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Pall Mall Process: Defining Responsible Cyber Intrusion

Originally published on: December 4, 2025
▼ Summary

– The Pall Mall Process is an international initiative launched by the UK and France to establish guidelines for the responsible use of commercial cyber intrusion capabilities (CCICs), including spyware.
– It involves 27 governments and major tech companies, aiming to maximize the positive use of CCICs for national security while eradicating their harmful and destabilizing applications.
– The process is currently consulting the “offensive cyber” industry to define responsible behavior, complementing an existing Code of Practice for States.
– The CCIC market is diverse and growing, encompassing services like exploit development and hacking-as-a-service, with a complex ecosystem of researchers, brokers, and state customers.
– This effort is timely, as the market for tools like zero-day exploits is active, with recent incidents highlighting both state-linked espionage and illegal sales to hostile actors.

A significant international initiative is now working to establish clear standards for the commercial cyber intrusion industry, aiming to curb dangerous practices while recognizing the legitimate security needs of nations. The Pall Mall Process, launched jointly by the UK and France, has united 27 governments and major technology firms like Google, Microsoft, Apple, and Meta. Its goal is to address the rapidly expanding market for commercial spyware and zero-day exploits by defining responsible conduct for private sector companies involved in offensive cyber capabilities.

Currently in a pivotal second phase, the process is actively seeking input from the industry itself. The UK’s National Cyber Security Centre (NCSC) is leading a consultation to gather perspectives from companies operating in this space. The insights will shape a set of guidelines for responsible behavior, designed to work alongside an existing Code of Practice for States that was endorsed by the participating nations last year. Officials argue that while these tools are vital for combating serious crime and national security threats, their unchecked use poses significant risks.

The NCSC defines Commercial Cyber Intrusion Capabilities (CCICs) broadly. This category includes vulnerability research, exploit development, malware creation, and various “as-a-service” offerings like hacking and access provision. The agency describes a complex and evolving marketplace with a diverse ecosystem of researchers, developers, brokers, and state customers. The consultation emphasizes that every participant in this ecosystem shares a responsibility for promoting safer practices and mitigating harm.

This push for guidelines coincides with undeniable growth in the CCIC market. The discovery and patching of new zero-day vulnerabilities by major vendors is a near-monthly occurrence, highlighting the constant arms race. Recent incidents underscore the dangers. In one case, a critical flaw in WhatsApp was exploited in attacks targeting Samsung device users. In another, a Chrome zero-day was linked to an espionage campaign utilizing tools from a commercial vendor. The market’s shadowy side was further revealed when a U.S. defense contractor executive admitted to selling company-developed exploits to a Russian broker with ties to the Kremlin.

The UK and French governments are particularly eager to hear directly from professionals within the CCIC industry. They want to understand business motivations and gather practical ideas on fostering responsibility. The ultimate objective is not merely to define good conduct but to empower the community to collectively address and reject irresponsible uses of these powerful tools. The open consultation for the Pall Mall Process guidelines is scheduled to conclude on December 22.

(Source: InfoSecurity Magazine)

Topics

commercial spyware 95% pall mall process 90% zero-day exploits 85% international cooperation 80% cybersecurity guidelines 80% vulnerability research 75% National Security 70% tech giants 70% cyber intrusion ecosystem 65% responsible behavior 65%