Recommendation 12

We note the Government’s concerns about the complexity of the regulatory landscape and the difficulty of imposing a more uniform regulatory regime. We agree with the NIC, however, that resilience cannot be left entirely to the market. Indeed, our survey found that only a third of responding organisations planned more than a decade in advance for the effects of climate change. We suggest that the Government undertakes more detailed work on international comparators in relation to regulatory regimes. In addition, in line with the NIC’s 2020 report on resilience, we recommend that: • The Government should publish a full set of resilience standards every five years, for the sectors under the NIC’s purview at a minimum (energy, water, digital, road and rail services); it should also examine how these could apply to other CNI sectors. • CNI regulators should require their operators to develop long-term resilience strategies; • Recognising that CNI should be tested regularly against a wide range of stresses, including interdependencies, regulators should oversee a programme of stress testing against a range of risks that might affect critical services; and • These resilience standards and stress tests should specifically address the effects of climate change in the short, medium and long term, to ensure that CNI operators are planning for a range of potential scenarios. 52 Readiness for storms ahead? Critical national infrastructure in an age of climate change Ministerial oversight and cross-Government action