The UK's financial regulators are redefining operational resilience by integrating financial and detailed impact metrics into impact tolerances, pushing firms to adopt more sophisticated risk assessment and management strategies ahead of the 2025 deadline.
The UK's approach to regulatory frameworks around operational resilience marks quite a significant shift—moving away from just ticking boxes toward truly safeguarding customers, maintaining market integrity, and ensuring firm stability. The FCA, PRA, and other regulators in the financial space have emphasized that operational resilience is more than simple compliance; it’s about defining clear boundaries on acceptable levels of disruption—called impact tolerances—beyond which damage becomes intolerable.
Now, these rules officially kicked in on 31 March 2022, and they require firms to identify their key business services and set impact tolerances. These tolerances basically describe the maximum level of disruption each service can endure during severe but plausible scenarios. By the time 2025 rolls around, firms are expected not only to set these impact thresholds but also to thoroughly map, test, and prove their ability to operate within them. This includes spotting vulnerabilities early and preparing communication plans to manage disruptions effectively when they happen.
Traditionally, impact tolerances were mostly expressed in terms of time—like how long a service can be down before causing unacceptable harm. Still, relying on time alone is starting to seem a bit limited. The overall financial impact and broader operational consequences of disruptions can go well beyond simple time measures—especially in today’s interconnected financial systems. For instance, a mid-sized asset manager once tested their client-facing app and found that an outage lasting a week could lead to losses of over £30 million—not exactly what they expected based on their initial 8-hour recovery estimate and 2-day impact tolerance. Such insights make one really question how firms should assess financial impact alongside operational downtime. It’s eye-opening, right?
Leading consulting firms and advisory services have responded by developing tools that quantify impact tolerances more deeply. Take WTW’s Risk Tolerance Clarified (RTC) tool, which is a good example. This tool essentially translates an organization’s financial priorities—like budget limits, cash flow targets, or risk appetite—into specific, measurable disruption thresholds. The idea is to bring risk management closer to actual business performance. This empowers risk officers and treasury teams to work together more effectively, using solid data to make smarter decisions. Back to the earlier example, if costs during an outage surpass £19 million by day four, that could seriously threaten liquidity and financing options—so integrating financial impact into resilience planning becomes critical.
Furthermore, both the FCA and PRA have started emphasizing that impact tolerances should consider more granular, multidimensional metrics. Instead of just time and money, they suggest that firms also look at other factors, such as what percentage of customers are affected. It’s about capturing the nuanced effects of operational hiccups. For firms that are regulated by both agencies, meeting both sets of requirements—sometimes with slight differences—adds another layer of complexity but ultimately helps better protect clients and markets.
The Bank of England’s supervisory approach makes this even clearer, highlighting that resilience isn’t just about individual firms surviving disruptions—it's also about managing the risks that come from how tightly interconnected the financial system has become. Their policy underscores that impact tolerances are crucial tools in safeguarding not just firms but the entire ecosystem against operational shocks.
Practical frameworks and step-by-step models from PwC and others also exist to help firms define, test, and implement these impact tolerances. These guide organizations in translating the sometimes abstract regulatory expectations into concrete, manageable resilience strategies—kind of like a bridge between theoretical risk limits and what is practically achievable.
All in all, the evolution of operational resilience regulations points to a broader shift in risk management. It’s not just about time-bound measures anymore; instead, firms need to understand and quantify the operational and financial impacts of disruptions in a much more sophisticated way. This shift pushes them to recalibrate their strategies, making sure their resilience measures are both comprehensive and precisely aligned with the real-world operational and financial risks they face.
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Source: Noah Wire Services
Verification / Sources
- https://www.wtwco.com/en-us/insights/2025/09/operational-resilience-how-are-you-determining-your-impact-tolerances - Please view link - unable to able to access data
- https://www.fca.org.uk/firms/operational-resilience - The Financial Conduct Authority (FCA) outlines the importance of operational resilience for firms, financial market infrastructures, and the financial sector. Firms are required to identify their important business services, set impact tolerances, and ensure they can operate within these tolerances during disruptions. The rules came into force on 31 March 2022, with firms expected to perform mapping and testing to remain within impact tolerances by 31 March 2025. This includes identifying vulnerabilities and developing communication plans for service disruptions.
