[OR] [BNM] [C1] Executive Summary of the BNM Discussion Paper

Chapter 1

Executive Summary of the BNM Discussion Paper

Context: BNM Operational Resilience Discussion Paper (Emerging Regulatory Expectations)

The BNM Discussion Paper establishes operational resilience as an outcome-focused capability, centred on a financial institution’s ability to continue delivering critical operations and services within tolerable limits under severe but plausible disruptions.

It reflects global regulatory convergence (BCBS, IAIS) and responds to Malaysia’s recent high-impact digital and third-party outages.

Key Themes Emerging from the BNM OR Consultative Paper

1. Disruptions are Inevitable

• • Prevention alone is insufficient; institutions must plan to withstand, adapt to, and recover from complex disruptions (cyber, cloud, third-party, climate, and infrastructure).

2. Focus on Critical Business Services and Operations

• • Not all activities are equal. Priority must be given to those whose disruption would cause intolerable harm to customers, markets, or financial stability.

3. End-to-end Dependency Visibility

• • Institutions must understand how people, processes, technology, data, facilities, and third parties interact and where failures can propagate.

4. Impact Tolerances over Internal Recovery Metrics

• • Traditional metrics (MTD, RTO) remain necessary but are no longer sufficient on their own; tolerances must reflect external harm and customer outcomes.

5. Severe but Plausible Scenario Testing

• • Testing must move beyond isolated failures to compound, concurrent, and systemic scenarios.

6. Strong Governance and Accountability

• • Boards must own operational resilience outcomes.
  • Clear senior management accountability (single accountable executive) is critical.

7. Continuous Learning and Improvement

• • Operational resilience is not a one-off compliance exercise but a continuous journey.

BCM Institute’s OR Planning Methodology (High-Level)

The BCM Institute’s Operational Resilience Roadmap integrates Operational Risk, Cyber Resilience, BCM, CM, Incident Response, third-party risk, and governance into a single, outcome-driven framework.

At a high level, the OR planning methodology follows these stages:

1. Define Critical Services / Outcomes
2. Identify Critical Business Services (CBSs)
3. Conduct CBS Business Impact Analysis (BIA)
4. Map Dependencies (end-to-end)
5. Set Impact Tolerances
6. Design Resilience & Recovery Strategies
7. Scenario Testing & Exercising
8. Governance, Assurance & Continuous Improvement

Direct Mapping: BNM Discussion Paper vs BCM Institute Methodology

Key Observations: Why the Two Are Highly Aligned

1. BCM as a Foundation, Not the Destination

In the 2025 BNM Discussion Paper on Operational Resilience,  BNM explicitly recognises that existing BCM, technology risk, outsourcing, and governance frameworks already contain resilience elements, but need to be reframed around outcomes

This mirrors the BCM Institute’s position that BCM is necessary but not sufficient for operational resilience.

2. Outcome-Focused Thinking

Both frameworks move away from:

• “Did we recover systems on time?”

Toward:

• “Did customers experience intolerable harm?”

This is a defining shift in modern operational resilience.

Dependency Mapping as the Cornerstone

BNM’s emphasis on deep visibility into interdependencies aligns with the BCM Institute’s roadmap, where dependency mapping bridges BIA and resilience strategy.

Governance as the Differentiator

BNM highlights governance quality—not technology alone—as the key differentiator between institutions that withstand disruption and those that fail. This reinforces the BCM Institute’s emphasis on:

• Board engagement
• Senior management accountability
• Cross-functional ownership

Practical Implications for Organisations Using the BCM Institute Methodology

For organisations already adopting the BCM Institute’s Operational Resilience Roadmap:

• You are directionally aligned with BNM’s emerging expectations
• No wholesale reinvention is required
• The key uplift areas are:
  • Stronger articulation of critical services
  • Clearer impact tolerances
  • More severe and compound scenario testing
  • Explicit board ownership of resilience outcomes

The BNM Discussion Paper effectively validates the BCM Institute’s operational resilience planning methodology from a regulatory perspective. It reinforces that:

Operational resilience is not a new discipline but a more integrated, outcome-driven approach to applying BCM, risk management, technology resilience, and governance.

Organisations that adopt the BCM Institute’s roadmap will be well-positioned to meet not only BNM’s future regulatory direction, but also broader global operational resilience expectations.

Note from Author/Speaker

Author Comment: This is a concise synthesis of the Bank Negara Malaysia (BNM) Discussion Paper on Operational Resilience and a clear mapping to the BCM Institute’s Operational Resilience Planning Methodology (Operational Resilience Roadmap).

Comparison with BNM OR Paper with BCM Institute's Operational Resilience Planning Methodology
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