) and Policy Secure (PS) appliances.

In addition to the download of known malicious files, Darktrace also detected new IoCs, including several executable files that could not be attributed to any known malware families or previous attacks, and for which no corresponding OSINT reporting was available.

Post-CVE publication detection

Exploit Validation

Between April 27 and 29, Darktrace observed unusual activity from an SAP device on the network of a manufacturing customer in EMEA.

Figure 2: Darktrace / NETWORK’s detection of an SAP device performing a large volume of suspicious activity between April 27 and April 29.

The device was observed making DNS requests for OAST domains (e.g. aaaaaaaa.d06qqn7pu5a6u25tv9q08p5xhbjzw33ge.oast[.]online and aaaaaaaaaaa.d07j2htekalm3139uk2gowmxuhapkijtp.oast[.]pro), suggesting that a threat actor was testing for exploit validation [9].

Figure 3: Darktrace / NETWORK’s detection of a SAP device making suspicious domain name resolution requests for multiple OAST domains.

Privilege escalation tool download attempt

One day later, Darktrace observed the same device attempting to download an executable file from hxxp://23.95.123[.]5:666/xmrigCCall/s.exe (SHA-1 file hash: e007edd4688c5f94a714fee036590a11684d6a3a).

‍Darktrace / NETWORK identified the user agents Microsoft-CryptoAPI/10.0 and CertUtil URL Agent during the connections to 23.95.123[.]5. The connections were made over port 666, which is not typically used for HTTP connections.

Multiple open-source intelligence (OSINT) vendors have identified the executable file as either JuicyPotato or SweetPotato, both Windows privilege escalation tools[16][17][18][19]. The file hash and the unusual external endpoint have been associated with the Chinese APT group Gelsemium in the past, however, many threat actors are known to leverage this tool in their attacks [20] [21].

Figure 4: Darktrace’s Cyber AI Analyst’s detection of a SAP device downloading a suspicious executable file from hxxp://23.95.123[.]5:666/xmrigCCall/s.exe on April 28, 2025.

Darktrace deemed this activity highly suspicious and triggered an Enhanced Monitoring model alert, a high-priority security model designed to detect activity likely indicative of compromise. As the customer was subscribed to the Managed Threat Detection service, Darktrace’s Security Operations Centre (SOC) promptly investigated the alert and notified the customer for swift remediation. Additionally, Darktrace’s Autonomous Response capability automatically blocked connections to the suspicious IP, 23.95.123[.]5, effectively containing the compromise in its early stages.

Actions taken by Darktrace’s Autonomous Response to block connections to the suspicious external endpoint 23.95.123[.]5. This event log shows that the connections to 23.95.123[.]5 were made over a rare destination port for the HTTP protocol and that new user agents were used during the connections. — Figure 5: Actions taken by Darktrace’s Autonomous Response to block connections to the suspicious external endpoint 23.95.123[.]5. This event log shows that the connections to **23.95.123[.]5** were made over a rare destination port for the HTTP protocol and that new user agents were used during the connections.

Conclusion

The exploitation of CVE-2025-31324 to compromise SAP NetWeaver systems highlights the persistent threat posed by vulnerabilities in public-facing assets. In this case, threat actors leveraged the flaw to gain an initial foothold, followed by attempts to deploy malware linked to groups affiliated with China [8][20].

Crucially, Darktrace demonstrated its ability to detect and respond to emerging threats even before they are publicly disclosed. Six days prior to the public disclosure of CVE-2025-31324, Darktrace detected unusual activity on a device believed to be a SAP system, which ultimately represented an early detection of the CVE. This detection was made possible through Darktrace’s behavioral analysis and anomaly detection, allowing it to recognize unexpected deviations in device behavior without relying on signatures, rules or known IoCs. Combined with its Autonomous Response capability, this allowed for immediate containment of suspicious activity, giving security teams valuable time to investigate and mitigate the threat.

