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[OR] [CAPM] [BNM] Operational Resilience Capability-level Assessment Aligned to Bank Negara Malaysia

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Malaysia FlagThis chapter contains a comprehensive Operational Resilience Capability Assessment Questionnaire tailored for banks in Malaysia, aligned to:

  • The 2025 Bank Negara Malaysia Operational Resilience Discussion Paper (emerging regulatory expectations) 

  • BCM Institute OR planning methodology ([OR] [P1-S1]) 

  • Capability assessment principles from BCM Institute and BCMPedia 

The questions are structured to reflect BNM’s emphasis on governance, critical services, interdependencies, technology, and third-party risks, as well as increasing accountability and resilience integration 

Moh Heng Goh
Operational Resilience Planner-Specialist-Expert

New call-to-actionOperational Resilience Capability Assessment (BNM-Aligned)

OR PM Plan Assess Capability and Maturity

BCMPedia Operational Resilience

This chapter contains a comprehensive Operational Resilience Capability Assessment Questionnaire tailored for banks in Malaysia, aligned to:

  • The 2025 Bank Negara Malaysia Operational Resilience Discussion Paper (emerging regulatory expectations) 

  • BCM Institute OR planning methodology ([OR] [P1-S1]) 

  • Capability assessment principles from BCM Institute and BCMPedia 

The questions are structured to reflect BNM’s emphasis on governance, critical services, interdependencies, technology, and third-party risks, as well as increasing accountability and resilience integration 

New call-to-actionemphasis on:

  • Sustaining critical business services (CBS)
  • Ability to prevent, respond, recover, and adapt to disruptions
  • Strong governance, accountability, and interdependency management
  • Focus on customer impact and systemic stability

 

1. Governance, Oversight and Accountability

Board and Senior Management Oversight
  • Has the Board formally approved an Operational Resilience framework and strategy?
  • Is there a clearly designated accountable executive (e.g., CRO / Head of OR)?
  • Does the Board receive regular reporting on resilience posture and disruptions?
  • Are resilience objectives integrated into enterprise risk management (ERM)?
Policy and Governance Structure
  • Are there documented policies covering:
    • Operational resilience
    • Business continuity
    • Crisis management
    • Third-party risk management
  • Are governance roles clearly defined across the three lines of defence?
Culture and Accountability
  • Are KPIs/KRIs aligned to resilience outcomes (not just compliance)?
  • Is there evidence of cross-functional accountability for critical services?

 

2. Identification of Critical Business Services (CBS)

  • Has the bank formally identified Critical Business Services (CBS)?
  • Are CBS defined based on:
    • Customer impact
    • Financial stability impact
    • Regulatory expectations
  • Are CBS clearly distinguished from:
    • Processes
    • Systems
    • Functions
CBS Governance
  • Are CBS owners formally assigned?
  • Are CBS definitions periodically reviewed and approved?

 

👉 BNM emphasises that resilience must focus on critical services and customer impact, not just internal recovery

 

3. Impact Tolerance and Service Resilience Objectives

    • Has the bank defined impact tolerances for each CBS?
    • Are tolerances measurable (e.g., downtime, backlog, data loss)?
    • Are tolerances aligned with:
      • Customer expectations
      • Regulatory requirements

  • Are tolerance breaches:
    • Monitored
    • Escalated
    • Reported to senior management

 

4. Mapping Interdependencies (End-to-End Visibility)

Dependency Mapping
  • Has the bank mapped dependencies for each CBS across:
    • People
    • Processes
    • Technology
    • Third parties
Connectivity and Complexity
  • Are interconnections between systems and services documented?
  • Are single points of failure identified and mitigated?
Data and Documentation
  • Are mapping outputs:
    • Documented
    • Maintained
    • Regularly updated

👉 BNM highlights complex interdependencies and digital ecosystems as a key resilience challenge

 

5. Scenario Testing and Resilience Validation

Scenario Design
  • Are severe but plausible scenarios (SbPS) defined?
  • Do scenarios include:
    • Cyber incidents
    • Technology failures
    • Third-party disruptions
    • Pandemic/people's unavailability
Testing Execution
  • Are scenarios tested against:
    • CBS
    • Impact tolerances
  • Are tests conducted:
    • End-to-end
    • Across business and technology layers
Outcomes and Improvement
  • Are test results:
    • Documented
    • Reviewed by senior management
  • Are lessons learned translated into:
    • Control improvements
    • Capability enhancements

