UK: UK Government Issues Report On Huawei Vulnerabilities


On March 28, 2019, the Oversight Board of the United Kingdom's Huawei Cyber Security Evaluation Centre (HCSEC)1 released a report identifying "serious and systematic defects in Huawei's software engineering and cyber security competence." This report — the fifth annual review of Huawei products used in British telecommunications networks — represents the most detailed public expression of concern regarding security vulnerabilities in Huawei products by a national government to date, and bolsters, with significant technical detail, the concerns that U.S. government officials have raised about Huawei. Although the report states that the issues are not believed to be the result of Chinese state interference, the issues identified in the report are nonetheless serious enough that the Oversight Board found that it could offer only "limited assurance" that long-term security risks can be managed in the Huawei equipment currently employed in U.K. networks. The report is important not only for providing insight into how the U.S. and other allied governments may perceive Huawei and, thus, companies that use Huawei equipment, but for providing technology companies guidance on where to focus their own security and product integrity efforts.

Summary of the HCSEC Oversight Board's Findings

In evaluating more than three dozen products, the HCSEC identified "significant, concerning issues in Huawei's approach to software development bringing significantly increased risk to U.K. operators," including major defects in general software engineering and cybersecurity quality. The evaluation uncovered, among other things, the following issues:

  • Huawei's build process continues to provide no end-to-end integrity or adequate configuration management. Without this baseline of integrity, the HCSEC cannot routinely confirm that the products they are testing are the same as the products used in U.K. networks, or perform true root cause analysis of any issues identified in the products. Particular build process issues identified in the report included the use of unclean virtual machines in the build process, poor management of the build environment resulting in unnecessary or duplicate tools being installed, and poor management of source code across development teams and poor integration of components in the products.
  • Huawei uses an old, and soon-to-be out of mainstream, support version of a third-party real-time operating system that is subject to increased risk as a result of its out-of-date design. Huawei also did not provide a credible plan to reduce the risk of its use of this operating system or a path to upgrade to a supportable operating system that is appropriate for carrier-grade telecommunications systems.
  • Huawei's software component lifecycle management revealed significant flaws that could lead to cybersecurity and availability risk. For example, the HCSEC found evidence of extensive non-adherence to basic secure coding practices, the incorrect use of safe memory manipulation functions, and the inappropriate suppression of warnings from static analysis tools.

Perhaps most troubling, the annual report noted that Huawei made no material progress on the software engineering and cybersecurity issues that the Oversight Board identified in its 2018 report, nor has the company made any credible plans to mitigate or remediate the risks posed by its products. Although Huawei announced its intention to transform its software engineering processes through a $2 billion investment over the next five years, it has not supported this claim with any material and verifiable actions.

Key Takeaways

The HCSEC Oversight Board's report may complicate the vendor selection process for companies considering using Huawei equipment on their networks in the U.K., the United States and, likely, their close allies. Indeed, although the report stated that the HCSEC Oversight Board did not believe Huawei's problems were the result of Chinese state interference, in a way, this conclusion may be more damaging to Huawei because it serves as a counterpoint to Huawei's claims that the critiques levied against it are merely warrantless geopolitical attacks. Rather than vague national security concerns, the report documents in great detail the security problems with Huawei equipment. Companies using Huawei equipment and seeking legal or regulatory approvals in the United States, such as through the Committee on Foreign Investment in the United States (CFIUS) or the Federal Communications Commission's Team Telecom process, can expect this report to only further solidify those entities' concerns about Huawei.

In addition, apart from the use of Huawei equipment specifically, companies can expect the issues highlighted by the HCSEC Oversight Board to be raised with other equipment makers in the context of government reviews and licensing scenarios globally, including in the transactional and export licensing spaces. For instance, foreign companies seeking to acquire U.S.-based technology companies may expect CFIUS to scrutinize cybersecurity, product development and supply chain concerns during the review process. These issues also could be examined in the foreign direct investment review processes in other countries and regions, such as in the European Union. Moreover, software engineering and cybersecurity practices could arise in the export control licensing context to ensure that products are consistent and secure.