Credit to Signe Zaharka (Principal Cyber Analyst), Emily Megan Lim, (Senior Cyber Analyst) and Ryan Traill (Analyst Content Lead)

Appendices

List of IoCs

23.95.123[.]5:666/xmrigCCall/s.exe - URL- JuicyPotato/SweetPotato - high confidence

29274ca90e6dcf5ae4762739fcbadf01- MD5 file hash - JuicyPotato/SweetPotato - high confidence

e007edd4688c5f94a714fee036590a11684d6a3a - SHA-1 file hash - JuicyPotato/SweetPotato -high confidence

3268f269371a81dbdce8c4eedffd8817c1ec2eadec9ba4ab043cb779c2f8a5d2 - SHA-256 file hash - JuicyPotato/SweetPotato -high confidence

abode-dashboard-media.s3.ap-south-1.amazonaws[.]com/nVW2lsYsYnv58 - URL- high confidence

applr-malbbal.s3.ap-northeast-2.amazonaws[.]com/7p3ow2ZH - URL- high confidence

applr-malbbal.s3.ap-northeast-2.amazonaws[.]com/UUTICMm - URL- KrustyLoader - high confidence

beansdeals-static.s3.amazonaws[.]com/UsjKy - URL- high confidence

brandnav-cms-storage.s3.amazonaws[.]com/3S1kc - URL- KrustyLoader - high confidence

bringthenoiseappnew.s3.amazonaws[.]com/pp79zE - URL- KrustyLoader - high confidence

f662135bdd8bf792a941ea222e8a1330 - MD5 file hash- KrustyLoader - high confidence

fa645f33c0e3a98436a0161b19342f78683dbd9d - SHA-1 file hash- KrustyLoader - high confidence

1d26fff4232bc64f9ab3c2b09281d932dd6afb84a24f32d772d3f7bc23d99c60 - SHA-256 file hash- KrustyLoader - high confidence

6900e844f887321f22dd606a6f2925ef - MD5 file hash- KrustyLoader - high confidence

da23dab4851df3ef7f6e5952a2fc9a6a57ab6983 - SHA-1 file hash- KrustyLoader - high confidence

1544d9392eedf7ae4205dd45ad54ec67e5ce831d2c61875806ce4c86412a4344 - SHA-256 file hash- KrustyLoader - high confidence

83a797e5b47ce6e89440c47f6e33fa08 - MD5 file hash - high confidence

a29e8f030db8990c432020441c91e4b74d4a4e16 - SHA-1 file hash - high confidence

72afde58a1bed7697c0aa7fa8b4e3b03 - MD5 file hash- high confidence

fe931adc0531fd1cb600af0c01f307da3314c5c9 - SHA-1 file hash- high confidence

b8e56de3792dbd0f4239b54cfaad7ece3bd42affa4fbbdd7668492de548b5df8 - SHA-256 file hash- KrustyLoader - high confidence

17d65a9d8d40375b5b939b60f21eb06eb17054fc - SHA-1 file hash- KrustyLoader - high confidence

8c8681e805e0ae7a7d1a609efc000c84 - MD5 file hash- KrustyLoader - high confidence

29274ca90e6dcf5ae4762739fcbadf01 - MD5 file hash- KrustyLoader - high confidence

Darktrace Model Detections

Anomalous Connection / CertUtil Requesting Non Certificate

Anomalous Connection / CertUtil to Rare Destination

Anomalous Connection / Powershell to Rare External

Anomalous File / EXE from Rare External Location

Anomalous File / Multiple EXE from Rare External Locations

Anomalous File / Internet Facing System File Download

Anomalous File / Masqueraded File Transfer (Enhanced Monitoring)

Anomalous Server Activity / New User Agent from Internet Facing System

Compliance / CertUtil External Connection

Compromise / High Priority Tunnelling to Bin Services (Enhanced Monitoring)

Compromise / Possible Tunnelling to Bin Services

Device / Initial Attack Chain Activity (Enhanced Monitoring)

Device / Suspicious Domain

Device / Internet Facing Device with High Priority Alert

Device / Large Number of Model Alerts

Device / Large Number of Model Alerts from Critical Network Device (Enhanced Monitoring)

Device / New PowerShell User Agent

Device / New User Agent

Autonomous Response Model Alerts

Antigena / Network / External Threat / Antigena Suspicious File Block

Antigena / Network / Significant Anomaly / Antigena Controlled and Model Alert

Antigena / Network / Significant Anomaly / Antigena Enhanced Monitoring from Server Block

