Operational Resilience Is Becoming the Global Regulatory Baseline

What Regulators Are Codifying, and Markets Already Exposed

Operational resilience has never been a novel regulatory concern, nor one confined to a single geography or sector. It has long been an operational reality shaped by scale, concentration, and interdependence. As financial and digital systems expanded and consolidated, the ability to sustain critical services under disruption became foundational to confidence in those systems. What has changed in recent years is not recognition of this reality, but the extent to which regulators across jurisdictions are now making resilience expectations explicit, enforceable, and measurable.

Earlier regulatory regimes inferred resilience indirectly. Capital adequacy, governance frameworks, and control maturity were treated as reasonable proxies for continuity. Those proxies were workable in environments where systems were less interconnected and failures more easily contained. In modern economies, they are increasingly insufficient. Disruption now propagates through shared infrastructure, outsourced platforms, and tightly coupled digital dependencies at a pace that exceeds traditional supervisory assumptions.

The convergence now underway reflects this shift. Regulators are not discovering a new category of risk. They are codifying operational truths that markets have already exposed, translating lived experience into supervisory expectation.

I. Resilience Was Always Global, Formalization Was Not

Few senior leaders responsible for technology, risk, or operations ever believed that service disruption was a localized problem. Payments, market infrastructure, identity services, and third-party technology platforms have operated across borders for decades. Failures in one jurisdiction have routinely produced consequences elsewhere, whether through market contagion, service unavailability, or erosion of confidence.

What differed across jurisdictions was not awareness of these risks, but the mechanisms used to address them. In some markets, expectations around continuity were enforced implicitly through supervisory dialogue, market discipline, or the visible consequences of failure. In others, resilience remained embedded within broader operational risk or business continuity programs, often without clear articulation of acceptable disruption or recovery expectations.

The present moment reflects a narrowing of that divergence. Across jurisdictions, supervisors are increasingly aligned around a shared premise: resilience must be demonstrated through observable continuity of important services under stress. Documentation, policies, and maturity assessments remain relevant, but they are no longer treated as substitutes for performance under realistic conditions.

While financial markets served as the earliest and most visible proving ground, regulatory focus has increasingly expanded to any systemically important service whose disruption would undermine confidence in the broader economic or social system.

II. From Institution-Centric Safety to Service-Centric Continuity

This shift from institution-centric to service-centric thinking represents one of the most consequential changes in modern supervision, and it is often misunderstood.

Traditional prudential regulation treated the institution as the primary unit of stability. Capital buffers, governance frameworks, and internal controls were intended to ensure that firms could absorb shocks without failing. In environments where services were delivered largely through institution-owned infrastructure, this approach aligned reasonably well with how disruption manifested.

That alignment has eroded. Customers, counterparties, and markets do not experience resilience at the level of legal entities. They experience it through services. Payment rails, authentication mechanisms, trading platforms, and customer-facing applications are the points at which confidence is earned or lost. These services are frequently delivered through shared infrastructure, outsourced platforms, and complex dependency chains that transcend institutional boundaries.

As a result, an institution may remain solvent, well governed, and compliant, while still failing to deliver critical services when disruption occurs. From the perspective of markets and customers, that distinction is immaterial. Confidence erodes at the moment continuity fails, not when capital thresholds are breached.

Regulatory attention has adjusted accordingly. Supervisors increasingly ask whether critical services remain available, whether disruption remains within defined tolerances, and whether recovery occurs predictably. The emphasis has shifted from the presence of controls to the endurance of outcomes. This service-centric lens reflects how modern systems actually function and why resilience can no longer be inferred solely from institutional strength.

III. Asia-Pacific as an Early Accelerator of Operational Reality

Several Asia-Pacific markets encountered the consequences of digital concentration and operational dependency earlier than many peers. Rapid digitization, centralized infrastructure, and the prominence of regional financial hubs meant that failure modes surfaced sooner and at greater scale.

In Singapore, the financial system is highly concentrated and deeply digitized. Core banking, payments, and market services rely on a relatively small number of shared platforms and third-party providers. Service disruptions in this environment are immediately visible and system-wide. Outages and near-misses in payments and market access revealed that operational failure could generate systemic consequences without any accompanying financial distress. Supervisory focus on technology risk and service continuity emerged early, shaped by exposure rather than theory.

In Japan, continuity expectations have been shaped by repeated experience with large-scale disruption. Natural disasters stressed assumptions about availability and recovery long before operational resilience became formal regulatory language. Financial institutions integrated continuity into operational culture, recognizing that service failure undermines confidence at a societal level.

Australia provides a third illustration. Dependence on shared platforms and service providers, combined with a relatively concentrated financial sector, highlighted how operational risk could become systemic even in the absence of institutional failure. Supervisory emphasis on operational risk and service reliability reflected this exposure.

These examples do not suggest conceptual leadership. They illustrate temporal exposure. Asia-Pacific markets encountered the operational consequences of concentration and dependency earlier, accelerating practical resilience thinking before it was formally codified elsewhere.

IV. Europe as Codifier: From Experience to Enforceable Structure

European regulatory regimes are often described as the birthplace of modern operational resilience thinking. A more accurate characterization is that Europe formalized expectations earlier and more explicitly than many peers.

In the United Kingdom, the UK Prudential Regulation Authority introduced an operational resilience framework centered on identifying important business services, defining tolerances for disruption, and testing the ability to remain within those tolerances under severe but plausible stress. This marked a clear departure from control-based assurance. Firms were required to demonstrate that critical services would continue, not merely that processes existed.

