
Operational resilience has moved well beyond regulatory compliance. In today’s increasingly volatile risk environment, it is now a defining business capability. Firms that succeed will be those that treat operational resilience not as a regulatory obligation, but as a strategic lever and, ultimately, a source of competitive advantage.
Across jurisdictions, we have seen increasing regulatory focus and scrutiny around operational resilience. While terminology differs across regulations – such as important business services (IBSs), critical operations, critical functions or critical services – the objectives and outcomes are consistent. This convergence centres on five core expectations:
For globally active firms, the challenge lies in navigating differing regulatory languages while demonstrating a common capability: proving that IBSs can remain within impact tolerances (ITOLs) during severe but plausible disruptions.
Supervisors increasingly expect robust evidence, from mapping to scenario results to governance effectiveness, rather than theoretical frameworks.
The shift is not about building parallel structures; it is about pivoting existing capabilities through a service lens to support effective resilience outcomes
Operational resilience is the ability of firms to prevent, adapt and respond to, recover and learn from operational disruption. It is grounded in a service-led view. It demands a clear, service-led understanding of how the organisation delivers value and where it is most exposed.
Resilience requires appreciating how enabling resources interact, how vulnerabilities aggregate and how disruption spreads across interconnected processes.
Operational resilience does not replace existing capabilities. Instead, it integrates and elevates existing capabilities such as business continuity, operational risk, cyber security and third-party risk management. Existing vulnerability analysis, controls and management information should inform both resilience posture and investment priorities.
The shift is not about building parallel structures; it is about pivoting existing capabilities through a service lens to support effective resilience outcomes.
Mature operational resilience programmes follow a structured lifecycle:
The most effective firms integrate this lifecycle into their existing operating model rather than treating it as a standalone regulatory initiative. Operational resilience requires harmonisation of your existing capabilities, rather than reinvention.
When looking at the implementation lessons learned, there are some recurring themes across firms:
As regulatory deadlines mature, attention is shifting from framework establishment to an enduring demonstrable capability.
Operational resilience is an enduring strategic capability, not a regulatory destination.
Firms that invest strategically, prioritise time-critical services, uplift third-party resilience and embed resilience dynamically into governance and change will be best positioned to meet regulatory expectations and maintain stakeholder trust during disruption.
When implemented strategically, operational resilience transforms from regulatory burden into competitive advantage, which enables organisations to thrive when others merely survive.
Within treasury teams, operational resilience requires a fundamental shift from viewing treasury as a support function to recognising its critical role in enabling IBSs.
Key considerations for treasury teams include:
Cross-functional engagement and process mapping:
Treasury should engage closely with operational resilience and business continuity functions to map treasury processes against IBS delivery chains, identifying where treasury capabilities directly impact trading, settlement, payments and other critical services that must remain within impact tolerances during a disruption.
Leveraging existing capabilities and alignment:
Many treasury functions already possess robust business continuity and crisis management capabilities that can be enhanced to support broader operational resilience objectives. An important further consideration is ensuring that treasury recovery time objectives align with the firm’s established impact tolerances for its dependent IBSs.
Comprehensive scenario testing and communication:
Treasury should participate in operational resilience scenario testing, including being involved in communication protocols during prolonged market stress, where treasury’s role in maintaining stakeholder confidence may be paramount.
Simran Singh is a director at KPMG