Antigena / Network / Significant Anomaly / Antigena Significant Server Anomaly Block

Antigena/ Network / External Threat / Antigena Suspicious File Block

Antigena/ Network / External Threat / Antigena Suspicious File Pattern of Life Block

Antigena/ Network / Significant Anomaly / Antigena Alerts Over Time Block

Antigena/ Network / Significant Anomaly / Antigena Controlled and Model Alert

Antigena/ Network / Significant Anomaly / Antigena Enhanced Monitoring from Server Block

Antigena/ Network / Significant Anomaly / Antigena Significant Server Anomaly Block

Cyber AI Analyst Incidents

Possible HTTP Command and Control

Suspicious File Download

MITRE ATT&CK Mapping

Malware - RESOURCE DEVELOPMENT - T1588.001

PowerShell - EXECUTION - T1059.001

Drive-by Compromise - INITIAL ACCESS - T1189

Ingress Tool Transfer - COMMAND AND CONTROL - T1105

Application Layer Protocol - COMMAND AND CONTROL - T1071

Exploitation of Remote Services - LATERAL MOVEMENT - T1210

Exfiltration Over Unencrypted/Obfuscated Non-C2 Protocol - EXFILTRATION - T1048.003

References

1. https://nvd.nist.gov/vuln/detail/CVE-2025-31324

2. https://www.bleepingcomputer.com/news/security/over-1-200-sap-netweaver-servers-vulnerable-to-actively-exploited-flaw/

3. https://reliaquest.com/blog/threat-spotlight-reliaquest-uncovers-vulnerability-behind-sap-netweaver-compromise/

4. https://onapsis.com/blog/active-exploitation-of-sap-vulnerability-cve-2025-31324/

5. https://www.bleepingcomputer.com/news/security/sap-fixes-suspected-netweaver-zero-day-exploited-in-attacks/

6. https://op-c.net/blog/sap-cve-2025-31324-qilin-breach/

7. https://www.forescout.com/blog/threat-analysis-sap-vulnerability-exploited-in-the-wild-by-chinese-threat-actor/

8. https://blog.eclecticiq.com/china-nexus-nation-state-actors-exploit-sap-netweaver-cve-2025-31324-to-target-critical-infrastructures

9. https://portswigger.net/burp/application-security-testing/oast

10. https://www.picussecurity.com/resource/blog/unc5221-cve-2025-22457-ivanti-connect-secure

11. https://malpedia.caad.fkie.fraunhofer.de/details/elf.krustyloader

12. https://www.broadcom.com/support/security-center/protection-bulletin/krustyloader-backdoor

13. https://labs.withsecure.com/publications/new-krustyloader-variant-dropped-via-screenconnect-exploit

14. https://blog.eclecticiq.com/china-nexus-threat-actor-actively-exploiting-ivanti-endpoint-manager-mobile-cve-2025-4428-vulnerability

15. https://thehackernews.com/2024/01/chinese-hackers-exploiting-critical-vpn.html

16. https://www.virustotal.com/gui/file/3268f269371a81dbdce8c4eedffd8817c1ec2eadec9ba4ab043cb779c2f8a5d2

17. https://bazaar.abuse.ch/sample/3268f269371a81dbdce8c4eedffd8817c1ec2eadec9ba4ab043cb779c2f8a5d2/

18. https://www.fortinet.com/content/dam/fortinet/assets/analyst-reports/report-juicypotato-hacking-tool-discovered.pdf

19. https://www.manageengine.com/log-management/correlation-rules/detecting-sweetpotato.html

20. https://unit42.paloaltonetworks.com/rare-possible-gelsemium-attack-targets-se-asia/

21. https://assets.kpmg.com/content/dam/kpmg/in/pdf/2023/10/kpmg-ctip-gelsemium-apt-31-oct-2023.pdf

22. https://securityaffairs.com/177522/hacking/experts-warn-of-a-second-wave-of-attacks-targeting-sap-netweaver-bug-cve-2025-31324.html