At the European Union level, the Digital Operational Resilience Act extended this logic across jurisdictions and institutions. Its scope reaches beyond cybersecurity to encompass information and communication technology risk, outsourcing, and systemic concentration in third-party service providers. DORA translated operational reality into enforceable structure, creating consistency across borders.

Europe’s significance lies not in conceptual invention, but in being the first major jurisdiction to formalize operational resilience expectations into a harmonized, enforceable regulatory regime. Its contribution was codification, transforming operational insight into supervisory obligation earlier than many jurisdictions, enabled by institutional capacity and cross-border integration.

V. Convergence Beyond Traditional Centers: Brazil and Kenya

The same resilience logic appears beyond traditional regulatory centers, reinforcing the argument that convergence is driven by necessity rather than fashion.

In Brazil, real-time payments function as national infrastructure. Disruption is immediately visible, widely felt, and economically consequential. Supervisory attention has therefore treated technology resilience and service continuity as matters of systemic stability rather than internal hygiene. Expectations emerged because failure was intolerable.

A similar dynamic can be observed in Kenya, where mobile payments underpin everyday economic activity. Platforms such as M-Pesa support wage distribution, remittances, and small-business commerce at national scale. Operational disruption in this context produces immediate economic and social impact. Resilience discipline developed through lived dependency, shaped by visibility of failure rather than formal regulatory taxonomy.

Where services become essential to economic participation, resilience expectations follow.

VI. The United States: Fragmentation and Convergence Through Consequence

In the United States, convergence has taken a distinct path. There is no single operational resilience statute and no unified supervisory authority. Oversight is fragmented across federal and state regulators and varies by charter, industry, and activity.

Despite this fragmentation, alignment has emerged in practice. Supervisory guidance, enforcement actions, litigation risk, and board-level accountability increasingly frame prolonged service disruption, third-party dependency, and cloud concentration as governance issues rather than isolated technical failures. Market consequence has played a central role in shaping expectations, particularly for organizations whose services are deeply embedded in daily economic activity.

The U.S. experience illustrates that operational resilience expectations can converge through supervisory consequence and market accountability, even in the absence of a unified regulatory framework. Convergence does not require codification. It requires consequence.

VII. Global Bodies as Translators of Systemic Risk

International standard-setting bodies play a role that is often misunderstood, precisely because they operate above national regulatory regimes rather than within them. Organizations such as the Financial Stability Board do not regulate firms directly, nor do they issue binding rules. Their influence lies in shaping how systemic risk is defined, discussed, and prioritized across jurisdictions.

Following the global financial crisis, the Financial Stability Board increasingly framed financial stability around the continuity of critical functions rather than the solvency of individual institutions. This reflected a growing recognition that disruption to services such as payments, clearing, or market access could destabilize markets even when firms themselves remained financially viable. Stability could no longer be inferred solely from balance sheets. It depended on whether essential services continued to operate under stress.

This language did not impose requirements on institutions. Instead, it provided a shared lens that national regulators could adapt to their own authority and institutional context. The translation of that framing is visible in how operational resilience has since been codified or enforced across jurisdictions.

In Europe, this translation occurred through formal regulation. Concerns articulated at the global level around operational dependency, third-party concentration, and service continuity later surfaced in the European Union’s Digital Operational Resilience Act. DORA does not simply address cybersecurity. It establishes expectations around information and communication technology risk, outsourcing, and systemic concentration in third-party service providers. Global framing became enforceable structure.

In the United States, the same global concerns emerged through a different mechanism. There is no single operational resilience statute equivalent to DORA. Instead, language around operational dependency and critical services has surfaced through supervisory guidance, examination focus, and enforcement posture across multiple regulators. U.S. authorities increasingly evaluate whether institutions can maintain access to critical services, manage concentration in third-party providers, and recover predictably from operational disruption. Terminology differs. Expectations converge.

The contrast is instructive. Europe translated global concepts into harmonized rules. The United States translated the same concepts into supervisory consequence without a unified rulebook. In both cases, global bodies shaped vocabulary and priorities, while national authorities determined form. Convergence occurred through translation rather than command.

VIII. Executives as the Integration Layer

Operational resilience does not reside neatly within technology, risk, or compliance functions. It emerges at the intersection of business strategy, architecture, governance, and accountability. Executives who own revenue-generating services ultimately own the consequences of disruption.

This integration role cannot be delegated. Decisions about architecture, sourcing, and service design shape resilience outcomes long before incidents occur. Leadership must reconcile risk appetite with operational tolerance, global dependency with local responsibility, and regulatory expectation with technical reality.

As supervisory regimes converge on outcomes rather than artifacts, attention shifts from documentation toward evidence. Resilience becomes a property of how systems are designed and governed, not how convincingly they are described.

IX. The Baseline Is Set, and Differentiation Has Shifted

Across jurisdictions, regulators are converging on a shared expectation: critical services must continue under stress, and that continuity must be demonstrable. This is no longer an emerging standard or a regional experiment. It is the operating baseline for institutions whose services are systemically important.

What has changed is not the existence of resilience programs, but the narrowing of discretion around how resilience is judged. Supervisors, boards, and markets increasingly distinguish between organizations that can articulate preparedness and those whose systems behave predictably when stressed. Regulatory compliance now functions as a baseline condition rather than a differentiator. Performance under stress is what establishes credibility.

This shift reflects a lasting change in how resilience is evaluated. As global expectations continue to converge, organizations will not differentiate themselves by how carefully they frame compliance, but by how predictably their systems perform under stress. Operational resilience is no longer a characteristic to be declared or a program to be described. In this environment, leadership is revealed not through policy or posture, but through whether critical services continue when assumptions fail.