Guidance

National Security (State Threats) Act 2026: information for organisations

Published 17 July 2026

The National Security (State Threats) Act 2026 received Royal Assent on 8 July 2026.

It provides law enforcement with stronger tools to disrupt organisations engaged in hostile state-linked activity against the UK.

The Home Secretary has the power to designate bodies involved in Foreign Power Threat Activity where necessary to protect the safety or interests of the UK. Following a designation, a number of prohibitions will apply to all individuals and organisations.

This guidance is designed for organisations, including the private sector, to raise awareness of:

• how new offences under the legislation may apply to them
• what they can do to minimise their risk of prosecution and harm to their organisation and the UK’s safety or interests

Background

State threats is an umbrella term to describe overt or covert actions by foreign governments which fall short of direct armed conflict but go beyond peaceful diplomacy and expected statecraft to harm or threaten the safety or interests of the UK.

The Act is specifically concerned with Foreign Power Threat Activity (defined under section 33 of the National Security Act 2023 as amended by the new Act). That includes a range of harmful conduct against the UK that may be done for, on behalf of, or with the intention to benefit a foreign power (defined under section 32 of the National Security Act 2023), including:

• Espionage
• Sabotage
• Foreign interference; and
• Threats or acts of serious violence

Foreign states and proxies (either groups or individuals) may target commercial, academic and professional sectors to access the UK’s money, expertise, information and influence networks by embedding themselves in legitimate business activity, often through intermediaries, front organisations, or relationships that appear routine.

This can include requests for services, data, funding or partnerships that ultimately support Foreign Power Threat Activity.

These approaches are frequently designed to look innocent, which makes them harder to detect.

In addition to supporting Foreign Power Threat Activity, this activity may carry legal, commercial and reputational risk.

Criminal offences

The National Security Act 2023 contains criminal offences of assisting and obtaining material benefits from a foreign intelligence service, which individuals and organisations can be prosecuted under.

The new amendments to the National Security Act 2023 impose additional penalties on individuals and organisations who support, materially assist and obtain material benefits from designated bodies.

Designation makes it a criminal offence to:

• support a designated body (new section 17A) - this will apply where a person invites support for, or expresses an opinion or belief that is supportive of a designated body, and does so for a prohibited purpose (i.e. a purpose that a person knows, or having regard to other matters known to them ought reasonably to know, is prejudicial to the safety or interests of the UK). It will also apply where a person arranges, manages or assists in arranging or managing a meeting which supports, further the activities of or is addressed by a person who belongs or claims to belong to a designated body for a prohibited purpose.

• assist a designated body (new section 17B) - this will apply where a person engages in conduct and intends it to materially assist a designated body in carrying out UK-related activities; or where a person engages in conduct likely to materially assist a designated body and knows, or ought reasonably to know, their conduct is likely to materially assist a designated body in carrying out UK-related activities.

• obtain material benefits from a designated body (new section 17C(1)) - this will apply where a person obtains, accepts or retains a material benefit (or obtains or accepts the provision of such a benefit to another person) that is or was provided by or on behalf of a designated body and the person knows, or ought to reasonably know it was.

• agree to accept a material benefit (or the provision of such a benefit to another person) that is or was provided by or on behalf of a designated body and the person knows, or ought to reasonably know it was (new section 17C(2)).

These offences each carry a maximum penalty of 14 years imprisonment or a fine (or both), except for the offence of agreeing to accept a material benefit which carries a maximum penalty of 10 years imprisonment or a fine (or both).

Defences to criminal offences

The Act does not criminalise activities that require engagement with designated bodies and which are not prejudicial to the safety or interests of the UK, such as journalistic, diplomatic or humanitarian activities.

The offences of assisting and obtaining material benefits include specific defences for humanitarian activities, Crown employees, and those with an agreement or arrangement with the UK government (e.g. those with licences under a sanctions regime).

The humanitarian defence applies in line with internationally recognised principles and standards on humanitarian activities, recognised under international humanitarian law.

The offence of obtaining material benefits also includes a reasonable excuse defence for those who obtain information provided by a designated body. This applies to a range of legitimate activities including journalism and humanitarian efforts.

The legal activity defence to the material assistance offence is available for authorised persons e.g. solicitors and barristers, who carry out legal activities for designated bodies, including representation in challenges to Home Office decisions. This defence does not extend to others working in the legal profession such as trainee solicitors or paralegals. In such circumstances, the carrying out of legal activities which fall within the scope of the offence should be appropriately limited between an instructed authorised person and a designated body.

