Enhancing Business Continuity with Live Downtime Simulations

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In the evolving regulatory landscape, the Digital Operational Resilience Act (DORA) has introduced stringent requirements to ensure financial institutions can withstand, respond to, and recover from IT disruptions. 

The intent behind DORA is to harmonise existing legislation and supplement existing gaps with the introduction of new regulations to establish a unified digital framework whereby firms ensure they can adapt and endure all types of ICT-related disruptions and threats, to prevent and mitigate cyber threats.

As of 2025, DORA mandates robust operational resilience frameworks that include regular simulations and testing of business continuity plans, through to threat-led penetration testing and other resilience testing exercises in line with the TIBER-EU framework. This shift highlights the growing importance of proactive preparation against potential downtime or disasters.

Forward Emphasis’ Case Study as a BPO-fit for Seamless Compliance and Simulation Readiness 

Our client, a regional financial authority, requires end-to-end service resilience testing on a bi-annual basis, requiring rapid-response scale and training of net-new teams to act as first responders to customer queries. This simulation is an assessment of service response, if primary customer support should be compromised because of systems outages, cyber threat, liquidation, or other downtime.

In our simulation, our response teams mirror customer support in the event of organisational liquidation that would impact the deposit guarantee scheme, established under Irish and European legislation to protect depositors in the event of a bank, building society or credit union being unable to repay deposits.

An intensive training programme fast-tracks the response team knowledge on all details of the scheme, as well as systems training, to be able to handle and process queries and requests from simulated affected depositors who need support to host payment queries. Hundreds of simulated calls are tested via the team, from multiple European countries and across a spectrum of 75 query types, followed by complex case management, THBs, exceptions and payments, and receipt of completed and their accompanying documentation (utility bills, death certs, grants of probate, solicitor letters, decisions from official liquidator and account managers).

Detailed Simulation Readiness and Execution

Process, knowledge and systems access are stress tested to identify vulnerabilities, refine response protocols, and ensure seamless recovery in the event of disruption, with remediation of all issues identified via re-testing or revalidation. 

Results and Feedback

Forward Emphasis leveraged its proven simulation playbook to support the needs of our client, with an operational simulation model which satisfies the DORA-defined requirements for penetration testers – being of highest suitability and reputability, possess technical and organisational capabilities in penetration testing, adhere to formal codes of conduct or ethical frameworks, and provide independent assurance concerning the sound management of risks associated with the carrying out of threat-led penetration testing.

Through the simulation exercise, Forward Emphasis helped the client to prove out a series of compliance checks required as a regulatory service provider:

  1. Risk Assessment: Identify critical processes, systems, and potential points of failure within the operational framework.
  2. Scenario Development: Craft realistic scenarios that reflect possible IT outages, cyber incidents, or natural disasters.
  3. Cross-Department Collaboration: Engage IT, risk, compliance, and operational teams to ensure comprehensive testing.
  4. Response Evaluation: Measure the effectiveness of response times, communication protocols, and system recovery during the simulation.
  5. Refinement and Documentation: Adjust business continuity plans based on insights gained from simulations and ensure compliance documentation is up to date.

Upon completion of the simulation, the results from the Forward Emphasis teams are shared via attestation reports and summary of findings. Where needed, details of remediation plans are produced for compliance and operations teams to determine resilience and vulnerability. 

The Value of BPO Partnerships for Compliance Simulations

Looking beyond annual testing, under DORA, threat-led penetration testing of critical systems is mandatory every three years, covering live production environments at costs starting from €7k for smaller firms. Retesting is required if vulnerabilities are found.

In today’s interconnected financial ecosystem, resilience drives survival and competitive edge. BPO partnerships can streamline compliance, ensuring readiness through proactive simulations and safeguarding operations against evolving threats.

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