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The National Security and Investment Act 2021 ("NSI Act") commenced on 4 January 2022 and gave the UK government a stand-alone investment-screening regime separate from the merger-control framework. Under section 6 the Secretary of State may designate "notifiable acquisitions" by sector via secondary legislation — the Notifiable Acquisition Regulations (NARs), SI 2021/1264. The original NARs specified 17 sensitive sectors in which acquisitions of qualifying entities crossing 25% / 50% / 75% control thresholds (or material influence) require mandatory pre-completion notification to the Investment Security Unit (ISU) within the Cabinet Office; completion before clearance is void.
Between 22 July 2025 and 14 October 2025 the Cabinet Office consulted on the first substantive update to the schedules since 2022. The Government Response published on 12 March 2026 (alongside Written Ministerial Statement HLWS1399 by Chief Secretary to the Treasury Darren Jones) confirms the perimeter changes summarised below. Implementation is via a Statutory Instrument to be laid in Parliament later in 2026; until that SI is in force, the existing NARs continue to apply unchanged.
1. Critical Minerals — new standalone schedule. Lifts the critical-minerals carve-out from the Advanced Materials schedule and covers exploration, extraction, processing, recycling, R&D and production for all 34 minerals on the Critical Minerals Intelligence Centre's latest criticality assessment. Aligns the screening perimeter with the UK Critical Minerals Strategy "Vision 2035" (2025-11-22) and brings the regime closer to the EU CRMA / US §30D-FEOC / Canada Critical Minerals Strategy structural map.
2. Semiconductors — new standalone schedule. Previously combined inside Advanced Materials. The new schedule explicitly captures advanced packaging and specific chip-design processes, bringing the UK perimeter closer in shape to the US BIS export-controls perimeter and the EU Chips Act IPF/OEF facility designation.
3. Water — new mandatory schedule. First time the water sector has been subject to NSI mandatory notification. Covers the 17 regional water and sewerage undertakers in England and Wales but excludes companies operating solely as retailers in the non-household retail market. Reflects the post-Independent Water Commission policy push (Commission report July 2025; Government White Paper January 2026) and the long-running ownership-and-control concern around foreign-PE-held undertakings (Thames Water, Southern Water).
4. AI — narrowed to creators / modifiers. Routine end-use of off-the-shelf or licensed third-party AI systems and modifications made as part of routine IT deployment will be excluded from mandatory notification. Mandatory capture is refocused on entities that create or materially modify advanced AI systems.
5. Data Infrastructure — tightened definitional scope. Expressly captures all third-party-operated data centres including hyperscaler / CSP and Managed Service Providers; closes ambiguity around colocation and shared-infrastructure deals.
6. Clarifying refinements to Communications, Critical Suppliers to Government, Energy and Suppliers to the Emergency Services schedules to reduce low-risk capture without weakening core national-security coverage.
7. Unchanged. Following consultation feedback, the Advanced Materials and Synthetic Biology schedules remain unmodified.
Structural rather than market-moving in the short term — no transactions are blocked or unblocked on 12 March 2026, and the SI is months away. The strategic-classification effect, however, is durable: the UK joins the allied investment-screening tightening trend (2023-08-09-us-outbound-investment-screening-eo14105, 2024-03-22-canada-bill-c34-ica-modernization, 2024-11-15-korea-outbound-investment-screening, 2025-07-24-poland-investment-control-law-permanent, 2025-12-19-switzerland-investment-screening-act-ipg) and explicitly aligns the UK perimeter with the US/EU semiconductor and critical-minerals strategic-sector frameworks. Severity 3 = qualitative, non-quantified perimeter widening (water + standalone semis + standalone critical minerals) net of perimeter narrowing (AI end-use, Comms / Energy / Critical Suppliers refinements).
water/sewerage undertaker in England & Wales becomes mandatorily notifiable once the SI is in force. Re-prices the optionality of PE-held water undertakings (Thames Water restructuring track in particular) and slows secondary-buyout timelines.
ventures (e.g. Cornish Lithium, British Lithium / Imerys, Pensana, Less Common Metals, Cornwall Resources) into a clearly delineated mandatory-notification perimeter — useful for FTA-partner sourcing alignment with US §30D, EU CRMA Strategic Projects and the Vision 2035 strategy.
CSA Catapult, Pragmatic Semiconductor, Graphcore-successor IP acquisitions become visible to the ISU via the standalone Semiconductors schedule, structurally hardening the UK National Semiconductor Strategy 2023 perimeter.
"everyone-using-Copilot" tail of low-risk filings that have congested the ISU since 2022 — an explicit ease-of-business signal paired with the wider Modern Industrial Strategy push.
Critical Minerals Strategic Partnership (2026-04-24) and the India / Vietnam / Australia critical-minerals partner-shoring framework — the UK is positioning to join the same data-sharing regime allied screening agencies are building.
has committed to laying SI later in 2026; perimeter precision (e.g. whether "advanced packaging" tracks BIS 88 FR 73424 definitions) is unresolved until then.
but completing after.
by static cross-reference or by dynamic "as-amended" language — determines how quickly future minerals (e.g. germanium, gallium reclassification) flow into the regime.
2026-03-18-uk-cbam-finance-act-2026)on critical-mineral importers.