How risks of new offences may arise

Risks can arise even where activity appears routine, commercially legitimate, or is carried out through intermediaries or third parties such as:

• providing services, funding, infrastructure, or advice to a designated body
• engaging in activity that materially assists a designated body, even indirectly
• engaging with a client or partner that is acting on behalf of a designated body
• undertaking any of the above activity by continuing to work with a body after it has been designated

Steps to take

To protect your organisation and comply with the law, you should consider:

• familiarity with the list of designated bodies – The list of designated bodies will be updated each time the Secretary of State exercises their power (to add or remove bodies).
• being vigilant - Stay alert to how designated bodies could appear in your sector. This includes understanding emerging risks and recognising warning signs.
• whether your organisation’s activity falls within the scope of the offence - Assess whether the activity falls within sections 17A, 17B or 17C. Where your activity does not amount to an offence, the legislation is not intended to prevent, discourage or disrupt that activity.
• whether a defence applies - Assess whether your organisation’s activity falls within a statutory defence under the legislation. Where a statutory defence applies, the legislation is not intended to prevent, discourage or disrupt that activity.
• proportionate due diligence - Verify who your client or partner is, consider who ultimately benefits from your work and whether there are links to a designated body which risks an offence being committed.
• reporting to the police – If you are concerned there is a risk your activity could be linked to a designated body, consider reporting this to the police. However, reporting will not be necessary where, following appropriate due diligence, you reasonably conclude that the conduct falls within a statutory defence or does not satisfy the elements of an offence under the legislation.
• ongoing and potential client relationships – You can reduce the risk of a potential offence by considering ending customer relationships and exercising caution over potential relationships where a risk is identified and the conduct does not appear to fall within a statutory defence and otherwise satisfies the elements of an offence.
• wider reporting obligations – If you have a suspicion of money laundering or terrorist financing linked to a designated body, consider any existing obligations to report this to the National Crime Agency by submitting a Suspicious Activity Report.

Taking these steps will help you reduce your exposure to legal, commercial and reputational risk and support the UK’s response to state threats.

It is likely that your organisation is already taking steps that align with this guidance. The key is to ensure these are appropriately applied to the risks posed by designated bodies.

Report to law enforcement

You should report to the police on 999 in an emergency, otherwise call 101 as soon as possible and give as much detail as you can. You can also call the Anti-Terrorist Hotline on 0800 789 321 or report using the online portal where:

• you are dealing with a designated body
• you suspect a client, partner or intermediary is acting for a designated body and continuing your activity could materially assist one
• you are unsure but there is a realistic possibility of a link to a designated body

Reporting is encouraged in circumstances where an individual or organisation reasonably suspects that conduct may amount to an offence under this legislation. There is no general obligation under this legislation or expectation to report a transaction, interaction or other dealing with a designated body where an individual reasonably considers that the conduct does not amount to an offence or that a statutory defence applies.

Consider wider reporting obligations

Reporting incidents where there is a risk of an offence under this legislation is separate from reporting under any existing anti-money laundering obligations under the Proceeds of Crime Act 2002 and Terrorism Act 2000.

Organisations in the regulated sector are required to submit Suspicious Activity Reports to the National Crime Agency where they know or suspect that money laundering or terrorist financing has occurred.

Individuals and organisations also have the option to seek a defence from the National Crime Agency under section 335 and 336 of the Proceeds of Crime Act 2002 or under section 21ZA of the Terrorism Act 2000 where they believe the activity they intend to carry out may result in them committing a money laundering or terrorist financing offence.

Obtaining consent from the National Crime Agency under the Proceeds of Crime Act 2002 or Terrorism Act 2000 does not absolve individuals or organisations of any liability in respect of the new offences under this legislation.

Executing the steps outlined in this guidance will help reduce the risk of prosecution for them.

Case studies – responding to risks

1. A UK bank has an account open with a customer, body A, that is subsequently designated under the National Security Act 2023. Once the UK bank is aware of body A’s designation, it carries out due diligence and identifies the designated body’s account. The UK bank assesses that no defence applies. The UK bank risks committing the offence of assisting a designated body by providing it with financial services in circumstances where it ought reasonably to know that its services will materially assist the body in carrying out UK-related activities (which could be any activities in the UK). In accordance with internal business processes, the bank decides it would be proportionate to freeze the account before informing the police of the activity.

