Chapter 4
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Comparison with the Sustain Phase [P3] of the OR Planning Methodology
Overview: BCM Institute’s Implement Phase (OR-P2)
The Sustain phase is the third and final phase of the BCM Institute’s Operational Resilience Roadmap.
Once the resilience capabilities have been developed and implemented (P1 and P2), this phase ensures the program becomes an ongoing, embedded organisational capability rather than a one-time project.
Key activities (five stages) include:
- Introduce Cultural Change Management: Embed resilience thinking into organisational culture.
- Develop a Communication Strategy: Ensure clear internal and external communication regarding the roles and expectations of resilience.
- Implement Training and Awareness: Build skills and awareness across the organisation.
- Provide Self-Assessment: Conduct periodic self-assessments of operational resilience readiness.
- Conduct Independent Quality Review: Enable internal or independent review to sustain program effectiveness.
Summary: BNM Discussion Paper on Operational Resilience
BNM’s Discussion Paper is a consultative policy document outlining high-level principles and emerging expectations for financial institutions to strengthen operational resilience. It emphasizes:
- Maintaining continuity of critical financial services under severe but plausible disruptions.
- Understanding interdependencies, including people, processes, technology, and third parties, with a focus on customer and systemic impact.
- Governance and accountability at the Board and senior-management levels.
- Severe-scenario testing, impact tolerance, and continuous learning.
- Enhanced ecosystem coordination given digitalisation and outsourcing trends.
Unlike BCM Institute’s methodology (which outlines a structured planning and sustain lifecycle), BNM’s paper serves as a statement of regulatory expectations and principles rather than a step-by-step implementation guide.
Detailed Comparison: Sustain Phase vs. BNM Expectations
|
Sustain Phase Activity (BCM Institute) |
BNM Discussion Paper Direction/ Expectation |
Alignment / Key Differences |
|
[P3-S1] Introduce Cultural Change Management |
BNM calls for board-level accountability and a shift in mindset where operational resilience is a core business priority rather than an IT/risk silo. |
Strong alignment. Both frameworks emphasise the need for a cultural shift away from compliance-only thinking toward proactive resilience. BCM Institute embeds change management, whereas BNM highlights cultural enablers (e.g., leadership accountability). |
|
[P3-S2] Develop a Communication Strategy |
BNM implicitly expects clear communication, escalation during disruptions, and transparent reporting to stakeholders/regulators. |
Aligned in intent. BCM Institute formalises communication as a sustainable activity; BNM’s paper emphasises communication as part of governance and crisis management expectations. |
|
[P3-S3] Implement Training and Awareness |
BNM underscores the importance of skills and preparedness across functions for managing operational risk and resilience (not explicitly detailed but implied by governance and operational capability expectations). |
Aligned. BCM Institute’s explicit training and awareness stage complements BNM’s high-level expectations that institutions have competent, skilled staff capable of delivering resilience outcomes. |
|
[P3-S4] Provide Self-Assessment |
BNM expects ongoing self-evaluation and adaptation of frameworks (e.g., addressing gaps identified in severe-scenario testing and third-party risk exposures). |
Complementary. BCM Institute structures self-assessment as sustain activity to ensure the program remains relevant. BNM requires institutions to understand their own resilience gaps, but does not prescribe mechanisms for self-assessment. |
|
[P3-S5] Conduct an Independent Quality Review |
BNM’s broad expectations include independent oversight, such as internal audit, board assurance, and external reporting, particularly with respect to resilience and systemic stability. |
Partially aligned. BCM Institute provides an audit/review mechanism that supports the governance and assurance BNM indicates, although BNM doesn’t articulate specific review steps. |
Areas of Strong Convergence
Governance & Accountability as Enduring Program Elements
Both frameworks see governance as a continuous responsibility:
- BCM Institute embeds governance within sustainable activities, including communication, self-assessment, and independent review.
- BNM emphasises ongoing oversight by Boards and senior management—not only during planning and implementation.
Takeaway
Sustaining governance focus enables institutions to consistently respond to dynamic risk environments and regulatory expectations.
Continuous Improvement and Assurance
Both frameworks require ongoing evaluation and improvement:
- Self-assessment and independent review in BCM Institute’s Sustain phase embed a cycle of evaluation.
- BNM expects institutions to regularly reassess their resilience posture in light of new risks and test outcomes.
Takeaway
Continuous improvement assures that resilience measures remain appropriate as technology, third-party landscapes, and threat environments evolve.
Communication and Awareness
Communication isn’t just crisis response; it’s a sustainment function that ensures resilience roles are understood, expectations are clear, and lessons are shared — internally and externally.
BNM reinforces that communication to regulators, stakeholders, and customers during stress events is essential to preserve trust.
Takeaway
A sustained communication strategy bridges internal preparedness and external confidence — a key outcome of resilience.
Where BNM Goes Beyond BCM Institute’s Sustain Phase
|
BNM Emphasis |
What It Implies Beyond Sustainable Activities |
|
Ecosystem-Wide Coordination |
BNM emphasises coordination across the ecosystem (vendors, infrastructure, cross-institutional interdependencies)—an expectation that extends beyond internal sustain activities to include external collaboration and data sharing. |
|
Regulatory Reporting Expectations |
BNM’s consultation process implies institutions may be required to report resilience frameworks, test results, and governance evidence to regulators. BCM Institute maintains procedures for generating these artefacts, but doesn’t mandate a reporting format. |
|
Systemic Impact Orientation |
BNM focuses on protecting financial system stability, not just organisational continuity — this extends the sustainability agenda into macro-resilience planning. |
Practical Implications for Financial Institutions
If an institution uses the BCM Institute’s Sustain phase as the basis for its resilience program:
✔ Strong operational foundation: The activities in P3 cover key elements BNM expects in a mature resilience program (culture, training, assessment).
✔ Complement with ecosystem coordination: Embed processes for third-party and industry collaboration to satisfy BNM’s ecosystem resilience expectations.
✔ Embed regulatory reporting: Adapt sustain activities to include structured evidence and reporting ready for regulatory engagement.
✔ Link self-assessment with risk tolerance and test outcomes: Ensure self-assessment isn’t just a checklist but tied to BNM-style impact tolerances and scenario findings.
Summary Matrix
|
Sustain Phase Outputs |
BNM Operational Resilience Expectations |
Status |
|
Cultural Change Metrics |
Strong leadership, accountability mindset |
Aligned |
|
Communication Plans |
Transparent stakeholder communication |
Aligned |
|
Training Programs |
Competency building for operational risk |
Aligned |
|
Self-Assessment Reports |
Ongoing resilience evaluation |
Aligned |
|
Independent Quality Review reports |
Assurance and governance review |
Aligned |
|
Regulatory Risk & Ecosystem Reporting |
Systemic resilience reporting |
Goes Beyond |
Comparison with BNM OR Paper with BCM Institute's Operational Resilience Planning Methodology |
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| C1 | C2 | C3 | C4 | C5 |
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Gain Competency: For organisations looking to accelerate their journey, BCM Institute’s training and certification programs, including the OR-5000 Operational Resilience Expert Implementer course, provide in-depth insights and practical toolkits for effectively embedding this model.
More Information About Operational Resilience Course OR-5000 [OR-5] or OR-300 [OR-3]
To learn more about the course and schedule, click the buttons below for the OR-300 Operational Resilience Implementer [OR-3] course and the OR-5000 Operational Resilience Expert Implementer [OR-5] course.
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