- https://www.forvismazars.com/uk/en/industries/financial-services/regulatory-insights/operational-resilience-final-rules-and-guidance - Forvis Mazars discusses the Prudential Regulation Authority (PRA) and FCA's definitions of impact tolerances, which are the maximum tolerable level of disruption to an important business service. Firms must express impact tolerances using time-based metrics, such as a maximum tolerable duration of disruption, and consider additional metrics like the percentage of the customer base impacted. Dual-regulated firms may need to set separate impact tolerances to address the objectives of both the FCA and PRA.
- https://www.bankofengland.co.uk/prudential-regulation/publication/2021/march/operational-resilience-impact-tolerances-for-important-business-services-ss - The Bank of England's Supervisory Statement 1/21 outlines the policy objective to improve the resilience of firms and the wider financial sector to operational disruptions. It addresses risks from the interconnectedness of the financial system and the complex environment in which firms operate. The policy requires firms to set impact tolerances for each important business service and ensure they can remain within these tolerances during severe but plausible disruptions.
- https://www.pwc.co.uk/industries/financial-services/insights/how-to-set-and-test-impact-tolerances.html - PwC UK provides guidance on setting and testing impact tolerances, a concept introduced by UK financial services regulators in 2018. The article offers a five-step model for defining and testing impact tolerances, including a worked example and specific examples for financial services firms. It also compares risk appetite and impact tolerance fundamentals, aiming to help firms understand and implement these concepts effectively.
- https://www.fca.org.uk/news/press-releases/building-operational-resilience-impact-tolerances-important-business-services - The FCA, Bank of England, and PRA published a shared policy summary and coordinated consultation papers on new requirements to strengthen operational resilience in the financial services sector. Firms and financial market infrastructures are expected to identify important business services, set impact tolerances, and take actions to remain within these tolerances during severe but plausible disruptions. The consultation period closed on 1 October 2020.
- https://www.fca.org.uk/publications/policy-statements/ps21-3-building-operational-resilience - The FCA, in collaboration with the Bank of England and PRA, published final policy statements on building operational resilience. Firms are required to identify their important business services, set impact tolerances, and perform mapping and testing to ensure they can operate within these tolerances during disruptions. The rules came into force on 31 March 2022, with firms expected to remain within impact tolerances by 31 March 2025.
Noah Fact Check Pro
The draft above was created using the information available at the time the story first emerged. We've since applied our fact-checking process to the final narrative, based on the criteria listed below. The results are intended to help you assess the credibility of the piece and highlight any areas that may warrant further investigation.
Freshness check
Score: 8
Notes: The narrative discusses the UK's operational resilience regulations, which came into force on 31 March 2022. The article was published on 10 September 2025, indicating a freshness of over three years. While the core information remains relevant, the specific examples and data points may be outdated. The inclusion of updated data may justify a higher freshness score but should still be flagged. (fca.org.uk)
Quotes check
Score: 7
Notes: The article includes a specific example of a mid-sized asset manager testing their client-facing app, revealing a loss of over £30 million from a week-long outage. This example appears unique to the article, with no exact matches found in earlier material. However, the lack of corroboration from other reputable sources raises questions about its authenticity. The absence of identical quotes suggests potential originality, but the lack of supporting evidence reduces the score.
Source reliability
Score: 9
Notes: The narrative originates from WTW, a reputable global advisory, broking, and solutions company. WTW's established presence and expertise lend credibility to the report. However, as the content is self-published, it may carry inherent biases, and the absence of external verification slightly lowers the score.
Plausability check
Score: 6
Notes: The article discusses the UK's operational resilience regulations, which came into force on 31 March 2022. The example of a mid-sized asset manager experiencing significant losses due to an outage aligns with plausible scenarios. However, the lack of corroboration from other reputable sources raises questions about the authenticity of the example. The absence of supporting detail from other reputable outlets and the lack of specific factual anchors (e.g., names, institutions, dates) reduce the score.
Overall assessment
Veredict (FAIL, OPEN, PASS): OPEN
Confidence (LOW, MEDIUM, HIGH): MEDIUM
Summary: The narrative provides a detailed discussion on the UK's operational resilience regulations, with a specific example of a mid-sized asset manager's loss due to an outage. While the source is reputable, the lack of corroboration for the specific example and the absence of supporting details from other reputable outlets raise concerns about the authenticity and originality of the content. The freshness of the information is over three years, which may affect its current relevance. Given these factors, the overall assessment is 'OPEN' with medium confidence.