MSP CAF Compliance Guide: Complete Requirements & Implementation Strategy

Table of Contents

• What is the Cyber Assessment Framework (CAF)?
• Why MSPs Must Comply with CAF
• Key CAF Requirements for MSPs
• CAF vs Cyber Essentials vs ISO 27001
• Implementation Timeline & Steps
• Regulatory Obligations Under CAF
• Getting Started with CAF Compliance

What is the Cyber Assessment Framework (CAF)?

The Cyber Assessment Framework (CAF) is the UK government’s official standard for assessing cyber resilience, developed by the National Cyber Security Centre (NCSC). Unlike prescriptive control frameworks, CAF focuses on outcomes-based cybersecurity, requiring organisations to demonstrate measurable results across four core objectives.

The Four Core CAF Objectives for MSPs

1. Managing Security Risk

• Demonstrate robust governance structures for cybersecurity risk management
• Maintain comprehensive risk assessments for systems supporting essential services
• Establish clear accountability frameworks for security decisions

2. Protecting Against Cyber Attack

• Implement effective security controls to safeguard critical systems
• Deploy defence-in-depth strategies tailored to threat landscapes
• Maintain up-to-date security measures aligned with emerging threats

3. Detecting Cyber Security Events

• Establish continuous monitoring capabilities for critical infrastructure
• Implement regular testing protocols for security defences
• Develop threat detection capabilities spanning all supported services

4. Minimising the Impact of Incidents

• Create comprehensive incident response procedures
• Establish rapid service restoration capabilities
• Maintain business continuity plans for essential services

Why MSPs Are Now Under CAF Regulatory Scope

The Growing MSP Cyber Threat Landscape

Recent high-profile cyberattacks on major UK organisations including Jaguar Land Rover, Marks & Spencer, and The Co-op have highlighted critical vulnerabilities in the digital supply chain. MSPs represent a particularly attractive target for threat actors because:

• Single point of failure: Compromising one MSP can provide access to multiple client organisations
• Privileged access: MSPs typically maintain elevated permissions across client systems
• Supply chain amplification: Successful MSP breaches can impact entire sectors simultaneously

Cyber Security and Resilience Bill Impact

The upcoming Cyber Security and Resilience Bill brings MSPs directly under regulatory oversight for the first time, recognising their critical role in UK cyber resilience. This regulatory expansion means:

• MSPs supporting essential services must demonstrate CAF compliance
• Enhanced reporting obligations to regulators and NCSC
• Potential designation as “Critical Suppliers” for high-impact providers
• ICO oversight and regular compliance audits

Key CAF Requirements for MSPs

Security and Incident Reporting Obligations

24-Hour Incident Notification Requirement

• Report security incidents affecting essential services within 24 hours
• Submit detailed incident analysis within 72 hours
• Maintain comprehensive incident logs for regulatory review

Enhanced Regulatory Oversight

• Regular compliance audits and assessments
• Ongoing evidence gathering for security practices
• Potential unscheduled inspections for critical suppliers

ICO as Lead Regulator

• Information Commissioner’s Office assumes primary regulatory authority
• Regular engagement required on compliance matters
• External audit requirements for designated critical suppliers

CAF vs Cyber Essentials vs ISO 27001: Control Comparison

Key Differences for MSPs

CAF Positioning: CAF typically sits between Cyber Essentials and ISO 27001, providing a balanced approach to cybersecurity governance without the overhead of a full Information Security Management System implementation.

Client Expectations: Even MSPs initially out of regulatory scope will face client demands for CAF evidence, making proactive compliance a competitive differentiator.

Scalability Considerations: Larger MSPs designated as critical suppliers may face control requirements exceeding ISO 27001 standards.

