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Pall Mall’s Shifting Sands: A Critical Assessment of State Norms and the Future of Cyber Security

The proliferation of commercial cyber intrusion capabilities presents a sustained and evolving challenge to global security. States are grappling with how to manage the risks stemming from readily available tools capable of sophisticated attacks, while simultaneously balancing national security imperatives with the need for a stable, open internet. This necessitates a continuous reevaluation of existing norms and frameworks, particularly those established through the Pall Mall Process.

The Singapore International Cyber Week event, specifically France’s engagement on October 21, 2025, represents a key juncture in this ongoing process. The Pall Mall Process, initiated as a collaborative effort between France and the United Kingdom, aims to address the risks associated with the purchase, transfer, and use of commercial cyber intrusion capabilities. The process is underpinned by the Paris Call for Trust and Security in Cyberspace, reflecting a broader international consensus on responsible state behavior within cyberspace. The event’s focus on sharing assessments, particularly from the French National Cybersecurity Agency (ANSSI), highlights a growing recognition within the international community that simply establishing a framework is insufficient; demonstrable action and consistent enforcement are paramount.

Historical Context & The Evolution of the Pall Mall Process

The Pall Mall Process emerged in 2019 following a series of high-profile cyberattacks attributed to state-sponsored actors. These attacks, including those targeting democratic institutions and critical infrastructure, exposed vulnerabilities and underscored the need for a coordinated international response. The initial impetus was to create a space for open dialogue between governments and industry stakeholders on how to mitigate the risks. Prior to the Paris Call in 2025, discussions largely centered on discouraging states from directly developing and deploying these tools. However, the reality is that many states operate in the grey areas of cyberspace, utilizing proxies and third parties to conduct offensive operations.

The second conference in Paris in April 2025 catalyzed a shift toward a more formalized Code of Practice. This document, supported by 27 signatories at the time of the Singapore event, committed states to taking concrete steps to address the proliferation of commercial cyber intrusion capabilities. The Code emphasizes responsible state behavior, discouraging the use of these tools for offensive purposes, and promoting transparency and accountability. “The challenge isn’t simply stating intentions; it’s demonstrating adherence through verifiable mechanisms,” notes Dr. Evelyn Hayes, Senior Fellow at the International Cyber Policy Center at the University of Maryland. “Without robust enforcement and independent verification, the Code risks becoming a largely symbolic gesture.”

Stakeholders and Motivations

Several key stakeholders are actively involved in the Pall Mall Process, each driven by distinct motivations. France, as a leading digital economy power and a key defender of cybersecurity standards, seeks to shape the global norms landscape and protect its national interests. The United Kingdom, similarly invested in a secure and resilient cyberspace, acts as a crucial partner in establishing these norms. The United States, while not a formal signatory, maintains a significant interest due to the prevalence of American technology within the global cyber market. Several Eastern European states, particularly those bordering Russia and Ukraine, have become increasingly vocal supporters, reflecting concerns about potential spillover effects from hybrid warfare tactics. China, while officially supportive of the Paris Call, remains a complex and potentially problematic participant, given its own documented state-sponsored cyber operations. “The level of genuine commitment varies significantly,” argues Ben Davis, Head of Threat Intelligence at SecureState. “Some states genuinely embrace the principles, while others use the process to deflect criticism or signal compliance without undertaking substantive changes in their operational practices.”

Recent Developments & The Singapore Event

The addition of Belgium as the 27th signatory at the Singapore event represents a significant bolstering of the Pall Mall Process’s legitimacy. Belgium’s decision, driven by concerns about potential threats to its critical infrastructure and digital economy, demonstrates a growing recognition among European nations of the need for a multilateral approach to cybersecurity. The ANSSI's intervention at the event, through the Director General’s presentation, highlighted France’s assessment of the escalating threat posed by commercially available tools. This signaled a shift toward a more proactive stance, emphasizing the need for intelligence sharing and coordinated responses.

Furthermore, the initiative to launch a public industry consultation – a critical component of the Pall Mall Process’s next steps – suggests a commitment to incorporating diverse perspectives and fostering a more collaborative ecosystem. The goal is to develop future guidelines for a "responsible cyber intrusion market," potentially encompassing elements like vendor due diligence, supply chain security, and end-user training.

Short-Term and Long-Term Outcomes

In the short term (next 6 months), we can anticipate continued efforts to expand the Pall Mall Process’s membership and refine its operational mechanisms. Increased engagement from industry stakeholders is crucial to develop practical guidelines and establish verifiable standards. The Singapore event’s focus on industry consultation is a promising step, but the effectiveness will hinge on the willingness of companies to participate openly and honestly. There's a significant risk of "naming and shaming" – a tactic that could backfire if not handled delicately.

Looking longer-term (5-10 years), the Pall Mall Process faces considerable challenges. The proliferation of sophisticated, readily accessible cyber tools is likely to continue, driven by economic incentives and state-sponsored actors. The process’s success will depend on its ability to adapt to this evolving threat landscape. A key indicator will be the establishment of robust, independently verifiable mechanisms for assessing and addressing irresponsible behavior. “The future of the Pall Mall Process isn’t about dictating norms; it’s about building a resilient and trustworthy ecosystem,” concludes Dr. Hayes. “That requires constant vigilance, data-driven analysis, and a willingness to confront difficult questions.” The Singapore event, while a positive development, underscores the enduring complexity of securing cyberspace in a world where state actors operate with ever-increasing agility and sophistication.

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