Ransomware payment restrictions are coming. Your resilience plan needs to assume you can’t pay.

• by Olivia Lawlor-Blackburn
• Advent IM Blog

The UK is moving towards a tougher stance on ransomware payments, particularly for the public sector and regulated critical national infrastructure. Policy proposals have included a targeted ban for those sectors, alongside measures that increase incident reporting and introduce a notify-to-pay approach for organisations outside the ban. 

This shift matters because it changes the shape of an incident. Many organisations have historically treated ransom payment as an ugly last resort, the ‘break glass’ option when restoration timelines and operational pressure collide. Policymakers are trying to remove that option, at least for the parts of the economy where disruption can become a public safety issue. 

Why the UK would do this 

Ransomware is a market. Payments sustain it, professionalise it, and fund the next round of attacks. A ban aims to cut the demand side, not because it makes crime vanish, but because it makes the model less reliable for the attacker. 

The UK approach is also linked to visibility. If more incidents are reported, government and law enforcement can build better intelligence, spot patterns across supply chains, and support victims more effectively. 

Why it’s controversial 

The hard part is the collision between policy intent and operational reality. 

If an organisation is running a service where downtime creates immediate harm, then ‘do not pay’ is not just a moral stance, it’s a continuity requirement. Critics have warned that a blanket ban could force organisations into impossible choices during live incidents, potentially increasing disruption if resilience is not strong enough. 

That’s why you see discussion of national security exemptions. In certain circumstances, the state may need options that aren’t appropriate for day-to-day public bodies or regulated operators. Whether you agree with that or not, the signal is clear: ransomware is being treated as a national security and resilience problem, not only a cyber hygiene problem. 

What stays true, regardless of what Parliament finally does 

Even today, the NCSC and UK law enforcement do not encourage paying ransoms. The UK government’s position is that ransomware payments perpetuate the threat and do not guarantee recovery. 

There is also a legal sting in the tail: even if paying a ransom is not automatically illegal in itself, payments can create serious exposure if money ends up with sanctioned individuals or entities. This is one reason government has talked about providing advice and support where organisations notify intent to pay. 

So the question for leadership is not ‘would we pay?’ It’s ‘can we keep operating if we can’t?’ 

The GRC implications people miss 

Ransomware response is often treated as a technical procedure. In practice, it’s a governance stress test. 

During a real incident, the failure mode is rarely ‘we didn’t have a policy’. It’s ‘we didn’t have a decision’. Decision rights get fuzzy, risk appetite gets rewritten on the fly, and everyone is simultaneously trying to be fast, lawful, ethical, and publicly defensible. 

If payment restrictions tighten, the governance bar rises. You will need to be able to demonstrate, in plain English, that you designed your services to tolerate disruption (not just prevent it), you can restore within acceptable timeframes without relying on criminals, you have rehearsed leadership decisions including communications and supplier coordination, you understand your legal and regulatory obligations including sanctions risk, and you can produce evidence quickly for regulators, auditors, boards, and sometimes the public. 

A practical way to ‘ban-proof’ your ransomware posture 

This isn’t about buying a magic tool. It’s about removing single points of failure and proving recoverability. 

Start with these four areas: 

Recoverability you can prove, not hope for: Backups are only ‘backups’ if they restore. The operational question is simple: what is our tested restore time for the services that matter most, and can we run in degraded mode while we recover? 

Containment that limits blast radius: Attackers love flat networks, shared admin credentials, and over-permissioned service accounts. Segmentation, identity controls, and hardening are still the cheapest way to stop an incident becoming an organisational shutdown. 

Leadership rehearsal: Run an exercise that forces real trade-offs: patient safety vs system isolation, reputational damage vs transparency, operational continuity vs legal constraints. Include legal, comms, ops, HR, insurers, and critical suppliers, because ransomware is a business crisis, not an IT ticket. 

Supplier and third-party reality: Many critical services are delivered through an ecosystem. Your recovery capability is only as good as the slowest or least prepared supplier you depend on. Incident plans should assume supplier compromise, not treat it as an edge case. 

Where this lands for CNI, government and defence supply chains 

If you’re a public body, a regulated operator, or a supplier keeping those organisations running, treat this as a coming-of-age moment for resilience. Expect more scrutiny, faster reporting expectations, and greater emphasis on evidence of operational recovery capability, not just security controls. 

And if you’re in the defence and government supplier world, don’t miss the meta-point: the exemptions conversation tells you the state expects ransomware to be used for leverage, disruption, and strategic effect. That should change how seriously we take continuity planning and supplier assurance. 

How Advent IM can help (practically, not performatively) 

We typically support organisations here in three ways: 

Ransomware readiness and resilience reviews focused on recoverability, decision rights, and evidence. 

Incident response governance and leadership tabletop exercises that test the whole system. 

Supplier assurance and Secure by Design work so dependencies don’t become the downfall. 

If you’d like, this can be turned into a one-page Board Briefing and a checklist-style ‘Ransomware Ban-Proofing Pack’ suitable for a risk committee paper, written in plain UK English and mapped to practical actions. 

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Sources 

UK Home Office: Government response to ransomware legislative proposals (reducing payments and increasing incident reporting): https://www.gov.uk/government/consultations/ransomware-proposals-to-increase-incident-reporting-and-reduce-payments-to-criminals/outcome/government-response-to-ransomware-legislative-proposals-reducing-payments-to-cyber-criminals-and-increasing-incident-reporting-accessible 

UK Government: Financial sanctions guidance for ransomware: https://www.gov.uk/government/publications/financial-sanctions-guidance-for-ransomware/financial-sanctions-guidance-for-ransomware 

NCSC: Ransomware guidance: https://www.ncsc.gov.uk/ransomware/home 

Financial Times coverage (context on policy trade-offs): https://www.ft.com/