(disclaimer, speculation) The Times article says this has been in progress for four years, so I suspect that this is the culmination of https://wiki.openrightsg

(disclaimer, speculation) The Times article says this has been in progress for four years, so I suspect that this is the culmination of https://wiki.openrightsgroup.org/wiki/UK-US_Bilateral_Agreement_on_Data_Access https://wiki.openrightsgroup.org/wiki/UK-US_Bilateral_Agreem.... Which was originally planned to be encryption-neutral, but maybe things have changed in the past two years.