CAF Implementation Timeline & Strategy

Phase 1: Assessment and Gap Analysis (Months 1-2)

Current State Analysis

• Inventory of existing security controls and documentation
• Map current practices against CAF objectives
• Identify compliance gaps and resource requirements

Stakeholder Engagement

• Establish CAF compliance team with clear responsibilities
• Engage with clients regarding CAF requirements and timelines
• Co-ordinate with legal and regulatory advisers

Phase 2: Control Implementation (Months 3-8)

Priority Control Areas

1. Governance and Risk Management: Establish formal cybersecurity governance structures
2. Technical Controls: Implement monitoring, detection, and response capabilities
3. Documentation: Create comprehensive policies, procedures, and evidence packages
4. Training and Awareness: Develop CAF-specific training programmes for staff

Automation Integration

• Deploy compliance management platforms for continuous monitoring
• Implement automated evidence collection and reporting systems
• Establish real-time compliance dashboards for ongoing oversight

Phase 3: Testing and Validation (Months 9-12)

Internal Validation

• Conduct comprehensive control testing across all CAF objectives
• Perform tabletop exercises for incident response procedures
• Validate documentation completeness and accuracy

External Assessment Preparation

• Where necessary, co-ordinate with external auditors for formal assessment
• Prepare comprehensive evidence packages for regulatory review

CAF Regulatory Requirements and Compliance Obligations

Mandatory Reporting Timelines

Immediate Response Requirements

• 24 hours: Initial incident notification to regulators and NCSC
• 72 hours: Detailed incident report with impact assessment
• Ongoing: Regular compliance status updates and evidence provision

Critical Supplier Designation Criteria

Organisations may receive Critical Supplier status if:

• Service disruption would significantly impact essential services
• Client base includes multiple essential service providers
• Geographic or sector concentration creates systemic risk

Enhanced Requirements for Critical Suppliers

• Quarterly compliance assessments
• Mandatory external security audits
• Enhanced incident response capabilities
• Advanced threat intelligence integration

Getting Started with CAF Compliance: Practical Steps

1. Understand Your Specific Requirements

Service Categorisation

• Identify which services qualify as supporting “essential services”
• Determine applicable CAF objectives and principles
• Map client requirements to regulatory expectations

Risk Assessment

• Conduct comprehensive threat modelling for MSP operations
• Assess potential impact of service disruptions
• Evaluate likelihood of Critical Supplier designation

2. Leverage Automation for Efficiency

Compliance Management Platforms

Modern CAF compliance requires automated solutions that can:

• Monitor CAF objectives and assign remediation tasks
• Automatically map existing controls to CAF principles
• Track implementation progress with real-time dashboards
• Generate audit-ready evidence packages
• Provide continuous compliance status monitoring

Key Automation Benefits

• Reduce manual compliance overhead by up to 70%
• Ensure consistent evidence collection and documentation
• Enable proactive risk identification and remediation
• Streamline regulatory reporting and audit preparation

3. Engage Expert Support Early

CAF Specialist Consultation

• Interpret complex regulatory requirements for your specific context
• Identify implementation shortcuts and efficiency opportunities
• Provide ongoing guidance for emerging regulatory changes
• Support audit preparation and regulatory engagement

Implementation Support Services

• Gap analysis and remediation planning
• Policy and procedure development
• Staff training and awareness programmes
• Ongoing compliance monitoring and optimisation

Competitive Advantage Through Early CAF Adoption

Market Positioning Benefits

Trust and Credibility

• Demonstrate proactive cybersecurity leadership
• Differentiate from competitors still developing CAF capabilities
• Build stronger client relationships through enhanced security posture

Business Development Opportunities

• Access new contracts requiring CAF compliance
• Command premium pricing for enhanced security services
• Expand into essential services sectors with confidence

Risk Mitigation

• Reduce likelihood of security incidents and their associated costs
• Minimise regulatory penalties and reputational damage
• Strengthen overall business resilience and continuity

Key Takeaways for MSP CAF Compliance

CAF compliance is becoming mandatory for MSPs supporting essential services, with client expectations extending beyond formal regulatory scope.

Early preparation provides competitive advantage by demonstrating cybersecurity leadership and enabling access to new market opportunities.

Automation and expert guidance are essential for efficient implementation and ongoing compliance management.

The regulatory landscape is evolving rapidly, making proactive engagement with CAF requirements crucial for long-term business success.