Accordingly, hardware and software developers should compare the Oversight Board's findings against their own practices and, to the extent that companies have deficiencies similar to those identified by the Oversight Board, they should be treated as high-priority items. For example, developers should be mindful in ensuring that they are using secure coding practices and supportable components. It is also important for developers to consider controls and tools necessary to ensure build consistency across products and programs, manage components appropriately, and test for potential vulnerabilities. Finally, developers should consider the plans and mechanisms in place to obtain feedback on vulnerabilities, mitigate such vulnerabilities, and communicate the patches in an effective and efficient manner.


1 The HCSEC is a Huawei facility that opened in November 2010 to provide the British government with insight into Huawei products and operations and help mitigate any perceived risks arising from the use of Huawei products in U.K. critical national infrastructure.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

To print this article, all you need is to be registered on

Click to Login as an existing user or Register so you can print this article.

In association with
Related Topics
Related Articles
Related Video
Up-coming Events Search
Font Size:
Mondaq on Twitter
Mondaq Free Registration
Gain access to Mondaq global archive of over 375,000 articles covering 200 countries with a personalised News Alert and automatic login on this device.
Mondaq News Alert (some suggested topics and region)
Select Topics
Registration (please scroll down to set your data preferences)

Mondaq Ltd requires you to register and provide information that personally identifies you, including your content preferences, for three primary purposes (full details of Mondaq’s use of your personal data can be found in our Privacy and Cookies Notice):

  • To allow you to personalize the Mondaq websites you are visiting to show content ("Content") relevant to your interests.
  • To enable features such as password reminder, news alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our content providers ("Contributors") who contribute Content for free for your use.

Mondaq hopes that our registered users will support us in maintaining our free to view business model by consenting to our use of your personal data as described below.

Mondaq has a "free to view" business model. Our services are paid for by Contributors in exchange for Mondaq providing them with access to information about who accesses their content. Once personal data is transferred to our Contributors they become a data controller of this personal data. They use it to measure the response that their articles are receiving, as a form of market research. They may also use it to provide Mondaq users with information about their products and services.

Details of each Contributor to which your personal data will be transferred is clearly stated within the Content that you access. For full details of how this Contributor will use your personal data, you should review the Contributor’s own Privacy Notice.

Please indicate your preference below:

Yes, I am happy to support Mondaq in maintaining its free to view business model by agreeing to allow Mondaq to share my personal data with Contributors whose Content I access
No, I do not want Mondaq to share my personal data with Contributors

Also please let us know whether you are happy to receive communications promoting products and services offered by Mondaq:

Yes, I am happy to received promotional communications from Mondaq
No, please do not send me promotional communications from Mondaq
Terms & Conditions (the Website) is owned and managed by Mondaq Ltd (Mondaq). Mondaq grants you a non-exclusive, revocable licence to access the Website and associated services, such as the Mondaq News Alerts (Services), subject to and in consideration of your compliance with the following terms and conditions of use (Terms). Your use of the Website and/or Services constitutes your agreement to the Terms. Mondaq may terminate your use of the Website and Services if you are in breach of these Terms or if Mondaq decides to terminate the licence granted hereunder for any reason whatsoever.

Use of

To Use you must be: eighteen (18) years old or over; legally capable of entering into binding contracts; and not in any way prohibited by the applicable law to enter into these Terms in the jurisdiction which you are currently located.

You may use the Website as an unregistered user, however, you are required to register as a user if you wish to read the full text of the Content or to receive the Services.

You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these Terms or with the prior written consent of Mondaq. You may not use electronic or other means to extract details or information from the Content. Nor shall you extract information about users or Contributors in order to offer them any services or products.