2. A UK bank has an account open with a customer whose transactions, despite some variation, are overwhelmingly outward transfers of funds to a specific third party, Body B, which is a designated body. The UK bank subsequently undertakes due diligence to learn that the third party in question is a designated body. The UK bank assesses that no defence applies. The UK bank risks engaging in conduct likely to materially assist Body B in carrying out UK-related activities (which could be any activities in the UK) by allowing funds to be transferred to it. The UK bank decides in accordance with its internal business processes, it would be proportionate to block any future customer payments to Body B whilst informing the police of the activity.

3. A UK organisation delivers medical supplies for the ultimate benefit of the local civilian population in an area where a designated body, Body C, exercises de facto control. In order to access the affected population, the UK organisation may transact with, interact with or otherwise deal with the designated body or its representatives. The UK organisation uses a UK bank to process the payments involved in such transactions, interactions and other dealings, as well as instructing it to make payments to local partners suppliers and staff. The UK organisation maintains appropriate due diligence procedures, details of which it shares with the UK bank. The fact that the UK organisation receives information from, engages with, or makes incidental payments to Body C in connection with delivering humanitarian assistance or supporting basic human needs would not, without more, amount to an offence under sections 17A, 17B or 17C, and (in relation to sections 17B and 17C) should also fall within the specific defences relating to humanitarian activity. Both the UK organisation and the UK bank would be able to rely on these defences. In these circumstances, the UK bank should not treat the incidental transactions, interactions or other dealings of the UK organisation with Body C or its representatives as grounds for refusing, limiting or withdrawing banking services.

4. A UK-based defence manufacturer holds a UK government contract to supply communications equipment to the Armed Forces. During a routine supply chain review, the company discovers that a subcontractor providing specialist electronic components is wholly owned by Body D, which has recently been designated under the National Security Act 2023. The company undertakes due diligence by reviewing corporate ownership records, open-source information, and contractual documentation. This confirms Body D is clearly linked to the supplier. The company assesses that continuing to purchase components from the supplier risks providing financial benefit to Body D in carrying out UK-related activities (which could include any activities in the UK) and that no defence applies. In accordance with its internal compliance procedures, the company suspends future orders from the supplier, begins identifying alternative sources of supply, preserves relevant records and considers reporting the matter to the police. Given the clear ownership link and the value of the contracts involved, these steps are considered proportionate to the risk.

5. A small engineering company employing 20 staff manufactures specialist components used in military vehicles under a subcontract connected to a wider UK government programme. The company receives an enquiry from an overseas distributor seeking to purchase a large quantity of components. During customer onboarding, a compliance officer carries out basic due diligence proportionate to the firm’s size, including sanctions screening, checking publicly available corporate ownership information, and reviewing media reporting. The checks identify reports suggesting the distributor may be acting on behalf of Body E, a designated body. Although the link is not immediately conclusive, the company determines that there is a realistic possibility of a connection. Given the concerns, the company pauses the transaction, seeks additional information about the end user, and declines to proceed until it is satisfied the goods will not ultimately materially assist the Body E in carrying out UK-related activities (which could include any activities in the UK). The steps taken are proportionate to the company’s size and resources while reducing the risk of committing an offence.

6. A UK bank identifies through screening that a customer was employed by Body F, now a designated body, approximately ten years before designation occurred. There is no evidence the customer continues to have any involvement with Body F, receives funds from it, or acts on its behalf. The bank undertakes proportionate due diligence by reviewing account activity, conducting updated screening checks, and requesting clarification from the customer regarding their historical association. The review identifies no evidence that the customer is materially assisting Body F to carry out any UK-related activities (which could include any activities in the UK). The bank documents its assessment and continues providing services while maintaining ordinary monitoring arrangements.

7. A UK bank provides services to a manufacturing company. During periodic customer review, the bank learns that one of the company’s customers is a large multinational enterprise which, through several layers of subsidiaries, previously had a minor commercial relationship with Body G, a designated body. The bank assesses the information and determines there is no evidence that its customer is materially assisting Body G to carry out UK-related activities (which could include any activities in the UK). The bank seeks clarification from the customer and reviews transaction data to confirm its understanding. Having found only a remote and indirect connection, the bank concludes that enhanced monitoring is not required. The due diligence undertaken is considered proportionate to the low level of risk presented.

