Recommendations & Conclusions
28 items
1
Conclusion
1st Report - Subsea telecommunications …
Acknowledged
The UK’s strategic reliance on subsea cables will likely continue for the foreseeable future. The cable industry provides a commendable and commercially efficient repair service, which ensures good resilience against moderate damage. We do not believe there is an imminent threat to the UK’s national connectivity. (Conclusion, Paragraph 14) Threat …
Government response. The government agrees on the importance of updated risk scenarios and commits to considering how to best update reasonable worst-case scenarios within national risk assessments to reflect the possibility of coordinated sabotage on subsea and terrestrial internet infrastructure.
Cabinet Office
2
Recommendation
1st Report - Subsea telecommunications …
Accepted
The Government’s resilience assessments must take greater account of the worsening security environment over the next 5–10 years. The National Security Strategy and Strategic Defence Review set out serious preparations for future crises. However, the Minister for Data Protection and Telecoms suggested that exploring the risks of a co-ordinated attack …
Government response. The government agrees to strengthen security, with DSIT writing to operators to request emergency 'good enough' repair plans within 12 months and defining standards. They are also reviewing legislation and will explore similar exercises with European counterparts.
Cabinet Office
3
Conclusion
1st Report - Subsea telecommunications …
Accepted
We also found sceptical views in some parts of the cable industry about the risks of co-ordinated attacks. We agree that resilience across the sector is generally robust, major disruption is unlikely, and hype is unhelpful. But we caution against adopting ‘business as usual’ industry views to determine national security …
Government response. The government agrees with the underlying sentiment, committing to ensuring subsea cable infrastructure is geographically diverse and working with industry and Crown Estates to secure space for future routes to support long-term resilience.
Cabinet Office
4
Recommendation
1st Report - Subsea telecommunications …
Accepted
The Government should update its public and private risk scenarios to cover extensive co-ordinated sabotage to subsea and terrestrial internet infrastructure, including onward connections to Europe. (Recommendation, Paragraph 39) System vulnerabilities
Government response. The government agrees to develop more detailed technical plans for managing cable systems, engage with operators, conduct sector-specific technical impact assessments, and use these findings to inform additional contingency plans and the National Emergency Plans framework for Subsea Cables.
Cabinet Office
5
Recommendation
1st Report - Subsea telecommunications …
Not Addressed
Many cable landing stations are vulnerable to attack. The Government and operators must take the risk of state-backed sabotage seriously, including against targets in Europe. (Conclusion, Paragraph 47)
Government response. The government's response discusses the need for a UK-based and UK-flagged repair ship, which does not address the committee's recommendation about the vulnerability of cable landing stations or taking the risk of state-backed sabotage seriously.
Cabinet Office
6
Recommendation
1st Report - Subsea telecommunications …
Deferred
The National Protective Security Authority (NPSA) and National Cyber Security Centre should require all UK landing stations to be target-hardened to sufficient levels to deter state-backed sabotage. They should require landing station operators to develop within 12 months an emergency ‘good enough’ repair plan to recover from co-ordinated attacks. The …
Government response. The government requires more time to consider the recommendation, stating the MoD will work with other departments and industry to evaluate commercial cable repair capacity and determine if intervention is needed.
Cabinet Office
7
Recommendation
1st Report - Subsea telecommunications …
Accepted
To help mitigate risks around the clustering of high value targets, the Government should encourage subsea cable providers to connect to landing stations, terrestrial routes and data centres outside high-concentration points. (Recommendation, Paragraph 49)
Government response. The government agrees with the recommendation and will accelerate work with Lead Government Departments on technical impact assessments to help critical sectors prepare for subsea cable disruption, with oversight from the Cabinet Office’s ‘Undersea Infrastructure Security Oversight Board’.
Cabinet Office
8
Conclusion
1st Report - Subsea telecommunications …
Not Addressed
The Government’s resilience concept focuses too much on ‘having lots of cables’. This pays insufficient attention to the network’s actual capacity to absorb shocks and does not account for onshore vulnerabilities and long-term trends towards a more brittle system. There is also limited understanding of much damage the system can …
Government response. The government's response addresses emergency services' business continuity plans and their reliance on foreign internet servers, which does not engage with the committee's conclusion about the government's overall resilience concept regarding network capacity, shocks, and onshore vulnerabilities.
Cabinet Office
9
Recommendation
1st Report - Subsea telecommunications …
Not Addressed
The Government’s resilience plans should focus in more detail on the level of immediately available capacity in the cable system during a security crisis. The Department for Science, Innovation and Technology should request operators to provide regular updates on the scale and type of data each cable carries, short notice …
Government response. The government's response discusses the National Security Act 2023 and reviewing legislation related to subsea cable sabotage, which does not address the recommendation about focusing on cable system capacity, rerouting data, or developing contingency plans for the Channel Tunnel.
Cabinet Office
10
Conclusion
1st Report - Subsea telecommunications …
Not Addressed
The UK needs more confidence in access to cable repair vessels: the current fleet is ageing, and erstwhile UK businesses have been acquired by foreign entities. (Conclusion, Paragraph 71)
Government response. The government's response discusses UNCLOS and legal aspects of countering suspicious vessels, explicitly stating it does not accept reliance on piracy provisions or publishing a legal opinion, thereby failing to address the concern about access to cable repair vessels.
