UK Government Announces New Laws For Submarine Cable Protection

On 29 May 2026, The Baroness Lloyd of Effra CBE (Parliamentary Under-Secretary of State (Minister for Digital Economy)) announced the UK government's plan to introduce tougher laws protecting submarine communications cables.

Submarine communications cables are the fibre-optic cables laid on the ocean floor that carry the vast majority (over 99%) of international data traffic. They underpin international connectivity, economic growth and national security. Damage and disruption to submarine cables therefore has severe consequences and protection of this critical infrastructure has become a strategic priority for governments and industry across the world.

The UK government’s proposals, which will be subject to consultation and set out in a white paper later this year (being an official policy document that outlines the government's proposals for future legislation), rest on three pillars: resilience through growth, deterrence, and security.

There are three key elements to the proposal:

1. Implementing new security obligations for cable owners and operators, requiring them to prevent, detect and respond to security compromises in a consistent and timely manner.
2. Replacing the current, 140-year-old, legislation on damage to submarine cables with a modern criminal framework that imposes tougher fines and prison sentences on vessel owners and operators that intentionally or recklessly damage submarine cables.
3. Providing new emergency powers to allow government to direct businesses to protect cables during major incidents.

Notably, the announcement also referred to:

• The UK government’s formal endorsement of the European Subsea Cables Association’s new Fishing Liaison Guidelines (which provide a blueprint for safe coexistence and risk reduction between the submarine cable and fishing industries and addresses accidental cable faults caused by fishing equipment and dragged anchors).
• Detailed market engagement being carried out by the UK government to retain UK-based, UK flagged sovereign repair capability (i.e. UK dedicated cable repair ships) to improve cable repair times in UK waters.
• Work being undertaken by the National Protective Security Authority and the National Cyber Security Centre to deliver detailed, up-to-date physical and cyber-security guidance for cable landing station operators.
• The newly expanded National Wealth Fund as a vehicle that the UK government intends to use to upgrade and deploy critical submarine infrastructure.

Our Thoughts

The announcement comes at a time of intense focus and reporting on the security of submarine cable assets. The following day, AUKUS (the UK, US and Australian trilateral security partnership) announced new drone capability to protect submarine cables. There have also been recent reports of covert operations over cables in UK waters by Russian submarines, Iran’s plans to charge cable owners for submarine cables that traverse the Strait of Hormuz and cable breaks in the Red Sea linked to Houthi aggression. This focus is perhaps unsurprising given the geopolitical backdrop and criticality of submarine systems in supporting international connectivity and economic growth (and forming an essential part of the AI infrastructure currently experiencing a global wave of investment).

On the announcement itself, while the specific details will land in the white paper later this year, it already raises some interesting questions for submarine cable owners and operators, particularly in relation to the new security obligations (that will be based on the UK’s Telecommunications Security Act 2021 (“TSA”) with which some UK operators will already be familiar). Key points to consider include:

• Consortium Systems: Cable systems often have multiple owners (who are often from a range of different jurisdictions) operating as a consortium. Cable consortia will need to consider how responsibility for compliance is allocated, how compliance remediation costs are shared and where liability for regulatory penalties should land (especially if the new law mirrors the headline TSA penalties of 10% of annual turnover and £100,000 per day for continuing breaches). The Joint Build, C&M, SPV or equivalent consortia agreements will need to be amended to reflect the agreed allocation of responsibility and risk for each system.
• Flow Downs: New security obligations will very likely need to be flowed down to other entities in the cable’s ecosystem (e.g. landing providers, equipment suppliers, NOC providers, maintenance providers etc.). This may either be because those parties are, in practice, operationally responsible for security of the cable and associated infrastructure, or because the new laws mandate that certain obligations are flowed down (for example, the TSA requires certain tiers of network operators to contractually flow down specific measures to their suppliers).
• Compliance Roadmap: Cable owners will need to establish a compliance roadmap for their systems, including mapping project documents and, assuming some level of flow down is required, carrying out a contract remediation exercise to: (1) assess the gaps between their current project contracts and the new obligations, and (2) renegotiate any non-compliant contracts to align with the new rules. Given the 25+ year system design life of most modern cables, this will require reopening contracts which may have been agreed some time ago.
• Equivalent Laws: Given the global importance of submarine cables, many other countries are adopting, or have adopted, similar measures. The EU has adopted an EU Action Plan on Cable Security (a strategic framework to protect submarine cables) and is proposing an extension to NIS2 (the EU’s second Network and Information Systems Directive) to bring more submarine cable owners into its scope. In the US, the Strategic Subsea Cable Act and Undersea Cable Control Act are working through the legislative process. It will be interesting to see whether the UK’s rules go further, particularly in imposing positive security obligations and emergency powers.
• Standardisation: Linked to the previous point on equivalent laws, submarine cable systems are, by their nature, multijurisdictional assets and it is necessary (and efficient) to deploy standardised measures and obligations across each landing and the system (so far as possible). Especially so for consortium systems. Ultimately, whichever laws set the highest standard may end up being the benchmark for the relevant system (or potentially systems more generally), in a similar way as with global privacy standards following implementation of the GDPR. The need for international cooperation and harmonised standards, is (as with many other sectors) ever present but difficult to achieve in practice. This will likely continue to be an issue as other countries follow suit and implement similar measures. It will be important to ensure that inconsistencies do not eventuate where submarine cable systems connect countries with differing regimes.
• Resource Availability: The new obligations may necessitate procurement of additional maintenance capability by cable owners to meet response and repair requirements. This could place further pressure on supply in an already challenging marine maintenance market, which could in turn cause further compliance difficulties (especially for smaller owners and operators).
• Investment Decisions: While “resilience through growth” is promoted as a key pillar of the UK government’s strategy, the new regulatory burden will undoubtedly play into investment decisions for existing cable projects and new builds (requiring more due diligence and capital injection). The increased compliance burden and regulatory liability may delay new projects and potentially defeat one of the government’s main objectives.
• Criminal Penalties: The UK already has tough sanctions for acts of sabotage linked to hostile states (though in practice, a relatively rare occurrence). One of the key difficulties is that malicious activity often occurs in the "grey zone", where circumstances are ambiguous and intent is hard-to-prove (such as recent disruption in Finland linked to Russia). The UK government is seeking to plug this gap by extending criminal sanctions to “reckless” damage, but the extent of penalties and breadth of applicability will be key to determining how effective of a deterrent this is. There are also natural limitations to the UK’s sovereignty where damage occurs in international waters by a foreign flagged vessel (which are hard to solve in national legislation and where a national legislative regime is inherently more difficult to enforce).

For more information on the proposed legislative changes or legal advice on submarine cable systems more generally, please contact: Stuart Blythe, Derek Jones, Costa Smith, Josh Cole, Jonathan Gordon and William Barrow.