[OR] [GCash] [E3] [CBS] [1] [ST] Perform Scenario Testing

Chapter: Perform Scenario Testing for CO-1 Digital Wallet Operations

Introduction

Scenario Testing is one of the most important validation activities within an Operational Resilience programme because it provides objective evidence of whether a Critical Operation can continue to operate within its defined Impact Tolerance when exposed to Severe but Plausible Scenarios.

Rather than focusing solely on technology recovery or business continuity plans, Scenario Testing evaluates the coordinated response of people, processes, technology, information, facilities, third parties, and governance across the complete end-to-end service.

For GCash's CO-1 Digital Wallet Operations, the previously identified Severe but Plausible Scenarios provide the foundation for designing realistic Scenario Tests. Each test is mapped to a specific Sub-Critical Business Service (Sub-CBS), while also assessing how disruption propagates across interconnected business processes and supporting capabilities.

The recommended testing programme integrates Cyber and ICT Risks throughout every scenario. Cyberattacks, cloud outages, API failures, telecommunications disruptions, data integrity failures, and third-party service interruptions are treated as embedded components of operational disruption rather than isolated technology events.

This integrated approach enables GCash to assess its ability to maintain Digital Wallet Operations within its approved Impact Tolerance while identifying resilience gaps, validating governance, and supporting continuous improvement.

The uploaded prompt specifies that the programme should include end-to-end testing, integrated cyber and ICT risk considerations, measurable objectives, auditable evidence, and regulatory alignment with BSP Circular No. 1203 (Series of 2024).

Table 1 (Part 1): Scenario Testing Programme

Sub-CBS Code	Name of Sub-CBS	Severe but Plausible Scenario	Recommended Scenario Test	Testing Method	Scenario Testing Objective	Key Scenario Injects / Disruption Conditions	Interconnections and Interdependencies Tested
CO-1.1	Digital Wallet Registration and Provisioning	DDoS attack on onboarding platform	Customer onboarding resilience test	Cyber incident simulation with API resilience testing	Validate the ability to continue onboarding customers during sustained cyber disruption.	Customer registration failures, API latency, surge in onboarding requests	Customer onboarding, identity verification, CRM integration, network infrastructure
CO-1.2	Customer Identity Verification and Account Validation	National identity verification service outage	Identity verification continuity exercise	Third-party disruption exercise with tabletop escalation	Assess continuity of customer verification when external identity services become unavailable.	External KYC service unavailable, communications delays, manual verification activation	Identity providers, compliance operations, fraud management, customer onboarding
CO-1.3	Wallet Funding and Value Loading	Banking connectivity failure	Payment channel resilience test	Integrated business and technology simulation	Validate continued customer funding using alternative banking channels.	Primary banking interface unavailable, payment gateway degradation, increased transaction retries	Banking interfaces, payment gateways, treasury operations, settlement services
CO-1.4	Wallet Balance Management	Ledger database corruption	Data integrity validation exercise	Data integrity and reconciliation test	Demonstrate the ability to detect, isolate and restore accurate wallet balances.	Database corruption, inconsistent balances, recovery from replicated database	Transaction processing, reconciliation, customer account management
CO-1.5	Payment Transaction Processing	Ransomware affecting payment processing	Integrated payment resilience exercise	Cyber incident simulation combined with disaster recovery test	Validate end-to-end payment continuity during a major cyber incident.	Payment processing failure, ransomware encryption, failover activation	Merchant ecosystem, fraud controls, banking connectivity, customer services
CO-1.6	Funds Transfer and Settlement Processing	National payment settlement disruption	Settlement continuity exercise	Integrated business and technology simulation	Assess settlement capability when external clearing services are unavailable.	Settlement delays, banking network outage, liquidity management decisions	Banking institutions, clearing houses, treasury, reconciliation
CO-1.7	Transaction Authorisation and Risk Controls	Authentication platform compromise	Fraud and authentication resilience exercise	Cyber incident simulation	Validate secure customer authentication while maintaining fraud prevention capability.	Authentication failures, privileged account compromise, fraud alerts	Identity management, fraud monitoring, cybersecurity operations
CO-1.8	Merchant Payment Enablement	Merchant platform capacity exhaustion	Merchant payment stress exercise	Capacity and stress test	Validate payment performance during sustained peak transaction demand.	Transaction surge, API congestion, merchant payment delays	Merchant platforms, acquiring partners, payment APIs