In your use of the Website and/or Services you shall: comply with all applicable laws, regulations, directives and legislations which apply to your Use of the Website and/or Services in whatever country you are physically located including without limitation any and all consumer law, export control laws and regulations; provide to us true, correct and accurate information and promptly inform us in the event that any information that you have provided to us changes or becomes inaccurate; notify Mondaq immediately of any circumstances where you have reason to believe that any Intellectual Property Rights or any other rights of any third party may have been infringed; co-operate with reasonable security or other checks or requests for information made by Mondaq from time to time; and at all times be fully liable for the breach of any of these Terms by a third party using your login details to access the Website and/or Services

however, you shall not: do anything likely to impair, interfere with or damage or cause harm or distress to any persons, or the network; do anything that will infringe any Intellectual Property Rights or other rights of Mondaq or any third party; or use the Website, Services and/or Content otherwise than in accordance with these Terms; use any trade marks or service marks of Mondaq or the Contributors, or do anything which may be seen to take unfair advantage of the reputation and goodwill of Mondaq or the Contributors, or the Website, Services and/or Content.

Mondaq reserves the right, in its sole discretion, to take any action that it deems necessary and appropriate in the event it considers that there is a breach or threatened breach of the Terms.

Mondaq’s Rights and Obligations

Unless otherwise expressly set out to the contrary, nothing in these Terms shall serve to transfer from Mondaq to you, any Intellectual Property Rights owned by and/or licensed to Mondaq and all rights, title and interest in and to such Intellectual Property Rights will remain exclusively with Mondaq and/or its licensors.

Mondaq shall use its reasonable endeavours to make the Website and Services available to you at all times, but we cannot guarantee an uninterrupted and fault free service.

Mondaq reserves the right to make changes to the services and/or the Website or part thereof, from time to time, and we may add, remove, modify and/or vary any elements of features and functionalities of the Website or the services.

Mondaq also reserves the right from time to time to monitor your Use of the Website and/or services.


The Content is general information only. It is not intended to constitute legal advice or seek to be the complete and comprehensive statement of the law, nor is it intended to address your specific requirements or provide advice on which reliance should be placed. Mondaq and/or its Contributors and other suppliers make no representations about the suitability of the information contained in the Content for any purpose. All Content provided "as is" without warranty of any kind. Mondaq and/or its Contributors and other suppliers hereby exclude and disclaim all representations, warranties or guarantees with regard to the Content, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. To the maximum extent permitted by law, Mondaq expressly excludes all representations, warranties, obligations, and liabilities arising out of or in connection with all Content. In no event shall Mondaq and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use of the Content or performance of Mondaq’s Services.


Mondaq may alter or amend these Terms by amending them on the Website. By continuing to Use the Services and/or the Website after such amendment, you will be deemed to have accepted any amendment to these Terms.

These Terms shall be governed by and construed in accordance with the laws of England and Wales and you irrevocably submit to the exclusive jurisdiction of the courts of England and Wales to settle any dispute which may arise out of or in connection with these Terms. If you live outside the United Kingdom, English law shall apply only to the extent that English law shall not deprive you of any legal protection accorded in accordance with the law of the place where you are habitually resident ("Local Law"). In the event English law deprives you of any legal protection which is accorded to you under Local Law, then these terms shall be governed by Local Law and any dispute or claim arising out of or in connection with these Terms shall be subject to the non-exclusive jurisdiction of the courts where you are habitually resident.

You may print and keep a copy of these Terms, which form the entire agreement between you and Mondaq and supersede any other communications or advertising in respect of the Service and/or the Website.

No delay in exercising or non-exercise by you and/or Mondaq of any of its rights under or in connection with these Terms shall operate as a waiver or release of each of your or Mondaq’s right. Rather, any such waiver or release must be specifically granted in writing signed by the party granting it.

If any part of these Terms is held unenforceable, that part shall be enforced to the maximum extent permissible so as to give effect to the intent of the parties, and the Terms shall continue in full force and effect.

Mondaq shall not incur any liability to you on account of any loss or damage resulting from any delay or failure to perform all or any part of these Terms if such delay or failure is caused, in whole or in part, by events, occurrences, or causes beyond the control of Mondaq. Such events, occurrences or causes will include, without limitation, acts of God, strikes, lockouts, server and network failure, riots, acts of war, earthquakes, fire and explosions.

By clicking Register you state you have read and agree to our Terms and Conditions