Operational resilience has become a top priority for regulators worldwide. From the EU’s DORA and Network and Information Security Directive 2 (NIS2) to the UK’s FCA / Prudential Regulation Authority (PRA) guidelines, UAE’s DFSA and Central Bank of the UAE (CBUAE) frameworks, Australia’s Australian Prudential Regulation Authority (APRA) CPS 230, and India’s Cybersecurity and Cyber Resilience Framework (CSCRF), firms are facing an increasingly complex web of requirements.
While some regulations take a broad approach and others target specific risks, they all share one goal: strengthening resilience against disruptions. But meeting these expectations across multiple jurisdictions is no small task. Different timelines, reporting standards, and resilience obligations make compliance a significant challenge for global organizations.
The following outlines the applicable requirements and the steps we recommend to address them efficiently.
Understanding the Major Regulations Driving Resilience
While global regulations share common pillars, they vary significantly in scope and specificity. Rather than reviewing each framework independently, we’ve outlined the core components more regimes address, and where they align or diverge.
| Component/ Requirement | EU DORA | EU NIS2 | UK’s FCA/PRA | The SEC's 2026 Exam Priorities | UAE’s CBUA and DFSA |
|---|---|---|---|---|---|
| Scope/ Coverage | Applies to financial entities such as banks, insurers, and investment firms, with a strong focus on Information and Communication Technology (ICT) risk management. | Covers “essential” and “important” entities across 18 critical sectors (e.g., energy, healthcare, finance, transport). | Includes banks, PRA-designated firms (those posing systemic risk), and insurance companies regulated in the UK. | Applies to Investment Advisers (IAs), Investment Companies (ICs), broker-dealers, and clearing agencies’ key players in U.S. financial markets. | Covers licensed banks and Authorized Market Institutions (AMIs) operating within the DIFC. |
| Risk Management Framework | Requires a prescriptive ICT risk management framework with continuous monitoring and evaluation. Firms must identify, assess, and mitigate ICT-related threats proactively. | Focuses on broad cybersecurity risk management across critical sectors. Less prescriptive than DORA, allowing flexibility in how organizations implement controls. | Emphasizes operational resilience for all types of disruptions (not just ICT). Driven by Important Business Services (IBS), firms must ensure continuity of critical services under stress scenarios. | Adopts a principle-based approach to governance, covering cyber risks and AI. | Requires a board-approved operational risk strategy supported by robust systems and internal controls. Firms must ensure resilience against ICT failures and operational disruptions. |
| Incident Reporting | Requires reporting of major ICT-related incidents such as system outages or cyberattacks. Timeline: Initial report within 4 hours (or within 24 hours of detection), an update within 72 hours, and a final report within 1 month. | Covers significant cybersecurity incidents like ransomware attacks or Distributed Denial of Service (DDoS) attacks. Timeline: Early warning within 24 hours, detailed report within 72 hours, and final report within 1 month. | Applies to operational incidents that impact financial stability or compromise data integrity. Timeline: Under FCA/PRA notification, no fixed timeline, but proposed that Initial Report within 24 hours, and final report within 30–60 working days. | Focuses on material cybersecurity events, including breaches and vendor-related issues. Timeline: No fixed deadlines, but firms must report promptly under Regulation S-P and S-ID, with timely escalation expected. | Requires reporting of cyber/data breaches and AML suspicious transactions. Timeline: Cyber breaches immediately; AML suspicious transactions should be filed without delay (or 24 hours if urgent); other material incidents without delay. |
| Resilience Testing | Requires continuous resilience testing, including Threat-Led Penetration Testing (TLPT), vulnerability assessments, and tabletop exercises to simulate real-world attack scenarios. | Emphasizes vulnerability management and security hygiene but is less prescriptive about formal resilience testing requirements. | Mandates scenario-based testing to validate impact tolerances for Important Business Services (IBS). Firms must conduct self-assessments and stress tests to ensure operational continuity. | Focuses on testing the effectiveness of cybersecurity controls, including ransomware response drills and vendor risk assessments. | Requires Disaster Recovery (DR) and Business Continuity Planning (BCP) to be formally approved and resourced. IT systems must undergo stress testing to ensure resilience under extreme conditions. |
| Third-Party/ Outsourcing | Requires maintaining an inventory of all third-party providers, conducting due diligence before engagement, ensuring contractual resilience clauses, and ongoing monitoring of outsourced services. | Mandates supply chain security and vendor risk management to prevent vulnerabilities introduced by external providers. | IBS tolerances apply even when services are outsourced, meaning firms must ensure continuity and resilience through third-party arrangements. | Focuses on vendor governance, including ransomware response planning and breach management protocols for outsourced services. | Requires DFSA approval for material outsourcing arrangements and mandates continuity planning and data security measures for outsourced functions. |
| Information Sharing | Encourages sharing of threat intelligence among financial entities to improve collective resilience against cyber risks. | Establishes Computer Security Incident Response Teams (CSIRTs) and promotes cross-border coordination for cybersecurity incident handling and information exchange. | Focuses on knowledge sharing through lessons learned from operational disruptions and resilience testing, helping firms improve preparedness. | Requires governance and board-level oversight of cyber and data-related issues, ensuring that information flows effectively within the organization. | Promotes continuous updates and alignment with international standards for cybersecurity and operational resilience, fostering collaboration and best practices. |
| Governance and Oversight | The board is accountable for ICT risk resilience and must ensure that technology risks are managed effectively across the organization. | Management holds responsibility for cybersecurity and interacts with CSIRTs to coordinate incident response and resilience measures. | Boards are required to set up IBS and define impact tolerances, while also investing in capabilities to maintain operational resilience. | Requires board and senior leadership oversight of cyber and data resilience, ensuring governance structures are in place to manage emerging risks. | Strong audit functions are mandated, along with measures for liquidity and safeguarding of client assets, ensuring robust governance and operational integrity. |
Your Trusted Cybersecurity Partner
Navigating evolving global resilience requirements such as DORA, NIS2, and FCA/PRA expectations requires more than technology alone. ACA Aponix® helps firms strengthen cyber resilience, meet regulatory obligations, and reduce operational risk through tailored advisory and managed solutions spanning cybersecurity, continuity, and third-party risk management.
Aponix Protect™
Aponix Protect is a comprehensive patch management solution designed to identify, prioritize, and remediate vulnerabilities before they can be exploited. It supports secure backup environments, reduces attack surfaces, and helps firms proactively manage cyber risk across their infrastructure.
Business Continuity and Incident Response Review
ACA develops a customized Business Continuity Plan (BCP) that defines roles, communication protocols, training requirements, and evacuation procedures, while also conducting a comprehensive review of your recent cyber incident response. Together, these efforts identify preparedness gaps, strengthen response capabilities, and provide actionable recommendations to enhance operational resilience during disruptions.
TPRM Program Review
ACA offers a TPRM Program Review, which evaluates the design and effectiveness of your third-party risk management program through documentation review and stakeholder interviews. Our assessment delivers clear findings and actionable recommendations to help improve oversight, reduce concentration risk, and align with regulatory expectations.
Regulatory Readiness Assessment
ACA performs a tailored Regulatory Readiness Assessment against the applicable regulation to evaluate your current state, identify gaps, and provide guidance on required documentation, evidence, and controls, helping you meet regulatory expectations.
Strengthen your cybersecurity framework today and learn how ACA can help you meet regulatory expectations while building lasting operational resilience.
Watch our recent webcast, Operational Resiliency and Evolving Regulatory Expectations, for additional insights from ACA experts.