Table 1 (Part 2): Scenario Testing Programme

Sub-CBS Code	Name of Sub-CBS	Severe but Plausible Scenario	Recommended Scenario Test	Testing Method	Scenario Testing Objective	Key Scenario Injects / Disruption Conditions	Interconnections and Interdependencies Tested
CO-1.9	Digital Wallet Service Integration Management	Enterprise API Gateway Failure combined with Cloud Connectivity Degradation	Enterprise Integration Resilience Exercise	API resilience test combined with integrated business and technology simulation	Validate that Digital Wallet Operations continue despite failure of multiple API services and cloud-hosted integration components.	API gateway failure, cloud latency, multiple external interface failures, degraded middleware performance	Banking APIs, merchant systems, payment gateways, settlement platforms, cloud infrastructure
CO-1.10	Customer Transaction Notification and Communication	Nationwide Telecommunications Service Disruption	Customer Communication Continuity Exercise	Walk-through combined with third-party disruption exercise	Assess GCash's ability to communicate with customers using alternative channels during telecommunications disruption.	SMS gateway outage, mobile network degradation, delayed push notifications	Telecommunications providers, notification platforms, customer support, fraud alert services
CO-1.11	Transaction Monitoring and Operational Surveillance	Failure of Monitoring Platform and Security Event Collection	Operational Monitoring Validation Exercise	Technical recovery test with cyber incident simulation	Validate detection capability when monitoring systems become unavailable while operational incidents continue to develop.	SIEM failure, monitoring dashboard outage, delayed operational alerts, loss of security logging	SOC, operational monitoring, technology operations, cybersecurity monitoring
CO-1.12	Exception Handling and Transaction Resolution	Large-scale Failed Transaction Backlog	Customer Resolution Surge Exercise	Integrated business simulation	Assess operational capability to manage high volumes of failed transactions while maintaining acceptable customer service levels.	Surge of failed transactions, duplicate payments, high complaint volumes, manual investigation workload	Customer service, payment operations, reconciliation teams, fraud management
CO-1.13	Financial Reconciliation and Operational Reporting	Data Integrity Failure during End-of-Day Reconciliation	Financial Integrity Recovery Exercise	Data integrity and reconciliation test	Validate the organisation's ability to restore accurate financial records following data corruption.	Corrupted settlement files, reconciliation mismatches, delayed reporting deadlines	Finance, accounting, settlement services, regulatory reporting
CO-1.14	Operational Incident Management	Major Cyber Incident with Escalation Failure	Crisis Coordination Exercise	Crisis management exercise integrated with cyber incident simulation	Assess executive decision-making, governance effectiveness and cross-functional coordination during a major cyber crisis.	Ransomware attack, communication failures, delayed escalation, executive decision points	Crisis Management Team, Executive Management, Technology Operations, Cybersecurity, Communications
CO-1.15	Service Recovery and Operational Restoration	Simultaneous Failure of Primary and Disaster Recovery Environments	End-to-End Service Recovery Exercise	Disaster recovery test combined with end-to-end Critical Operation scenario test	Validate recovery of Digital Wallet Operations within the approved Impact Tolerance following catastrophic infrastructure failure.	Primary site unavailable, disaster recovery replication failure, regional infrastructure disruption, prolonged service outage	Disaster Recovery infrastructure, cloud services, network providers, business operations, customer services