Cabinet Office
11
Recommendation
1st Report - Subsea telecommunications …
Not Addressed
The Government should acquire a genuinely sovereign cable repair ship by 2030. This could be leased to industry on favourable terms during peacetime and made available for Government use in a crisis. The Government should set out a timetable for this in response to this Report. (Recommendation, Paragraph 72)
Government response. The government's response discusses existing international cooperation on cable breaks and vessel behaviour but does not address the recommendation to acquire a sovereign cable repair ship by 2030 or set a timetable for it.
Cabinet Office
12
Recommendation
1st Report - Subsea telecommunications …
Not Addressed
The Royal Navy should establish a cadre of reservists and serving personnel to learn cable repair skills on commercial repair vessels. These could be called on in periods of heightened tension. (Recommendation, Paragraph 75) Moderate and catastrophic impacts
Government response. The government states it agrees with the recommendation, but the subsequent text discusses sensor and monitoring technologies and their integration with the Royal Navy, completely failing to address the call for training personnel in cable repair skills.
Cabinet Office
13
Recommendation
1st Report - Subsea telecommunications …
Not Addressed
The UK has particular vulnerabilities around outlying islands, the financial sector and military communications cables. These should be a key focus for contingency planning. (Conclusion, Paragraph 81)
Government response. The government partially agrees but primarily discusses military deterrence, reviewing concepts, and leveraging alliances, without detailing how specific vulnerabilities around outlying islands, the financial sector, and military communications cables will be a key focus for contingency planning.
Cabinet Office
14
Conclusion
1st Report - Subsea telecommunications …
Not Addressed
The impacts of catastrophic disruption from a co-ordinated attack remain speculative, but are almost certainly highly damaging. We estimate they would include payment and supply chain failures, some degraded communications, overstretched emergency responses, and unexpected cascading issues—all at a time of crisis. We are not convinced there are currently adequate …
Government response. The government's response discusses escorting ships, investing in underwater drones, and the Royal Navy's exercises, which does not address the committee's conclusion regarding the impacts of catastrophic disruption or the adequacy of sector-by-sector assessments of reliance on subsea cables.
Cabinet Office
15
Recommendation
1st Report - Subsea telecommunications …
Accepted in Part
The Department for Science, Innovation and Technology should ensure all lead departments have detailed sector-by-sector technical impact studies on areas most likely to be affected and response plans—notably finance, maritime and air traffic, communications, defence and supply chains including food and fuel. We suggest such assessments are handled securely given …
Government response. The government partially agrees on the importance of a centralised coordination function, establishing an Undersea Infrastructure Security Oversight Board chaired by the Cabinet Office for strategic direction, but does not adopt the specific suggestion to expand SIRG or set up …
Cabinet Office
16
Recommendation
1st Report - Subsea telecommunications …
Not Addressed
Emergency services should ensure their business continuity plans highlight any areas of critical reliance on foreign internet servers, and account for temporary internet disruption in the event of a security crisis. (Recommendation, Paragraph 100) Legal Responses
Government response. The government's response discusses exploring cable protection zones and engaging with European partners on maritime infrastructure protection, which does not address the recommendation regarding emergency services' business continuity plans for reliance on foreign internet servers or internet disruption.
Cabinet Office
17
Recommendation
1st Report - Subsea telecommunications …
Accepted
The legal provisions for responding to malicious cable damage are weak. It is encouraging that the Government has identified the forthcoming Defence Readiness Bill as a potential legislative vehicle to implement changes. We would like to emphasise the urgency of making progress internationally too: legal developments can be slow, and …
Government response. The government accepts the recommendation, agreeing that current legislation for non-foreign power sabotage of cables is weak. It is conducting a comprehensive review of legislation related to subsea cable infrastructure to ensure robust routes for prosecuting private actors.
Cabinet Office
18
Recommendation
1st Report - Subsea telecommunications …
Deferred
The Government’s review of legislation must pay particular attention to strong deterrents, such as major fines and criminal liability, that can be applied to private actors suspected of working for or on behalf of foreign states. (Recommendation, Paragraph 114)
Government response. The government agrees with the recommendation and is closely examining the issue of deterrents, such as major fines and criminal liability for private actors, as part of a comprehensive review of legislation relating to subsea cable infrastructure.
