For a bank CISO, cyber resilience means more than stopping intrusions: it means sustaining critical operations through disruption and restoring them safely when they fail. Start with the services customers and markets depend on, then determine whether the people, systems, information and providers behind those services can withstand a severe cyber event.
What does cyber resilience mean for a bank?
The Federal Reserve defines operational resilience as “the ability to deliver operations, including core business lines and critical operations, through a disruption from any hazard.” Cybersecurity supports that broader outcome; it is not the outcome by itself. A bank may have extensive security controls and still be unable to process payments, serve customers or manage liquidity when a key system or provider is unavailable.
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This shifts the central question from “How many controls are deployed?” to “Can the bank continue its most important operations when prevention fails?” Prevention and detection remain essential, but resilience also depends on preparation, adaptation, response, recovery and learning.
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| Perspective | What it emphasizes | Useful leadership question |
|---|---|---|
| Control coverage | Whether safeguards are implemented across systems and risks | Which controls reduce the likelihood or impact of this threat? |
| Operational resilience | Whether a critical operation can continue through disruption and recover | What service will be affected, how long can it be impaired, and what allows it to continue? |
This is a practical distinction, not a regulator’s formal scoring model. Basel Committee on Banking Supervision guidance treats resilience as a connected management discipline spanning governance, operational risk, continuity and testing, dependency mapping, third-party management, incident management, and resilient information and communications technology (ICT), including cybersecurity.
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Which operations must remain available?
Define the outcome in terms of bank operations, not just applications or security systems. Senior leaders should identify the critical operations the institution must deliver, then establish what disruption to each would mean for customers, counterparties and the bank. The answer depends on the bank’s business model, obligations and risk profile; a single generic list is unlikely to fit every institution.
For each critical operation, record the service it provides, the business owner, the dependencies needed to deliver it, and the disruption conditions that could prevent delivery. This gives technology and risk teams a shared basis for prioritization. It also makes it possible to discuss alternatives: for example, whether a service can operate at reduced capacity, whether work can be rerouted, and what conditions must be met before normal processing resumes.
How should a bank map its dependencies?
Trace each critical operation end to end. An operation may depend on more than the application that appears on a system inventory: it can rely on information, infrastructure, people, facilities and external providers. A failure in one dependency can interrupt the service even when the bank’s own security controls are functioning as designed.
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- Information: Identify critical information assets and the integrity, availability and access requirements that allow the operation to function.
- Technology: Map applications, data stores, networks, identity services, hosting and other ICT components that support the operation.
- People and processes: Record the roles, skills, procedures and decision authority required to operate, respond and recover.
- External dependencies: Include third-party services and other providers whose disruption could affect delivery, along with the bank’s relevant dependencies on them.
- Substitutability and concentration: Note where a dependency has a viable alternative and where several critical operations rely on the same provider, system or capability.
Use the map to prioritize protection and testing according to operational significance and risk, rather than treating every asset as equally important. Basel guidance highlights the need to identify critical information assets and dependencies, protect information integrity and test vulnerabilities. A map is useful only if it informs decisions: when a dependency changes, the associated operation’s risk assessment, response plans and exercise scenarios should be reconsidered.
What should a bank resilience test cover?
A useful exercise tests whether the bank can respond, recover and continue delivering critical functions through a severe but plausible disruption. It should expose consequential assumptions—for example, that a backup is accessible, that an alternate process can handle real demand, or that a provider can restore a service in time. A discussion that confirms participants know the plan is not, on its own, evidence that the operation can continue.
Design the scenario around an operation
Choose a critical operation and create a plausible disruption that stresses its dependencies. Include third-party disruption where relevant: a bank’s resilience can be affected by a provider outage even when the initiating event is outside the bank. Decide in advance what evidence would demonstrate that the operation can continue or recover, such as whether staff can execute a fallback process or whether the required information remains usable and trustworthy.
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Exercise the full response and recovery path
Test how the bank detects and assesses the event, makes decisions, communicates, contains harm, sustains or restores the operation, and validates recovery. Include the teams and providers whose participation is necessary. Examine whether authority, information and escalation paths are available when normal systems or contacts are impaired.
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Turn findings into changes
Record where the exercise exposed a failure, delay or untested assumption; assign an owner and a corrective action; and revise procedures or dependencies where needed. Follow up with evidence that the change works. The aim is not a successful exercise narrative but a stronger ability to deliver the operation during disruption.
In a 2024 speech, ECB Banking Supervision reported that its qualitative cyber resilience stress test found high-level response and recovery frameworks in place, while also identifying room for improvement. That is a qualitative supervisory finding, not a numeric industry score or a prediction about any individual bank.
How do third parties fit into the resilience plan?
Third-party dependencies are part of the bank’s operational resilience posture, not a separate procurement concern. If an external service supports a critical operation, the bank needs to understand how its interruption would affect delivery, what response or recovery options exist, and how the bank will coordinate with the provider during an incident.
Map provider dependencies to the operations they support, prioritize them by potential operational impact, and include them in relevant exercises. Consider both the provider’s service and the bank’s ability to act if that service is impaired: a contractual assurance or provider recovery plan does not by itself demonstrate that the bank can sustain its own critical operation.
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The FFIEC Cybersecurity Assessment Tool (CAT) sunset on August 31, 2025, so it should not be presented as a current assessment tool. Federal Reserve guidance named the NIST Cybersecurity Framework 2.0, CISA Cybersecurity Performance Goals, Cyber Risk Institute Cyber Profile and CIS Critical Security Controls among available resources. These are resources to inform an institution’s approach, not a claim that one framework is universally required or sufficient.
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Basel guidance provides an international resilience framework, while Federal Reserve, FFIEC and ECB materials apply within their respective supervisory contexts. Applicability and supervisory expectations depend on jurisdiction and the bank’s circumstances; these sources do not establish a single reporting deadline or a uniform compliance checklist for every institution.
How should a CISO turn the perspective into action?
- Agree on critical operations. Work with business, risk and operations leaders to identify what the institution must continue delivering and who owns each operation.
- Map dependencies end to end. Connect each operation to its critical information assets, technology, people, processes and external providers.
- Prioritize by operational significance and risk. Direct attention to dependencies whose failure could materially impair a critical operation, and identify fragile or shared dependencies.
- Test severe but plausible disruption. Exercise response, recovery and continued delivery—including relevant provider failures—and define what evidence would demonstrate capability.
- Close the learning loop. Assign owners to findings, update plans and controls, and verify that corrective actions improve the operation’s ability to withstand disruption.
Scale the depth and formality of this work to the bank’s nature, size, complexity and risk profile, as Basel guidance calls for. The useful measure of progress is not the length of a checklist: it is whether leaders can identify what must keep working, understand what it depends on, and show through testing how it will continue when a serious disruption occurs.
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