Reference Guide

Compliance Frameworks
Plain English

Our tools reference ten cybersecurity and data protection frameworks. This page explains each one โ€” what it is, whether it applies to your business, and where to go for the official source. All external links go directly to government or standards body sites.

Jump to: Privacy Laws Industry Standards Information Security Government Frameworks UK Specific Quick Reference Table
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Privacy and Data Protection Laws
Legal obligations set by governments. Non-compliance can result in regulatory fines.
GDPR
EU & UK Law High Priority
General Data Protection Regulation
Applies to: Any business that
holds or processes data on
EU or UK residents

The primary data protection law in the EU and UK. GDPR sets rules on how personal data is collected, stored, used, and deleted. It gives individuals rights over their own data โ€” including the right to see it, correct it, and request deletion. Maximum fines: EUR 20M or 4% of global annual revenue, whichever is higher.

What this means for small businesses
If you collect email addresses, take online orders, or hold any information about EU or UK residents, GDPR applies โ€” regardless of where your business is based. You need a Privacy Policy, a lawful basis for each category of data collected, and a way to respond to customer data requests within 30 days. Most small businesses can cover the basics in a few hours.
CCPA / CPRA
California Law
California Consumer Privacy Act / California Privacy Rights Act
Applies to: Businesses serving
California residents above
certain revenue or data thresholds

California's primary privacy law, strengthened by CPRA. Gives California residents rights to know what data is collected, opt out of its sale, and request deletion. Enforcement is by the California Privacy Protection Agency. Fines up to $7,500 per intentional violation. Over 20 other US states now have similar laws in effect or in progress.

What this means for small businesses
CCPA applies if your business has annual gross revenue over $25M, buys or sells personal data of 100,000+ consumers annually, or derives 50%+ of revenue from selling personal data. Many small businesses fall below these thresholds โ€” but if you serve California customers, documenting your data practices is good practice regardless. Check whether your state has its own privacy law โ€” Virginia, Colorado, Texas, and others now do.
HIPAA
US Federal Law Healthcare Only
Health Insurance Portability and Accountability Act
Applies to: US healthcare providers,
health plans, and their
business associates

US federal law governing the protection of health information (PHI โ€” Protected Health Information). Requires administrative, physical, and technical safeguards. Civil fines range from $141 to over $71,000 per violation (2024 figures, adjusted annually for inflation), with annual caps up to $2.1M per violation category. Applies to covered entities and to any vendor or software provider that handles PHI on their behalf.

What this means for small businesses
If you are a healthcare provider, health insurer, or a vendor that handles PHI on behalf of these organisations, HIPAA applies regardless of your size. This includes medical practices, dental offices, physiotherapists, mental health providers, and many health tech companies. Non-healthcare SMBs do not need to comply. If you are uncertain, the HHS provides a free online tool to determine if you are a covered entity.
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Industry-Specific Standards
Sector requirements set by industry bodies. Non-compliance can result in loss of trading rights or contracts.
PCI-DSS
Industry Standard Payments Only
Payment Card Industry Data Security Standard (v4.0)
Applies to: Any business that
accepts, processes, stores or
transmits payment card data

Security standards maintained by the PCI Security Standards Council, founded by Visa, Mastercard, American Express, and Discover. Version 4.0 is currently in effect. Non-compliance can result in fines from payment processors, loss of card acceptance rights, and liability for fraud losses after a breach.

What this means for small businesses
If you take any card payments โ€” online or in person โ€” PCI-DSS applies. Most small businesses qualify for the simplest compliance tier (SAQ A) if they use a compliant payment processor like Stripe, Square, or PayPal and never handle raw card numbers themselves. Ask your payment provider if they are PCI-DSS Level 1 certified and confirm which SAQ type you qualify for.
FCA / DORA
Financial Services
FCA (UK) ยท Digital Operational Resilience Act (EU โ€” January 2025)
Applies to: Regulated financial
services firms in the UK and EU

The FCA regulates financial services firms in the UK, with requirements around operational resilience and cybersecurity. DORA is the EU equivalent โ€” mandatory for financial entities from January 2025 โ€” covering ICT risk management, incident reporting, operational resilience testing, and supply chain security. DORA applies to banks, insurers, investment firms, fintechs, and their technology providers.

What this means for small businesses
If your business holds an FCA authorisation (financial advice, insurance, investment management, payments, lending), both FCA operational resilience rules and potentially DORA apply regardless of your size. If you are a technology provider to a DORA-regulated firm, your customers may require you to meet specific ICT security standards through contractual clauses. Start with the FCA's operational resilience PS21/3 policy statement.
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Information Security Standards
Voluntary frameworks that demonstrate security maturity. Increasingly required by customers and insurers.
ISO 27001
International Standard Voluntary
ISO/IEC 27001:2022 โ€” Information Security Management System
Applies to: Any organisation
seeking formal certification of
their security management

The international standard for information security management (ISMS). Provides a systematic approach to managing sensitive information through people, processes, and technology. Certification requires an external audit by an accredited certification body. The current version is ISO 27001:2022. Recognised globally as the benchmark for organisational security maturity.

What this means for small businesses
ISO 27001 certification is increasingly required by larger customers, government contracts, and cyber insurers. Full certification takes 6-18 months and typically costs $15,000-$50,000 for small businesses including consultant and audit fees. As a first step: review the ISO 27001 control set and implement what is relevant without formal certification. For UK businesses, Cyber Essentials is faster, cheaper, and a recognised stepping stone.
SOC 2
US Standard Voluntary
System and Organization Controls 2 โ€” AICPA
Applies to: Technology and SaaS
companies storing or processing
customer data

An auditing standard from the American Institute of CPAs. SOC 2 Type I confirms controls are properly designed at a point in time. SOC 2 Type II confirms those controls operated effectively over a 6-12 month period. Type II is the standard demanded by US enterprise customers. Covers five Trust Service Criteria: Security, Availability, Processing Integrity, Confidentiality, and Privacy.

