Governance Briefing — March 31, 2025

Executive briefing: FCA Policy Statement PS21/3 and PRA SS1/21 set a 31 March 2025 deadline for firms to operate important business services within defined impact tolerances. The transition period ends on this date, requiring complete remediation of mapping, impact tolerance testing, and scenario response playbooks.

Key risk themes

• Supervisory scrutiny. FCA and PRA expect evidence that firms can remain within tolerances during severe but plausible disruptions.
• Third-party dependencies. Critical suppliers (cloud, payment processors) must be included in mapping and testing to avoid blind spots.
• Customer harm. Extended outages of important services without tolerance controls may trigger conduct and remediation obligations.

Operational priorities

• Mapping completeness. Finalize service maps, dependencies, and ownership for all important business services.
• Testing and remediation. Run scenario tests against tolerances, implement mitigations (capacity, failover, communications), and document results.
• Governance evidence. Prepare board-approved self-assessments and documented exception handling ahead of supervisory reviews.

Enablement moves

• Schedule joint exercises with critical third parties to validate tolerance adherence.
• Embed customer communications plans and regulatory notification triggers into incident runbooks.
• Refresh training for service owners on tolerance monitoring and metrics prior to the 31 March deadline.

Sources

• FCA PS21/3 operational resilience
• PRA SS1/21 and policy statement

Zeph Tech supports resilience self-assessments, testing, and board reporting ahead of the March 2025 deadline.

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