23. https://www.virustotal.com/gui/file/b8e56de3792dbd0f4239b54cfaad7ece3bd42affa4fbbdd7668492de548b5df8

24. https://www.virustotal.com/gui/file/1d26fff4232bc64f9ab3c2b09281d932dd6afb84a24f32d772d3f7bc23d99c60/detection

25. https://www.virustotal.com/gui/file/1544d9392eedf7ae4205dd45ad54ec67e5ce831d2c61875806ce4c86412a4344/detection

About the author

Signe Zaharka

Senior Cyber Security Analyst

Blog

June 12, 2025

Modernising UK Cyber Regulation: Implications of the Cyber Security and Resilience Bill

Two individuals sitting at a desk working on a document

The need for security and continued cyber resilience

The UK government has made national security a key priority, and the new Cyber Security and Resilience Bill (CSRB) is a direct reflection of that focus. In introducing the Bill, Secretary of State for Science, Innovation and Technology, Peter Kyle, recognised that the UK is “desperately exposed” to cyber threats—from criminal groups to hostile nation-states that are increasingly targeting the UK's digital systems and critical infrastructure^[1].

Context and timeline for the new legislation

First announced during the King’s Speech of July 2024, and elaborated in a Department for Science, Innovation and Technology (DSIT) policy statement published in April 2025, the CSRB is expected to be introduced in Parliament during the 2025-26 legislative session.

For now, organisations in the UK remain subject to the 2018 Network and Information Systems (NIS) Regulations – an EU-derived law which was drafted before today’s increasing digitisation of critical services, rise in cloud adoption and emergence of AI-powered threats.

Why modernisation is critical

Without modernisation, the Government believes UK’s infrastructure and economy risks falling behind international peers. The EU, which revised its cybersecurity regulation under the NIS2 Directive, already imposes stricter requirements on a broader set of sectors.

The urgency of the Bill is also underscored by recent high-impact incidents, including the Synnovis attack which targeted the National Health Service (NHS) suppliers and disrupted thousands of patient appointments and procedures^[2]. The Government has argued that such events highlight a systemic failure to keep pace with a rapidly evolving threat landscape^[3].

What the Bill aims to achieve

This Bill represents a decisive shift. According to the Government, it will modernise and future‑proof the UK’s cyber laws, extending oversight to areas where risk has grown but regulation has not kept pace^[4]. While the legislation builds on previous consultations and draws lessons from international frameworks like the EU’s NIS2 directive, it also aims to tailor solutions to the UK’s unique threat environment.

Importantly, the Government is framing cybersecurity not as a barrier to growth, but as a foundation for it. The policy statement emphasises that strong digital resilience will create the stability businesses need to thrive, innovate, and invest^[5]. Therefore, the goals of the Bill will not only be to enhance security but also act as an enabler to innovation and economic growth.

Recognition that AI changes cyber threats

The CSRB policy statement recognises that AI is fundamentally reshaping the threat landscape, with adversaries now leveraging AI and commercial cyber tools to exploit vulnerabilities in critical infrastructure and supply chains. Indeed, the NCSC has recently assessed that AI will almost certainly lead to “an increase in the frequency and intensity of cyber threats”^[6]. Accordingly, the policy statement insists that the UK’s regulatory framework “must keep pace and provide flexibility to respond to future threats as and when they emerge”^[7].

To address the threat, the Bill signals new obligations for MSPs and data centres, timely incident reporting and dynamic guidance that can be refreshed without fresh primary legislation, making it essential for firms to follow best practices.

What might change in day-to-day practice?

New organisations in scope of regulation

Under the existing Network and Information Systems (NIS) Regulations^[8], the UK already supervises operators in five critical sectors—energy, transport, drinking water, health (Operators of Essential Services, OES) and digital infrastructure (Relevant Digital Service Providers, RDSPs).

The Cyber Security and Resilience Bill retains this foundation and adds Managed Service Providers (MSPs) and data centres to the scope of regulation to “better recognise the increasing reliance on digital services and the vulnerabilities posed by supply chains”^[9]. It also grants the Secretary of State for Science, Innovation and Technology the power to add new sectors or sub‑sectors via secondary legislation, following consultation with Parliament and industry.

