Privacy & Cybersecurity Law Blog

On January 31, 2025, the UK government published the Code of Practice for the Cyber Security of AI (the “Code”) and the Implementation Guide for the Code (the “Guide”).  The purpose of the Code is to provide cyber security requirements for the lifecycle of AI.  Compliance with the Code is voluntary.  The purpose of the Guide is to provide guidance to stakeholders on how to meet the cyber security requirements outlined in the Code, including by providing examples of compliance.  The Code and the Guide will also be submitted to the European Telecommunications Standards Institute (“ETSI”) where they will be used as the basis for a new global standard (TS 104 223) and accompanying implementation guide (TR 104 128).

The Code defines each of the stakeholders that form part of the AI supply chain, such as developers (any business across any sector, as well as individuals, responsible for creating or adapting an AI model and/or system), system operators (any business across any sector that has responsibility for embedding/deploying an AI model and system within their infrastructure) and end-users (any employee within a business and UK consumers who use an AI model and/or system for any purpose, including to support their work and day-to-day activities).  The Code is broken down into 13 principles, each of which contains provisions, compliance with which is either required, recommended or a possibility.  While the Code is voluntary, if a business chooses to comply, it must adhere to those provisions which are stated as required. The principles are:

• Principle 1: Raise awareness of AI security threats and risks.
• Principle 2: Design your AI system for security as well as functionality and performance.
• Principle 3: Evaluate the threats and manage the risks to your AI system.
• Principle 4: Enable human responsibility for AI systems.
• Principle 5: Identify, track and protect your assets.
• Principle 6: Secure your infrastructure.
• Principle 7: Secure your supply chain.
• Principle 8: Document your data, models and prompts.
• Principle 9: Conduct appropriate testing and evaluation.
• Principle 10: Communication and processes associated with End-users and Affected Entities.
• Principle 11: Maintain regular security updates, patches and mitigations.
• Principle 12: Monitor your system’s behavior.
• Principle 13: Ensure proper data and model disposal.

The Guide breaks down each principle by its provisions, detailing associated risks/threats with each provision and providing example measures/controls that could be implemented to comply with each provision. 

Read the press release, the Code, and the Guide.