Ofgem, GEMA and the Cyber Security and Resilience Bill

Ofgem does not regulate energy cyber security under the Cyber Security and Resilience Bill (CSRB) alone. In Great Britain, the Energy Secretary and GEMA act jointly for electricity and most gas, the Energy Secretary alone covers oil, and the Department of Finance covers Northern Ireland.

Updated 2 November 2026Precursor Security
Where this stands

The Bill is not yet law. Regulation and section references come from the Bill as brought from the Commons (HL Bill 32). The Lords has since amended the Bill, so numbering and detail may change in the final Act. This guide is general information, not legal advice.

Who actually regulates energy

Schedule 1 of the NIS Regulations 2018 splits energy regulation by subsector and by nation.

Subsector Great Britain Northern Ireland
Electricity Energy Secretary and GEMA, jointly Department of Finance
Gas Energy Secretary and GEMA jointly, except specified services for the Energy Secretary alone Department of Finance
Oil Energy Secretary Department of Finance

GEMA is the Gas and Electricity Markets Authority, and Ofgem is the office that supports it. The Cyber Security and Resilience Bill (CSRB) does not change this basic split in the text we reviewed.

Main thresholds

Service Threshold in Great Britain
Electricity supply More than 250,000 final customers, or a supplier also generating with 2 GW or more of capacity
Electricity transmission and distribution Could disrupt supply to more than 250,000 customers
Interconnector 1 GW or more capacity
Gas supply More than 250,000 final customers
Gas storage and LNG Can input over 20 million cubic metres a day
Load control (added by the Bill) 300 MW or more of potential electrical control

Northern Ireland thresholds are often lower or based on licences. See our devolved nations guide.

The new load control duty

Section 6 of the Bill adds load control to the electricity paragraph of Schedule 2. It counts relevant energy smart appliances you control by signal, namely EV chargers, EVs, electric heating, batteries and virtual power plants. An intermediary authorised to adjust the signals can also count as a load controller. Our reading is that the electricity authorities would oversee this, subject to the final Act and any further detail.

What is published, and what isn't

Item Status when checked
Ofgem NIS guidance for downstream gas and electricity Published, updated 14 January 2026
Security assurance guidance Published April 2025, as referred to in Ofgem's guidance
Oil subsector guidance Check with the Department for Energy Security and Net Zero
Load controller guidance Not found
Charging scheme under the Bill Not found

Checked 2 November 2026. Regulators may publish more once the Bill passes, so check their own pages.

What changes for existing energy operators

Existing operators of essential services will need to prepare for the shorter reporting timetable: an initial notification within 24 hours and full notification within 72 hours, both from first awareness of a reportable incident. They should also expect closer scrutiny of supply chains through the critical supplier power, and possible cost recovery through a charging scheme.

What to do

  1. Confirm which authority covers each licensed activity.
  2. Re-check any growth that could cross a threshold.
  3. If you manage smart appliances, calculate potential electrical control using manufacturer ratings.
  4. Update incident plans to reflect the new timelines.

Sources

Frequently asked questions

Partly. GEMA, which Ofgem supports, acts jointly with the Secretary of State for Energy Security and Net Zero for electricity and most gas in Great Britain. It has no role for oil.

Ofgem publishes NIS guidance for downstream gas and electricity operators, updated in January 2026, along with security assurance guidance. Check that guidance for its current CAF expectations.

The Bill adds load control to the electricity paragraph of Schedule 2. On our reading that points to the electricity authorities, but check the final Act and implementing material.

The Department of Finance is the competent authority for the Northern Ireland energy subsectors listed in Schedule 1.

Related

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