Table 2: Expected Resilience Outcomes and Evidence

Sub-CBS Code	Name of Sub-CBS	Cyber and ICT Risk Linkage	Impact Tolerance Boundary Tested	Expected Resilience Outcome	Evidence to be Collected	Proactive Risk Management Action	Evidence of Proactive Risk Management
CO-1.1	Digital Wallet Registration and Provisioning	DDoS attack, API disruption	Ability to maintain customer onboarding within acceptable service levels	Customer onboarding continues using resilient infrastructure with minimal disruption.	Test plans, API monitoring logs, DDoS mitigation reports, onboarding performance metrics	Strengthen DDoS protection, API redundancy and onboarding scalability	DDoS testing reports, API resilience testing, capacity assessments
CO-1.2	Customer Identity Verification and Account Validation	Third-party ICT outage	Maximum acceptable onboarding delay	Customer verification continues using contingency verification procedures.	Third-party outage records, KYC processing times, manual verification logs	Diversify identity verification providers and strengthen contingency arrangements	Supplier assurance reports, resilience testing results
CO-1.3	Wallet Funding and Value Loading	Banking gateway failure	Maximum disruption to customer funding capability	Alternative banking channels restore funding capability before Impact Tolerance is exceeded.	Banking interface logs, transaction completion rates, failover timing	Enhance payment routing resilience and banking redundancy	Banking connectivity testing, failover exercise reports
CO-1.4	Wallet Balance Management	Database corruption, ransomware	Financial data integrity	Accurate wallet balances restored without material customer impact.	Database recovery logs, reconciliation reports, integrity validation results	Implement immutable backups and continuous integrity monitoring	Backup restoration reports, integrity testing results
CO-1.5	Payment Transaction Processing	Cyberattack, ransomware, application failure	End-to-end payment processing continuity	Critical payment processing remains within approved Impact Tolerance.	Transaction success rates, recovery times, cyber incident logs	Improve cyber resilience, active-active processing and automated failover	Cyber exercise reports, disaster recovery tests, penetration testing
CO-1.6	Funds Transfer and Settlement Processing	Settlement platform outage	Maximum settlement delay	Settlement processing resumes without systemic financial disruption.	Settlement backlog reports, recovery metrics, reconciliation records	Improve settlement contingency arrangements and liquidity planning	Settlement testing reports, contingency exercise documentation
CO-1.7	Transaction Authorisation and Risk Controls	Authentication compromise	Customer authentication availability and fraud prevention effectiveness	Legitimate customer access maintained while preventing fraudulent transactions.	Authentication success rates, fraud monitoring reports, SOC logs	Enhance privileged access management and adaptive authentication	Identity management reviews, cyber simulation reports
CO-1.8	Merchant Payment Enablement	Capacity exhaustion, API overload	Merchant transaction availability	Merchant payment services remain operational despite high transaction volumes.	Transaction latency reports, API utilisation metrics, merchant availability reports	Improve capacity planning, auto-scaling and merchant API resilience	Capacity testing reports, infrastructure monitoring
CO-1.9	Digital Wallet Service Integration Management	API gateway failure, cloud outage	End-to-end integration continuity	Critical interfaces recover automatically or fail over with minimal customer impact.	API performance reports, failover timing, cloud monitoring dashboards	Strengthen integration resilience and diversify technology concentration	Cloud resilience assessments, architecture reviews, API failover testing
CO-1.10	Customer Transaction Notification and Communication	Telecommunications disruption	Timeliness of customer communications	Customers continue receiving essential notifications through alternative channels.	Notification delivery reports, customer communication logs	Implement multi-channel communications and resilient messaging platforms	Communication resilience testing, third-party service reviews
CO-1.11	Transaction Monitoring and Operational Surveillance	Monitoring platform failure	Time to detect operational degradation	Critical incidents remain detectable through redundant monitoring capabilities.	SOC dashboards, incident detection timelines, monitoring logs	Implement redundant monitoring infrastructure and independent alerting	Monitoring resilience tests, SOC exercise reports
CO-1.12	Exception Handling and Transaction Resolution	Operational overload	Customer dispute resolution within acceptable timeframes	High transaction exception volumes managed without exceeding customer service thresholds.	Case resolution statistics, operational dashboards, customer service reports	Improve automation, surge staffing and workflow prioritisation	Operational readiness reviews, workflow testing results
CO-1.13	Financial Reconciliation and Operational Reporting	Data corruption	Financial reporting integrity	Accurate reconciliation completed within regulatory reporting timelines.	Reconciliation reports, audit trails, reporting validation	Strengthen automated reconciliation and integrity controls	Financial control testing, audit reports
CO-1.14	Operational Incident Management	Cyberattack and communication failure	Executive response and crisis coordination effectiveness	Effective governance, rapid escalation and coordinated decision-making maintained throughout the incident.	Crisis decision logs, executive briefings, incident timelines	Strengthen crisis governance, communication resilience and executive exercises	Crisis management exercise reports, governance reviews
CO-1.15	Service Recovery and Operational Restoration	Disaster Recovery failure, regional infrastructure outage	Overall Impact Tolerance for CO-1 Digital Wallet Operations	Full restoration achieved within approved Impact Tolerance using resilient recovery arrangements.	Disaster recovery results, service restoration timelines, customer impact assessments	Enhance recovery architecture, recovery automation and resilience governance	Disaster recovery exercises, independent assurance reports, recovery capability assessments