What this means for small businesses
If you are a SaaS or technology company with US enterprise customers, you will be asked for a SOC 2 Type II report. Full certification typically costs $30,000-$100,000 and takes 12-18 months. Start with a readiness assessment before committing to an audit. Platforms like Vanta and Drata automate evidence collection and significantly reduce audit preparation cost and time.
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Government Cybersecurity Frameworks
Published by national government bodies. Often required for public sector contracts and critical infrastructure.
NIST CSF 2.0
US Government Voluntary
NIST Cybersecurity Framework Version 2.0 (Released February 2024)
Applies to: US businesses, particularly
those supplying government or
critical infrastructure

Published by the National Institute of Standards and Technology, a US government agency. Organises cybersecurity activities into six functions: Govern, Identify, Protect, Detect, Respond, and Recover. Version 2.0 (2024) added Govern as a new function and expanded scope beyond critical infrastructure. Widely adopted globally as a best-practice reference.

What this means for small businesses
NIST CSF is voluntary for most businesses but mandatory for US federal agencies and many government contractors. For SMBs, the framework is most useful as a structured way to think about cybersecurity priorities. NIST publishes a dedicated Small Business Cybersecurity Corner with simplified implementation guidance. If you supply to US federal agencies, also review NIST SP 800-171 for specific controlled unclassified information requirements.
NIS2
EU Directive In Force Oct 2024
Network and Information Systems Directive 2
Applies to: EU medium and large
businesses in critical sectors.
Some SMBs indirectly affected.

The updated EU cybersecurity directive, replacing NIS1. Applied across EU member states from October 2024. NIS2 significantly expanded covered sectors (18 sectors including energy, transport, health, digital infrastructure, manufacturing, food, and public administration) and strengthened requirements for risk management, incident reporting within 24-72 hours, and supply chain security.

What this means for small businesses
NIS2 primarily targets medium companies (50+ employees or EUR 10M+ revenue) in critical sectors. Most small businesses are exempt from direct obligation. However: if you supply to a NIS2-obligated company, your customers are now required to assess their supply chain security โ€” which means security questionnaires, contractual security requirements, and audit rights may flow down to you as a supplier. Check your national transposition law as requirements vary by EU member state.
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UK-Specific Frameworks
Government-backed UK schemes. Cyber Essentials is the most accessible certification for small businesses.
Cyber Essentials
UK Government โ€” NCSC SMB Recommended
UK Government Cyber Essentials Scheme โ€” National Cyber Security Centre
Applies to: UK businesses.
Mandatory for UK government
contracts involving personal data.

A UK government-backed certification scheme developed by the NCSC. Covers five key controls: firewalls, secure configuration, user access control, malware protection, and patch management. Two levels: Cyber Essentials (self-assessed, verified by certifying body) and Cyber Essentials Plus (independent technical verification). Certification typically costs GBP 300-500 for small businesses.

What this means for small businesses
This is the most practical and affordable security certification available to UK small businesses. Mandatory for any UK government contract involving handling of personal data or delivery of certain technical products and services. The five controls address the vast majority of common automated cyberattacks. For UK SMBs: start here before pursuing ISO 27001. Certification takes 2-4 weeks and costs under GBP 500 through any NCSC-approved certifying body.
Quick Reference โ€” Does It Apply to Me?
Framework Serving EU/UK Customers Takes Card Payments Healthcare UK Business Financial Services
GDPRYesYesYesYesYes
UK GDPRIf UK customersIf UK customersIf UK customersYesYes
CCPAThreshold dependentThreshold dependentThreshold dependentThreshold dependentThreshold dependent
PCI-DSSOnly if cardsYesOnly if cardsOnly if cardsOnly if cards
HIPAAโ€”โ€”Yesโ€”โ€”
Cyber Essentialsโ€”โ€”โ€”Recommendedโ€”
FCA / DORAโ€”โ€”โ€”โ€”Yes
ISO 27001If required by customerIf required by customerIf required by customerIf required by customerIf required by customer
SOC 2If US customers requireIf US customers requireIf US customers requireโ€”If US customers require
NIST CSFโ€”โ€”โ€”โ€”If US govt contracts
NIS2If 50+ employees in scope sectorโ€”Critical sectorโ€”Critical sector
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For Reference Only โ€” Always Verify at Source
All content on this page is provided for general reference and awareness purposes only. It does not constitute legal advice, compliance certification, or a definitive statement of your obligations under any law or standard.
These guidelines change. Compliance frameworks, regulations, and enforcement guidance are updated regularly by the governments and standards bodies that publish them. The versions described on this page were accurate at the time of writing but may have since been amended, superseded, or extended. Do not rely on this page as your sole source of compliance information.
Go directly to official sources. For the most current and authoritative version of any requirement, go directly to the official government body or standards organisation responsible for that framework โ€” links are provided under each entry above. Regulatory websites publish updates, guidance documents, and enforcement decisions that supersede any third-party summary, including this one.
Your situation may differ. Which frameworks apply to your business depends on your specific activities, the countries you operate in, the sectors you serve, the type of data you hold, and your contractual obligations. Two businesses in the same industry can have significantly different compliance requirements. If you are uncertain, consult a qualified data protection solicitor or compliance specialist before making decisions based on this content.
Free resources for further research: ICO (UK) ยท NCSC (UK) ยท FTC (US) ยท CISA (US) ยท ENISA (EU) ยท SCORE โ€” Free US Business Mentoring
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