On a gray morning in London, as financial executives sip their first coffee of the day, an undercurrent of urgency hums through the City. The FCA’s operational resilience deadline looms, and firms are awakening to the reality that compliance is not just a regulatory hoop to jump through—it’s a litmus test for survival in an era of relentless disruption.

A C-suite conversation unfolds in a corner office, where an executive stares at a dashboard glowing with risk metrics. “How close are we to defining our impact tolerances?” she asks. The response is uneasy: “Closer than before, but gaps remain in third-party mapping and scenario testing.” CLDigital is stepping up at this crucial time, providing firms with a smart, automation-driven pathway to resilience.

Key Requirements Under FCA & PRA Regulations

The UK Financial Conduct Authority’s Policy Statement PS21/3 – Building Operational Resilience and the PRA’s Supervisory Statement SS1/21 mandate financial firms, including banks, insurers, electronic money institutions, and payment providers, to take a structured approach to operational resilience.

By 31 March 2025, firms must:

  1. Identify Important Business Services (IBS): What happens when a core payment system crashes? When clients are unable access their funds? These disruptions, if unmanaged, could erode trust and shake market stability.
  1. Set Impact Tolerances: Define maximum allowable disruption limits for each IBS, including time thresholds and other relevant metrics.
  1. Complete Mapping & Scenario Testing: Document people, processes, technology, and dependencies critical to IBS delivery, identify vulnerabilities, and test response capabilities under severe but plausible disruptions.
  1. Update Policies & Procedures: Maintain written records of resilience assessments and ensure governance structures support ongoing compliance.
  1. Develop a Communication Strategy: Ensure clear internal and external communication plans to respond effectively to disruptions.

Firms should align their resilience strategy with the FCA’s observations from May 2024, which emphasize third-party risk management, interdependencies between firms, and continuous improvement beyond the compliance deadline.

Operational Incident and Third-Party Reporting

In December 2024, new consultation papers from the PRA and FCA raised the stakes further, introducing a reporting framework for operational incidents and third-party dependencies. A single technology outage could now trigger regulatory scrutiny, regardless of whether it breaches formal impact tolerances.

Next Steps: Ensuring Continuous Compliance

The financial world is shifting. Resilience is no longer a niche concern—it is the foundation of trust in an interconnected, volatile economy. Leading firms are not merely treating operational resilience as a regulatory exercise; they are weaving it into the fabric of their business strategy.

  • Assess resilience posture and identify gaps in policies, testing frameworks, and governance structures.
  • Integrate resilience within risk, business continuity, and recovery planning, ensuring cross-functional alignment.
  • Strengthen third-party risk management by reviewing outsourcing agreements and monitoring service provider resilience.
  • Train senior leadership and employees to instill a proactive resilience mindset across the organization.

How CLDigital Can Help

As firms race toward compliance, CLDigital stands as a strategic ally, not just a solution provider. Our no-code platform orchestrates operational resilience, regulatory compliance, and risk management, offering real-time insights, AI-driven scenario testing, and automated governance workflows.

For firms straddling both the UK and EU, the challenge doubles. The EU Digital Operational Resilience Act (DORA), effective 17 January 2025, overlays another set of cybersecurity and IT resilience requirements. CLDigital’s technology ensures a seamless adaptation to these frameworks, allowing organizations to stay ahead of risk, not just react to it.

As the 31 March 2025 deadline looms, the firms that embrace operational resilience not as a box-ticking exercise, but as a strategic imperative, will be the ones that thrive in an unpredictable world. Is your firm ready?

Let’s Talk Operational Resilience. Contact us today to learn how CLDigital can help you navigate the future with confidence.