8. A bank initially identifies what appears to be a tenuous link between a customer and Body H, a designated body, through a shared business associate. As part of proportionate due diligence, the bank reviews transaction data and discovers a pattern of regular payments to intermediary companies linked to Body H. What first appeared to be a weak connection now suggests a potential indirect relationship with the designated body. The bank escalates the matter internally, undertakes enhanced due diligence, considers whether future transactions should be restricted, and evaluates whether reporting to the police is appropriate. The bank’s response becomes more extensive because the evidence uncovered increases the risk that its services may materially assist Body H in carrying out UK-related activities (which could include any activities in the UK).

For any queries related to this guidance, please contact the State Threats Legislation team at the Home Office: STULegislationTeam@homeoffice.gov.uk

Frequently asked questions

Is there a list of designated bodies available?

The list of designated bodies is available on GOV.UK.

How will I know that I am dealing with a designated body?

In some cases, it may be obvious; they could be acting in the name of a designated body or due diligence checks may reveal clear links to a designated body. However, it may be unclear or there may be no signs at all you are dealing with a designated body.

How do organisations verify the authenticity of a potential client?

Organisations are trusted to have their own client authentication process.

Does a potential client’s links to a foreign state mean I should not be dealing with them?

No, this guidance does not intend to encourage organisations to refrain from all activities with links to foreign states. We encourage organisations to use their own discretion in engaging in activities.

What if I realise halfway through a contract that I have been working for a designated body?

Organisations are encouraged to use their discretion in accordance with internal processes regarding what action to take. However, a clear case of assisting or obtaining material benefits where a specific defence does not apply and the requirements of one or more of the offences appear to have been met may require an organisation to reassess the arrangement and take appropriate mitigating steps. Depending on the circumstances, this may include modifying, suspending or ending activity and considering whether to contact the police. Where a statutory defence applies, cessation of the activity or reporting to law enforcement is not encouraged.

What will the consequences be for me or my organisation if I report an incident to the police?

If you and your organisation have carried out reasonable due diligence checks and have no reason to know that you are materially assisting or obtaining benefits from a designated body, you are unlikely to have anything to worry about. Reporting to the police will allow them to do their job effectively and protect your organisation.

What if I have a financial, trade or transport sanctions licence which enables activity?

If you are carrying out activities permitted under a valid licence issued by the UK Government in respect of a sanctions regime, you will have a defence against the offences of assisting a designated body and obtaining material benefits; on the basis that the licence is an arrangement to which the UK government is party. If you have a sanctions licence issued by another country’s government, the defence will not be available so it would not be a valid defence to be undertaking activity which breaches this legislation under such a licence.

How will designations be communicated?

The UK Government will carry out a range of communications activities to ensure there is broad awareness of new designations. An up-to-date list of designated bodies will be maintained.

How soon after a body is designated will organisations be expected to end the relationship?

Once a body’s designation has been announced, there will be a responsibility on individuals and organisations to ensure that their existing activities do not amount to a criminal offence. They will be expected to take action as soon as is reasonably practicable, taking into account the individual circumstances of that organisation.

It may or may not be necessary to exit the relationship formally. The material assistance offence does not require all business relationships to be terminated; only that all material assistance to the body (in carrying out UK-related activities) should cease. Material assistance could include the provision of financial services, but this will depend on the circumstances.

How will this exit process be managed without committing an offence?

This will depend on the circumstances and on the terms of your contract with the designated body. These terms will often allow organisations to end a contract where they are required to do so by law.  It may also be possible to continue a limited formal relationship without providing material assistance to (or obtaining any material benefit from) the designated body.

Can the organisation return funds to a designated body on exiting the relationship without committing an offence?

Whether you can return funds will depend on whether you know or ought to know that returning the funds will ‘materially assist’ the body. Whether you must return funds, and how soon, will depend on the terms of your contract.

What is the preferred reporting route organisations and staff should use?

Organisations and their staff are encouraged to report to the police using 101, the Anti-Terrorism Hotline, online at gov.uk/ACT, or in an emergency dial 999.

What type of information should be included with a police report?

Organisations and their staff are encouraged to provide as much information as possible, including why they believe the information relates to the offences or any other reason why they believe they may be at risk of a state threat.

Is it necessary to report to law enforcement in addition to the NCA via a SAR?

