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[OR] [MBT] [E3] [CBS] [7] [ITo] Establish Impact Tolerances

Written by Moh Heng Goh | Dec 2, 2025 1:33:07 AM

CBS-7 Digital and Online Banking Services

In line with operational resilience requirements, establishing impact tolerances for Metrobank’s Critical Business Service (CBS-7): Digital and Online Banking Services is essential to ensure that the bank can withstand, respond to, and recover from disruptions within acceptable levels.

Impact tolerance refers to the maximum level of disruption a critical service can withstand before intolerable harm occurs to customers, the financial market, or regulatory compliance.

Given that digital banking services form the backbone of Metrobank’s customer interactions and transactions, understanding and quantifying acceptable disruption thresholds—measured in Maximum Tolerable Downtime (MTD) and Maximum Tolerable Data Loss (MTDL)—is vital.

These tolerances are established through scenario testing, impact analysis, and stakeholder engagement, aligning with the principles outlined in the Bangko Sentral ng Pilipinas (BSP) Operational Resilience Framework and the broader financial industry’s resilience expectations.

The following table outlines the impact tolerances for each sub-component of CBS-7, detailing operational limits, customer and regulatory implications, and required improvement actions.

Table P4: Establish Impact Tolerance for CBS-7

Sub-CBS Code

Sub-CBS

Maximum Tolerable Downtime (MTD)

Maximum Tolerable Data Loss (MTDL)

Customer Impact

Regulatory Impact

Impact Type

Current Resilience Status

Action Required

7.1

Online Banking Platform Management

2 hours

< 15 minutes

Loss of account access; service interruption to retail and corporate users

Non-compliance with BSP circulars on digital access

High

Robust redundancy and DRP are tested quarterly

Enhance cross-site failover automation

7.2

Mobile Banking Application Services

2 hours

< 15 minutes

Loss of mobile transactions and app login failures

Reputational and regulatory exposure due to service unavailability

High

Stable, with mobile DR tested semi-annually

Increase mobile app uptime monitoring to real-time

7.3

Digital Account Access and Authentication

1 hour

< 5 minutes

Inability to authenticate; customer lockout

Breach of security and authentication regulations

Very High

Multi-factor auth system in place

Implement biometric backup and secondary ID verification

7.4

Online Funds Transfer and Payment Processing

1 hour

< 5 minutes

Failure of real-time payments; delay in fund availability

Non-compliance with BSP instant payment obligations

Very High

High availability and transaction mirroring

Introduce AI-based transaction rerouting

7.5

Digital Customer Onboarding and e-KYC

4 hours

< 30 minutes

Inability to onboard new customers digitally

Breach of e-KYC and AML obligations

Medium

KYC system integrated with the central ID database

Automate the fallback offline verification process

7.6

Digital Customer Support and Service Channels

4 hours

< 30 minutes

Disruption to customer inquiry resolution

Reputational and customer confidence impact

Medium

Chatbot and email redundancy exist

Expand IVR fallback and agent escalation protocols

7.7

Card-Not-Present (CNP) and e-Commerce Transaction Processing

1 hour

< 5 minutes

Payment failures on online purchases

Reputational and financial loss exposure

Very High

Strong payment gateway redundancy

Improve coordination with acquiring network partners

7.8

ATM and Electronic Channel Management

2 hours

< 10 minutes

ATM withdrawal failures; disruption in card services

BSP consumer protection compliance impact

High

Multiple ATM networks supported

Upgrade real-time ATM transaction monitoring

7.9

Cybersecurity and Fraud Monitoring for Digital Channels

30 minutes

< 1 minute

Unmonitored fraud activity; delayed detection of attacks

Severe regulatory breach; data privacy violation

Critical

24/7 SOC and threat analytics are active

Deploy AI anomaly-based fraud detection

7.10

Digital Banking Data Management and Reporting

4 hours

< 30 minutes

Delay in reporting and analytics for digital ops

Regulatory reporting breach; delayed decision-making

Medium

Centralized data warehouse in place

Implement real-time data replication across the DR site

 
 
 

Setting impact tolerances for Metrobank’s Digital and Online Banking Services (CBS-7) ensures that critical digital operations remain within acceptable disruption thresholds to maintain customer trust, market stability, and regulatory compliance.

These tolerances serve as measurable benchmarks for testing resilience and guiding investment in infrastructure, cybersecurity, and recovery capabilities.

By defining clear operational limits (MTD/MTDL) for each sub-service, Metrobank can prioritize resilience enhancements based on service criticality.

The continuous monitoring, scenario testing, and improvement of these tolerances will strengthen Metrobank’s ability to respond swiftly to cyber incidents, system outages, and third-party disruptions, ensuring sustainable digital banking continuity and customer confidence in a highly connected financial ecosystem.

 

Building Resilient Banking Operations: The Metrobank Operational Resilience Implementation Guide

eBook 3: Starting Your OR Implementation
CBS-7 Digital and Online Banking Services
CBS-7 DP CBS-7 MD CBS-7 MPR CBS-7 ITo CBS-7 SuPS CBS-7 ST
  

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.

 

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