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Resilience by Design

Financial services operating models and operational resilience

Financial services operating models are facing a growing need to modernise just as the regulatory push for operational resilience is reaching maturity. As parts of the world emerge from COVID-19, we believe that firms need to re-think their target operating models and integrate an operational resilience mindset into this work.

The recent regulatory push into Financial Services operational resilience is the closest regulators have yet come to scrutinising how a firm designs its internal operations. It is also a regulatory initiative that has rapidly gained momentum around the world as regulators become more alert to the risk that operational disruptions could pose just as significant a threat to the stability and soundness of the sector as financial ones.

Given all of this, firms will have to learn to live with continuous and rising regulatory scrutiny of the resilience of their operations. Financial Services operating models will have to adapt to this reality.

We believe that firms must consider the pressures of a post-COVID operating environment and the regulatory push for operational resilience hand-in-hand.

The financial services operating model

This report sets out our approach to the operating model and the challenges and opportunities that we see operational resilience presenting for it. We then propose an approach for how senior leadership can instil an operational resilience mindset into firm-wide operating model design.

Three principles for integrating an operational resilience mindset into operating model design

  1. Taking a consistent group-wide approach to integration
    Senior leadership needs to instil a common approach to operational resilience and operating model design throughout the group by creating a common set of objectives, a clear accountability structure for designing operating models that deliver important business services and a unified set of outcomes that operating model design choices should support. Done well, implementing this principle amounts to a group-wide cultural shift in thinking about operational resilience as a primary business objective.
  2. Prioritising action using impact tolerances
    Operational resilience considerations should take precedence in operating model design when particular operations support important business services. In such cases, teams need to understand how the applicable impact tolerance will affect the expected resilience of the service over time and be able to articulate how operating model changes made in that timeframe will support reaching that impact tolerance.
  3. Using testing to refine operating model design choices
    As more sophisticated, model-based, operational resilience scenario testing methods are developed firms should have the ambition not only to test service resilience periodically, but to deploy this testing to evaluate how proposed changes to the operating model could affect the firm’s ability to remain within its impact tolerance. This could pinpoint where additional investment, such as building substitutability, back-ups and redundancies, will be needed in order to proceed with operating model change.


Finally, we explain why we believe that resilient operating models will be a key competitive advantage for financial services firms in a post-COVID environment where efficiency, speed, and the digital delivery of services will be critical for firms’ success.Download the report

About the EMEA Centre for Regulatory Strategy


The Deloitte Centre for Regulatory Strategy is a powerful resource of information and insight, designed to assist financial institutions manage the complexity and convergence of rapidly increasing new regulation.

With regional hubs in the Americas, Asia Pacific and EMEA, the Centre combines the strength of Deloitte’s regional and international network of experienced risk, regulatory, and industry professionals – including a deep roster of former regulators, industry specialists, and business advisers – with a rich understanding of the impact of regulations on business models and strategy.

You can find more reports like this at, where you can also sign-up for our monthly risk and regulation newsletter.

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