The expectation that organisations and staff report to police where they are at risk of committing a new offence under this legislation is independent of existing anti-money laundering obligations under the Proceeds of Crime Act 2002 and Terrorism Act 2000. There may be circumstances where an activity both risks committing an offence, and an individual considers it necessary or appropriate to submit a Suspicious Activity Report, Defence Against Money Laundering or Defence Against Terrorist Financing to the National Crime Agency.

How far do organisations have to take their due diligence?

It is the responsibility of organisations to fully determine the extent of their specific risk exposure, and to develop an appropriate set of safeguards and controls tailored to their particular circumstances. The National Protective Security Authority has published a number of guidance documents for individuals and businesses to follow. The Protective Security Risk Management guidance is a good starting point for new businesses or those without established risk management practices for responding to national security threats. Organisations may choose to reflect or update their existing practices due to this legislation.

What are the costs to organisations from this?

There is expected to be minimal financial impact on organisations from this legislation. Reporting to the police where appropriate is likely to incur minimal costs whilst potential Suspicious Activity Reports should create some familiarisation and unmonetised minor administration costs. The Impact Assessment can be consulted for further detail.

Does the new legislation restrict humanitarian activities?

No. The legislation is not intended to impede humanitarian assistance or other activities that support basic human needs and the corresponding lawful provision of commercial services that enable aid organisations to carry out their activities. The provision of necessary banking, insurance, logistics, transport, communications or other support services is not captured by the legislation. Similarly, section 17B will not criminalise legitimate payments that those physically present in a country outside the UK may be required to make as part of their routine operations or day-to-day living.  Such conduct, including routine transactions involving the payment of taxes, duties, fees or other ordinary costs which are necessary for such conduct, is not contrary to the safety or interests of the UK for the purposes of Section 17B.

Section 17C will not criminalise conduct where it is necessary for an aid organisation to accept, obtain or retain a financial or other benefit (including information or tax rebate for instance) from a designated body. Such benefits are regarded as reasonable consideration for the lawful provision of goods and services and are not considered “material benefits” for the purposes of Section 17C.

Does the new legislation restrict peacebuilding or conflict-resolution activities?

No. Sections 17A, 17B and 17C contain specific elements which must be established before an offence is committed. Activities undertaken solely for development, peacebuilding, mediation, dialogue, conflict-resolution or conflict-prevention purposes will not be for the prohibited purpose required for section 17A. Similarly, a transaction, interaction or other dealing with a designated body which is necessary for such activities is unlikely to amount to material assistance for the purposes of section 17B. Section 17C also contains specific defences relating to where there is a reasonable excuse for retaining a benefit or for obtaining, accepting and agreeing to accept information.

Do activities pursuant to an exception in Regulations made under the Sanctions and Anti-Money Laundering Act 2018 which engage designated bodies risk committing an offence?

The National Security Act 2023 contains defences for activities carried out under agreements or arrangements the UK government is a party to. The UK government’s position is that exceptions contained in Regulations made pursuant to the Sanctions and Anti-Money Laundering Act 2018 do not constitute such an arrangement or agreement, so it would not be a valid defence in itself to be undertaking activity pursuant to such an exception. However, if your activity is in accordance with another agreement or arrangement involving the UK Government, the position of the Government is that the defence could be used.

Should UK banks freeze accounts of designated bodies?

If after following the “steps to take” set out above, a UK bank forms the view that continued access to funds by a designated body could risk an offence being committed, proportionate steps should be taken to minimise that risk and reporting to the police is encouraged.

Do the new offences apply to an organisation based outside the UK, or with international offices?

The offences apply to conduct taking place outside the UK if the person is a “UK person” (as defined under section 2 of the National Security Act 2023) or is employed by or holds office under the Crown. A UK person includes a UK national or an individual who is living in the UK. This means that such an individual employed outside the UK is capable of committing an offence under this legislation, including Section 17C which applies where the benefit is provided in or from the UK. Therefore, the steps outlined above are encouraged to minimise any risk of committing an offence.

How should a bank proceed in relation to transactions with bodies that are partly or mostly owned by a designated body?

There are no provisions in the legislation about ownership and control which exist for sanctions under the Sanctions and Anti-Money Laundering Act 2018. Organisations and their staff are encouraged to carry out proportionate due diligence to mitigate their risk of offending, relative to the individual circumstances faced with.