Regulatory Considerations for Scenario Testing by a Philippine Banking Financial Services Institution (BFSI)

For a Philippine BFSI such as GCash, BSP Circular No. 1203 (Series of 2024) establishes the expectation that Operational Resilience arrangements should include the identification of Critical Operations, the establishment of Impact Tolerances, the mapping of important interconnections and interdependencies, and the use of Severe but Plausible Scenarios to validate resilience capabilities.

The Circular emphasises that scenario testing should provide management with assurance regarding the institution's ability to continue delivering Critical Operations during significant disruption while identifying vulnerabilities requiring remediation.

From an implementation perspective, GCash should design a structured Scenario Testing programme that:

Tests the end-to-end delivery of Digital Wallet Operations rather than individual systems or business units.
Incorporates operational, cyber, ICT, third-party, and crisis management scenarios that reflect realistic threats.
Defines measurable Impact Tolerance thresholds and success criteria before each exercise.
Involves cross-functional participation from business operations, technology, cybersecurity, risk management, business continuity, crisis management, compliance, internal audit, and critical external service providers where appropriate.
Collects comprehensive evidence, including decision logs, recovery metrics, customer impact assessments, system performance data, and lessons identified.
Uses post-exercise findings to update resilience strategies, technology architecture, business continuity plans, cyber response procedures, governance arrangements, and future investment priorities.

Banner [Summing] [OR] [E3] Perform Scenario Testing

Scenario Testing provides the practical mechanism through which GCash can validate the resilience of CO-1 Digital Wallet Operations under realistic and demanding operating conditions. By using Severe but Plausible Scenarios as the foundation for testing, the organisation moves beyond verifying individual recovery plans to assessing whether the entire Critical Operation can continue delivering services within its defined Impact Tolerance.

Testing each Sub-Critical Business Service while simultaneously challenging the interconnections between people, processes, technology, information, facilities, and third-party providers provides a comprehensive understanding of end-to-end operational resilience.

The integration of Cyber and ICT Risks throughout the testing programme further reflects the dependence of Digital Wallet Operations on digital infrastructure, cloud services, payment networks, telecommunications, and external ecosystem partners.

The evidence collected from Scenario Testing—including recovery performance metrics, cyber event logs, decision records, customer impact assessments, and after-action reviews—provides management and the Board with demonstrable assurance that resilience capabilities are functioning as intended or highlights where improvements are required.

These findings should be translated into targeted remediation actions, governance enhancements, technology investments, updated response procedures, and continuous improvement initiatives, ensuring that GCash's Operational Resilience programme remains effective, adaptive, and aligned with evolving business risks and regulatory expectations.

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Strengthening Operational Resilience at GCash: An Enterprise Implementation Guide

[OR] [GCash] [E3] [CBS] [1] [ST] Perform Scenario Testing

Operational Resilience Planner-Specialist-Expert

Chapter: Perform Scenario Testing for CO-1 Digital Wallet Operations

Introduction

Regulatory Considerations for Scenario Testing by a Philippine Banking Financial Services Institution (BFSI)

More Information About OR-5000 [OR-5] or OR-300 [OR-3]

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Strengthening Operational Resilience at GCash: An Enterprise Implementation Guide

[OR] [GCash] [E3] [CBS] [1] [ST] Perform Scenario Testing

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Introduction

Regulatory Considerations for Scenario Testing by a Philippine Banking Financial Services Institution (BFSI)

More Information About OR-5000 [OR-5] or OR-300 [OR-3]

Your Comments Here:

Chapter: Perform Scenario Testing for CO-1 Digital Wallet Operations