Managed service providers (MSPs)

MSPs occupy a central position within the UK’s enterprise information‑technology infrastructure. Because they remotely run or monitor clients’ systems, networks and data, they hold privileged, often continuous access to multiple environments. This foothold makes them an attractive target for malicious actors.

The Bill aims to bring MSPs in scope of regulation by making them subject to the same duties as those placed on firms that provide digital services under the 2018 NIS Regulations. By doing so, the Bill seeks to raise baseline security across thousands of customer environments and to provide regulators with better visibility of supply‑chain risk.

The proposed definition for MSPs is a service which:

Is provided to another organisation
Relies on the use of network and information systems to deliver the service
Relates to ongoing management support, active administration and/or monitoring of AI systems, IT infrastructure, applications, and/or IT networks, including for the purpose of activities relating to cyber security.
Involves a network connection and/or access to the customer’s network and information systems.

Data centres

Building on the September 2024 designation of data centres as critical national infrastructure, the CSRB will fold data infrastructure into the NIS-style regime by naming it an “relevant sector" and data centres as “essential service”^[10].

About 182 colocation facilities run by 64 operators will therefore come under statutory duties to notify the regulator, maintain proportionate CAF-aligned controls and report significant incidents, regardless of who owns them or what workloads they host.

New requirements for regulated organisations

Incident reporting processes

There could be stricter timelines or broader definitions of what counts as a reportable incident. This might nudge organisations to formalise detection, triage, and escalation procedures.

The Government is proposing to introduce a new two-stage incident reporting process. This would include an initial notification which would be submitted within 24 hours of becoming aware of a significant incident, followed by a full incident report which should be submitted within 72 hours of the same.

Supply chain assurance requirements

Supply chains for the UK's most critical services are becoming increasingly complex and present new and serious vulnerabilities for cyber-attacks. The recent Synnovis ransomware attacks on the NHS^[11] exemplify the danger posed by attacks against the supply chains of important services and organisations. This is concerning when reflecting on the latest Cyber Security Breaches survey conducted by DSIT, which highlights that fewer than 25% of large businesses review their supply chain risks^[12].

Despite these risks, the UK’s legacy cybersecurity regulatory regime does not explicitly cover supply chain risk management. The UK instead relies on supporting and non-statutory guidance to close this gap, such as the NCSC’s Cyber Assessment Framework (CAF)^[13].

The CSRB policy statement acts on this regulatory shortcoming and recognises that “a single supplier’s disruption can have far-reaching impacts on the delivery of essential or digital services”^[14].

To address this, the Bill would make in-scope organisations (OES and RDPS) directly accountable for the cybersecurity of their supply chains. Secondary legislation would spell out these duties in detail, ensuring that OES and RDSPs systematically assess and mitigate third-party cyber risks.

Updated and strengthened security requirements

By placing the CAF into a firmer footing and backing it with a statutory Code of Practice, the Government is setting clearer expectations about government expectations on technical standards and methods organisations will need to follow to prove their resilience.

How Darktrace can help support affected organizations

Demonstrate resilience

Darktrace’s Self-Learning AI^TM continuously monitors your digital estate across cloud, network, OT, email, and endpoint to detect, investigate, and autonomously respond to emerging threats in real time. This persistent visibility and defense posture helps organizations demonstrate cyber resilience to regulators with confidence.

Streamline incident reporting and compliance

Darktrace surfaces clear alerts and automated investigation reports, complete with timeline views and root cause analysis. These insights reduce the time and complexity of regulatory incident reporting and support internal compliance workflows with auditable, AI-generated evidence.

Improve supply chain visibility

With full visibility across connected systems and third-party activity, Darktrace detects early indicators of lateral movement, account compromise, and unusual behavior stemming from vendor or partner access, reducing the risk of supply chain-originated cyber-attacks.

Ensure MSPs can meet new standards

For managed service providers, Darktrace offers native multi-tenant support and autonomous threat response that can be embedded directly into customer environments. This ensures consistent, scalable security standards across clients—helping MSPs address increasing regulatory obligations.

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