CurveBlock
The Financial Conduct Authority has set out an operational resilience regime that requires regulated firms to identify their important business services, set impact tolerances and undertake testing to ensure continuity through severe but plausible disruptions. For platforms handling digital securities this means mapping functions such as issuance, custody and corporate action processing, and understanding the knock‑on effects of an outage on retail holders and markets. Firms must show how they would restore services within acceptable timeframes and how they will communicate with customers during incidents.
Third‑party dependencies are central to resilience assessments. Many digital securities platforms rely on cloud infrastructure, custody providers, distributed ledger networks and specialised service vendors. The FCA expects firms to maintain governance over outsourcing arrangements, to conduct due diligence, and to have contingency plans where a supplier failure would breach an impact tolerance. Contractual protections, testing of failover arrangements and regular audits are typical mitigations.
Scenario testing must be proportionate and documented. Tests should cover cyber incidents, infrastructure failures, and operational errors that could affect issuance, ledger integrity, settlement and reconciliation. Regulators look for clear escalation paths, transparent customer communication protocols and evidence that lessons from tests are embedded into change controls. For retail investors in fractional digital shares, operational resilience underpins access to account information, the integrity of holdings and timely processing of corporate events; robust arrangements reduce the risk that technical failures translate into loss of access or value disruption.