Operational Resilience: Impact Tolerance Deadlines

Firms are now operating within their impact tolerances for important business services, and supervisory attention has shifted from whether tolerances were set to whether firms can evidence they would actually be met during a genuine disruption.

This is a harder test than the original mapping exercise. It requires firms to move beyond documented scenario testing toward genuine confidence that their operational response would hold up in practice — a distinction our research on operational resilience explores in more depth.

We recommend firms currently treat scenario testing as an ongoing discipline, not a completed milestone, and specifically test scenarios their own staff didn't help design.

This briefing reflects Alden Advisory's general commentary on a developing regulatory topic and is not legal or regulatory advice. Firms should seek specific guidance for their own circumstances.