Technological failure at a systemically important retail bank

Impact 5
4
upper risk error bar
3
upper likelihood error bar
risk indicator
lower likelihood error bar
2
lower impact error bar
1
1
2
3
4
5
Likelihood
ID 31a
Risk theme Accidents and system failures
Impact & Likelihood
Impact key
5 Catastrophic
4 Significant
3 Moderate
2 Limited
1 Minor
Likelihood key
5 >25%
4 5-25%
3 1-5%
2 0.2-1%
1 <0.2%

Background

The increasing digitisation of financial services means that a technological failure of IT systems could result in customers being unable to access key account functions and important information, including online banking. The financial regulators’ operational resilience policy requires finance sector organisations to ensure their critical business services are resilient to severe but plausible scenarios, including technological failures.

This supervisory framework covers financial market infrastructures (FMIs) and Other Systemically Important Institutions (O-SIIs), critical to the UK’s financial stability, who must also consider their risks in relation to harm their institution may cause to the real economy and financial services sector as a whole.

Scenario

The reasonable worst-case scenario is based on a technological systems failure that renders a systemically important retail bank’s critical technology inoperable, with a partial outage for 2 days thereafter. Potential immediate impacts would include customers being unable to view account balances, process payments, use online banking or withdraw cash from ATMs. Account data may also be compromised. Online and mobile customers would be locked out of their accounts, with some experiencing disruption in the weeks that follow.

Long-term disruption to consumer-facing banking would impact consumer confidence. The outage would disrupt critical government services for several hours, with longer-term impacts felt for weeks. This would impact people’s ability to buy necessary goods, travel to and from work and pay for basic utilities. The most significant impact would be felt by vulnerable customers with only a single bank account. The bank would also likely face heightened fraud and operational losses.

Key assumptions

This scenario assumes that the technical fault directly impacts the IT operations of a UK critical national infrastructure bank, and that the firm’s impact tolerances (the maximum tolerable level of disruption) are surpassed. This scenario assumes that the technical fault directly the IT operations of a UK critical national infrastructure bank, and that the firm’s impact tolerances (the maximum tolerable level of disruption) are surpassed.

Variations

Technological failure of a UK critical financial market infrastructure.

Response capability requirements

Local and national plans to deal with a surge in demand for consumer-facing financial services where online and mobile banking services are offline. Collective incident response capability is managed under the UK's Authorities’ Response Framework (ARF).

Recovery

Depending on the severity of the technological failure, a full systems recovery could be protracted. Recovery would involve interim actions to provide customer payments and fixing the affected technological systems. Some customers could experience disruption once the technical issue has been fixed as backlogs are cleared.