 

6. Technology and Cyber Resilience Capability

    • Are critical systems supporting CBS:
      • Redundant
      • Recoverable within tolerance

    • Is there alignment with:
      • Cyber resilience practices
      • Technology risk management frameworks

  • Are cloud and digital dependencies:
    • Identified
    • Risk assessed
Monitoring and Detection
    • Are real-time monitoring capabilities in place for:
      • System performance
      • Disruptions

  • Are early warning indicators defined?

 

7. Third-Party and Supply Chain Resilience

Third-Party Risk Management
  • Are third parties supporting CBS identified and classified?
  • Are critical vendors subject to:
    • Enhanced due diligence
    • Contractual resilience requirements
Concentration and Substitution Risk
  • Are concentration risks (e.g., single cloud provider) assessed?
  • Are exit and substitution strategies defined?
Integration into Testing
  • Are third parties included in:
    • Scenario testing
    • Crisis exercises

👉 BNM stresses the importance of third-party and ecosystem resilience due to increasing reliance on outsourcing and cloud

 

8. Incident Management and Crisis Response Capability

  • Is there a formal incident management framework?
  • Are escalation protocols clearly defined?
  • Is there an established crisis management structure (e.g., command centre)?
Communication Capability
    • Are communication plans defined for:
      • Customers
      • Regulators
      • Stakeholders

  • Are communication protocols tested?

 

9. Recovery, Continuity and Adaptation Capability

    • Are business continuity plans:
      • CBS-aligned (service-centric, not process-centric)?

  • Are recovery strategies:
    • Tested regularly
    • Aligned with impact tolerances
Adaptive Capacity
  • Can the organisation:
    • Operate in degraded mode?
    • Prioritise critical transactions?

 

10. Data, Metrics and Continuous Improvement

Metrics and Monitoring
  • Are resilience KPIs/KRIs defined for:
    • CBS availability
    • Incident response time
    • Recovery performance
Continuous Improvement
  • Is there a structured process for:
    • Lessons learned
    • Post-incident reviews
  • Are improvements tracked and reported?

 

11. Integration Across Risk Domains (Holistic Capability)

  • Is operational resilience integrated with:
    • Operational risk management
    • Business continuity management
    • Cyber resilience
    • Third-party risk management
Enterprise Alignment
  • Is resilience embedded into:
    • Strategic planning
    • Technology transformation
    • Product development

👉 BNM emphasises holistic and enterprise-wide resilience, not siloed practices

 

12. Capability Level Assessment (Scoring Dimension)

 

Maturity Rating Guide (Scoring Model)

 Use a 7-level maturity scale: 

New call-to-actionFor each question, assign:

  1. Level 0: Undefined: No evidence of capability 

  2. Level 1: Initial: Informal, inconsistent practices

  3. Level 2: Managed: Defined but not consistently applied 

  4. Level 3: Defined: Documented and consistently implemented 

  5. Level 4: Well-defined: Measured, monitored, and controlled 

  6. Level 5: Optimising: Continuously improved and integrated  

  7. Level 6: Innovative: Industry leadership through innovation.



How to Use This Capability Assessment

OR Capability Assessment BCMPediaStep 1: Assess Capability
  • Evaluate each question
  • Assign capability level (0–6)
Step 2: Identify Gaps
  • Focus on:
    • CBS definition gaps
    • Dependency visibility gaps
    • Testing weaknesses
Step 3: Align to BNM Expectations
  • Prioritise:
    • Governance accountability
    • End-to-end service resilience
    • Third-party risk integration

 

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Key Takeaways (Aligned to BNM Direction)

This capability assessment reflects BNM’s shift toward:

  • Service-centric, end-to-end, and accountable operational resilience

  • Banks are expected to move beyond traditional BCM into:

  • Integrated resilience capabilities

  • Customer-impact driven design

  • Continuous testing and improvement

 

 

 

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