Events in the Middle East are a sharp reminder that geopolitical instability can quickly disrupt supply chains and escalate cyber risks.

As we note in our 2026 Commercial, Technology & Regulatory Handbook:

The robustness of supply chains continues to be regularly tested. The scale of cloud reliance and issues with cybersecurity results mean a risk of serious loss when things go wrong, so businesses must be prepared contractually and operationally.

What the NCSC says about the conflict in the Middle East

Jonathon Ellison, director for national resilience at the National Cyber Security Centre (NCSC) said this week:

In light of rapidly evolving events in the Middle East, it is critical that all UK organisations remain alert to the potential risk of cyber compromise.

The NCSC's current assessment is that there is likely "no current significant change" in the direct cybersecurity threat from Iran. However, this could shift quickly. As the NCSC notes, there is "almost certainly a heightened risk of indirect cyber threat" for businesses based in the Middle East or who have supply chains there.

The NCSC has published recommended actions for businesses, which you can access here.

A reminder of your legal obligations

UK cybersecurity law already imposes substantial duties on businesses: assessing and managing cyber risk; implementing appropriate technical and organisational measures, such as under the UK GDPR; maintaining operational resilience; and notifying regulators of material incidents. Where relevant, you must also notify affected individuals. 

And these obligations are growing. The Cyber Security and Resilience Bill, when enacted, will expand the NIS framework considerably. More critical suppliers and managed service providers will fall within scope. Regulators will gain stronger enforcement powers and incident reporting timelines will tighten (see here for more details). 

And there's more: if your UK business falls within NIS2 because you operate in the EU, you must meet that regime too.

The upshot is that cybersecurity is not a box-ticking exercise. It requires ongoing attention at board level; robust contractual protections with suppliers and service providers; and a proactive approach to incident preparedness.

What you should do now

In light of current events, we recommend that businesses take the following steps in addition to reviewing their IT posture:

• review your supply chain exposure: identify any suppliers, partners, or cloud providers with operations or infrastructure in the Middle East. Assess their security posture and confirm contractual protections are in place.
• revisit your incident response plan: ensure your business has a tested plan for responding to cyber incidents, including clear escalation routes, regulatory notification procedures, and communication protocols.
• brief your board: cyber risk is a governance issue. Ensure directors understand the current threat landscape and the organisation's state of readiness.
• monitor NCSC guidance: the threat picture may evolve rapidly. Review their published guidance regularly.

If you need any help on the above, please get in touch with a member of the team.