Cabinet Office
19
Recommendation
1st Report - Subsea telecommunications …
Rejected
The Government should explore new options for taking a more robust approach to interdicting suspicious vessels—for example applying piracy provisions to cables that land in the UK or seeking a limited extension of domestic criminal law jurisdiction. It should commission a legal opinion on options and risks, and publish this …
Government response. The government partially agrees but explicitly rejects applying piracy provisions to cables or commissioning an external legal opinion on this issue, citing the importance of consistency with UNCLOS, international partner views, and the risk of reciprocal action. It states options …
Cabinet Office
20
Recommendation
1st Report - Subsea telecommunications …
Accepted in Part
The Foreign, Commonwealth and Development Office and the Department for Business and Trade should apply diplomatic and economic pressure to press for adequate investigations from flag states and states where vessels suspected of cable damage enter port. The Government should also work with partners, particularly the International Maritime Organization, to …
Government response. The government states it frequently uses diplomatic levers to ensure investigations into cable breaks. It notes existing IMO work on data sharing and mechanisms for reporting vessel behaviour, but states there is a limit to the utility of port inspections …
Cabinet Office
21
Recommendation
1st Report - Subsea telecommunications …
Accepted
The Government should support the subsea cable industry in rolling out more extensive cable monitoring technology and should explore incentives to encourage such investment. This could include Government commitments to make better use of existing measures and data—for example more proactive identification and investigation of vessels switching off Automatic Identification …
Government response. The government agrees to support the subsea cable industry in rolling out monitoring technology and is already engaged in cross-government cooperation, including commercial relationships and partnerships with the Royal Navy. It will explore better use of existing data, including AIS, …
Cabinet Office
22
Recommendation
1st Report - Subsea telecommunications …
Accepted in Part
The UK’s military deterrence concepts are too timid. They need to place greater emphasis on prevention and punitive consequences that go beyond private or public attribution. Otherwise, aggressors that are content with ‘implausible deniability’ can cause damage with minimal risk to themselves. The Government should work with NATO to ensure …
Government response. The government partially agrees, stating deterrence concepts are under constant review and leveraging NATO. They acknowledge the importance of effective data sharing, which remains a firm requirement in existing programmes, but do not commit to designing new schemes with NATO …
Cabinet Office
23
Conclusion
1st Report - Subsea telecommunications …
Accepted in Part
In a heightened threat scenario, we are uncertain about the Royal Navy’s ability to protect vulnerable cable regions and escort repair ships without undermining commitments to other NATO tasks. We admire the Minister for Armed Forces’ optimism that the problem can be solved with Atlantic Bastion’s future set of autonomous …
Government response. The government partially agreed with the Committee's concerns, stating it is investing in new capabilities such as underwater drones, autonomous sensors, and new ships under the 'Atlantic Bastion' concept to augment the Royal Navy's ability to protect vulnerable cable regions. …
Cabinet Office
24
Recommendation
1st Report - Subsea telecommunications …
Accepted in Part
The Ministry of Defence should work with international partners to ensure there are viable plans to escort cable ships without degrading wider NATO taskings. This plan could usefully include heightened surveillance of suspicious vessel activity, rules of engagement enabling a low threshold for physical interdiction of civilian and autonomous vessels, …
Government response. The government partially agrees, stating escorting ships is an important task and rules of engagement are routinely reviewed. They are investing in new capabilities like underwater drones and the ‘Atlantic Bastion’ concept. They also state the Royal Navy already conducts …
Cabinet Office
25
Conclusion
1st Report - Subsea telecommunications …
Accepted in Part
We commend the Government’s efforts to improve co-ordination, particularly the establishment of the Subsea Infrastructure Response Group and Subsea Communications Cables Industry Group. We accept that changing governance structures for the sake of it is not helpful. Equally, however, there is evidence that improvements to oversight and co- ordination would …
Government response. The government partially agreed, acknowledging the need for improved coordination but declining to expand the SIRG. Instead, it stated that it has established an Undersea Infrastructure Security (UIS) Oversight Board, chaired by the Cabinet Office, to provide a senior-level, cross-government …
Cabinet Office
26
Recommendation
1st Report - Subsea telecommunications …
Accepted in Part
The Government should seek to provide a joined-up subsea cables function providing a centralised point of contact for industry and international partners. This body should co-ordinate, not duplicate, cross-government work—bringing together departments and agencies covering subsea infrastructure operations, policy, security, resilience and contingency planning. In the first instance this could …
Government response. The government partially agrees, accepting the importance of a centralised function but rejecting the upgrade of SIRG and a new inter-ministerial group. They state an Undersea Infrastructure Security Oversight Board has been established to provide a joined-up function and ministerial …
Cabinet Office
27
Recommendation
1st Report - Subsea telecommunications …
Deferred
We support the Crown Estate’s ambitions to improve long-term spatial planning via the Marine Delivery Route Map. We urge those involved to ensure that plans prioritise a diversity of cable routes to avoid creating areas of concentrated targets. (Conclusion, Paragraph 168)
Government response. The government agrees with exploring cable protection zones and is considering existing powers as part of a comprehensive legislative review. They will factor identified areas of cable concentration into their assessment and are engaging with international partners on maritime infrastructure …
Cabinet Office
28
Recommendation
1st Report - Subsea telecommunications …
Deferred
The Government should further explore cable protection zones for critical areas of cable concentration, policed by early warning indicators and heightened monitoring and response capabilities. This would require close co-operation with European partners, given the need to manage other maritime activities proportionately. (Recommendation, Paragraph 169) 67
Government response. The government agrees to further explore cable protection zones, noting potential utility but also jurisdiction limitations and challenges in congested marine environments. They are considering existing powers as part of a legislative review and are engaging with international partners while …
Cabinet Office