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For Security Leaders, IT Directors, and Compliance Officers
Physical security systems — access control panels, IP cameras, video management software, cloud platforms — are no longer just locks and lenses. They are networked IT infrastructure, processing biometric data, streaming video to cloud servers, and authenticating identities in real time. And in 2026, the regulatory environment surrounding them has become genuinely consequential.
The FY2026 NDAA was signed by President Trump on 18 December 2025, passing with wide bipartisan margins (Holland & Knight) — and it carries real weight for the physical security industry. Cyber Essentials in the United Kingdom, meanwhile, enters its most rigorous update cycle to date. SOC 2 has evolved from a nice-to-have vendor credential into a baseline procurement requirement across both public and private sectors globally.
For security leaders and compliance officers, the convergence of these frameworks is not a bureaucratic headache — it is an opportunity. Organisations that understand and operationalise these requirements will protect their infrastructure, win more contracts, and build resilient systems that endure.
Those that ignore them face contract loss, legal exposure, and the real risk of deploying compromised hardware inside their own perimeters.
The National Defense Authorization Act is an annual piece of federal legislation that outlines the budget, policies, and priorities of the U.S. Department of Defense. While its main purpose is to authorise military spending, it has evolved to include measures aimed at strengthening national cybersecurity and protecting U.S. infrastructure from potential foreign threats, including restrictions on certain telecommunications and surveillance products (EMCI Wireless).
The critical provision for the physical security industry is Section 889. It prohibits the use of video surveillance and telecommunications equipment from specific Chinese companies — including Hikvision, Dahua, and Huawei — and FY2026 reinforces these bans without softening.
The practical implication: NDAA compliance in 2026 is not a checklist. It is a documented, evidenced, and legally consequential supply chain programme.
Hardware from banned vendors often carries risks that extend well beyond brand politics. Devices manufactured by state-linked companies may contain backdoors, undisclosed remote access capabilities, or firmware vulnerabilities that have never been independently audited. When such devices are deployed inside a corporate or government network, they represent a persistent, low-visibility threat.
Your CCTV infrastructure streams data to servers, receives firmware updates, and in many cases connects directly to cloud management platforms. These are not just cameras — they are networked IT systems that process sensitive data, and they historically have been managed with far less cybersecurity rigour than other enterprise IT infrastructure.
Experience shows that supply chain and compliance requirements are bound to become high-priority issues in M&A diligence and prime targets for False Claims Act enforcement. For any organisation operating in a federally funded environment — whether directly or as a downstream subcontractor — deploying Section 889-banned equipment can result in contract termination and ineligibility for future awards.
One of the trickiest aspects of NDAA compliance is that it covers both direct and indirect use. Direct use means an agency purchases or installs a banned product. Indirect use occurs when a non-compliant component, such as a chipset or camera module, is embedded within an otherwise approved system.
The ban extends to subsidiaries, affiliates, and OEM products that rebrand equipment from banned manufacturers — which is why working with a vetted distributor is critical. A camera may carry a European or American brand name while running firmware derived entirely from a restricted vendor's codebase. Due diligence requires examining the full component stack: chipsets, image processors, cloud management infrastructure, and firmware lineage.
Beyond the legal and financial impact, NDAA compliance represents a commitment to responsible technology sourcing and network security. Enterprise clients, insurers, and major institutional buyers are increasingly requiring compliance documentation as a condition of supplier qualification.
This is where many British and European security leaders have made a costly assumption: that NDAA is an American problem. It is not.
If your organisation does any of the following, NDAA compliance is directly relevant to you:
Companies doing business with defence or intelligence agencies should anticipate being required to certify compliance with these provisions. Beyond direct contractual exposure, there is a market signal effect that matters enormously. Large multinational enterprises have adopted NDAA-compliant procurement standards as part of their global supply chain risk programmes.
The UK Cyber Security and Resilience Bill expands the regulatory scope to explicitly include managed service providers and data centre operators. Fines for serious non-compliance could reach £17 million or 4% of global annual turnover. European organisations should treat NDAA compliance not as foreign regulation but as a forward indicator of where their own regulatory environment is heading.
Physical security has moved to the cloud. Access control systems now run on SaaS platforms, and video footage is processed and stored in cloud infrastructure. This architectural shift has made two certification frameworks essential: Cyber Essentials and SOC 2.
The v3.3 update to Cyber Essentials Plus places sharper emphasis on technical assurance over narrative responses — forcing organisations to prove controls are working, not just documented.
Key changes directly relevant to physical security:
Cyber Essentials has become more than a compliance checkbox — it is increasingly tied to procurement requirements, supply chain expectations, and customer confidence.
SOC 2 is an auditing standard that evaluates cloud service providers against five Trust Service Criteria: Security, Availability, Processing Integrity, Confidentiality, and Privacy.
For security leaders, SOC 2 Type II is the relevant credential. It covers not just the existence of controls at a point in time, but their consistent operational effectiveness over six to twelve months. A vendor without a current SOC 2 Type II report has a security posture that has not been independently verified — an unacceptable standard in 2026.
A genuinely secure physical security platform must protect sensitive data across its entire lifecycle.
Sensitive data held within a physical security platform includes access event logs, badge credentials, biometric templates, recorded video footage, and visitor records. The minimum standard for this data in 2026 is AES-256 encryption at rest, applied to both primary storage and backups.
Storage security also encompasses access controls: only authenticated, authorised services and personnel should be able to read or modify stored records. Role-based access control (RBAC) with least privilege principles should govern who can export, delete, or modify historical data.
All communication between physical security devices, on-premise servers, and cloud management platforms must be encrypted using TLS 1.2 or higher. Legacy unencrypted protocols represent exploitable attack surfaces and should be considered disqualifying.
Zero Trust Architecture (ZTA) assumes no user, device, application, or network segment should be trusted by default. For physical security systems, this means cameras and access readers are treated as untrusted endpoints until verified, and administrative access requires MFA and continuous logging.
A UK-based facilities management company installs access control for a US defence contractor's UK offices, using a camera brand not on the banned list. What they do not check is that the camera uses a Hikvision-derived chipset. Eighteen months later, an audit fails the cameras. The integrator faces contract termination and a rip-and-replace. **Lesson:** Demand firmware lineage before procurement.
A European corporate headquarters deploys a well-priced cloud-based access control system. When the CISO requests a SOC 2 Type II report for insurance, the vendor cannot produce one. A penetration test reveals access event logs are stored unencrypted. The result is forced migration and unexpected spend. **Lesson:** Ask for SOC 2 Type II reports upfront.
A UK-based financial institution selects a physical security platform that publicly documents NDAA compliance, holds SOC 2 Type II, and is Cyber Essentials Plus certified. When the institution tenders for a US programme, their security posture is documented and requires no remediation. Compliance becomes a competitive advantage.
The convergence of NDAA, Cyber Essentials, and SOC 2 in 2026 is a response to a demonstrable threat: the exploitation of physical security infrastructure for cyber attacks. The attacks of 2025 made one thing undeniably clear: physical security is IT security. The physical security perimeter and the cybersecurity perimeter are the same perimeter.
Companies that build compliance into their security architecture will win contracts and operate infrastructure they can genuinely trust. The frameworks to protect both have never been clearer.
Will your organisation act before a compliance failure makes the decision for you? Book a Migration Consultation today to learn how Wavestore's NDAA-certified, SOC 2 Type II compliant WaveFusion platform secures your perimeter and your data.
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