A Shift in Regulatory Focus

In 2021, the Financial Conduct Authority (FCA), Bank of England, and Prudential Regulation Authority (PRA) jointly published their final Operational Resilience Policy Statement (PS21/3). It marked a turning point.

For the first time, regulated firms were required to move beyond documentation and demonstrate an ability to remain within their impact tolerances during severe but plausible disruptions. By March 2025, most firms must have completed a full cycle of testing and remediation — and be ready to evidence that resilience is not only designed, but functioning.

The shift is clear: resilience is no longer theoretical. It must be observable

What the FCA Now Expects

Under PS21/3, the FCA sets out five key requirements:

1. Identify Important Business Services
   Firms must determine which services, if disrupted, could pose intolerable harm to customers or market integrity.

2. Set Impact Tolerances
   Organisations must define thresholds for maximum tolerable disruption (e.g. duration or extent of service loss).

3. Map Supporting Processes and Systems
   This includes people, technology, third parties, and facilities that underpin each critical service.

4. Scenario Testing
   Firms are expected to test their ability to remain within impact tolerances using severe but plausible scenarios.

5. Governance and Self-Assessment
   Boards must actively oversee resilience, with annual internal reviews and documentation ready for supervisory engagement.

Why Simulation Matters

Black Swan Labs is designed first and foremost to help leadership teams prepare for disruption — but it's more than a testing facility. The space will also provide resilience-ready meeting rooms and secure workspaces that can be used during periods of operational stress, whether triggered by digital, physical, or reputational events.

With independent internet connectivity and contingency power infrastructure under consideration, the facility is being developed with continuity in mind. Teams should have the option to relocate key decision-making activities quickly — without losing access to communications, data, or clarity..

Bridging the Gap Between Policy and Practice

Resilience frameworks can’t be measured solely by the clarity of the document — they must be tested against human, technical, and spatial realities. This is especially true in sectors where response speed and command structure matter.

Black Swan Labs is built to support both sides of the challenge:

• Stress-testing plans and people before disruption

• And providing a resilient space to operate through it

We don’t replace your framework. We give it room to perform — under pressure, and in practice.