Your financial institution’s business continuity plan sits in a shared drive somewhere, probably labeled with the current year. Examiners didn’t say anything about it during your last exam. The board reviewed it at their annual meeting and nodded approvingly. Everything seems fine – until you actually need it.
Business continuity plans (BCPs) can quickly become outdated. Whether you add new technology, bring on new vendors, or change policies and procedures, each change introduces new vulnerabilities your current plan may not address.
To weather crises effectively, and be prepared for unexpected disasters, it’s important to continually assess whether your business continuity plan remains viable. Here are five indicators that should prompt an immediate review of your business continuity strategy.
1. Recovery Time Objectives Aren’t Accurate
Your RTOs should reflect today’s customer expectations, not assumptions from five years ago. If customers expect instant mobile access to their accounts 24/7, but your plan still allows for 12-hour outages of digital banking services, you’re working with outdated objectives.
If you’ve added new revenue streams, like commercial lending or wealth management services, your plan needs to account for the continuity requirements of these operations.
Gaps between perception and documentation signal it’s time for an update.
2. Major Technology Changes Aren’t Reflected
Cloud migrations, API integrations, artificial intelligence implementations, and digital banking platforms are reshaping how financial institutions operate.
If your institution has migrated critical systems to the cloud, your continuity plan should detail how you’ll maintain access if your cloud provider experiences an outage. Understand service level agreements, redundancy options, and data recovery procedures specific to cloud environments.
The same applies to artificial intelligence and automation tools. As financial institutions increasingly use AI, these systems become critical dependencies. What happens when your AI-powered fraud monitoring goes offline? How quickly can you revert to manual processes, and does your staff know how to execute them?
3. Your Vendor Inventory Has Shifted Significantly
Many business continuity plans still focus primarily on internal operations, with vendor dependencies treated as an afterthought. But vendors are now woven into nearly every core function of a financial institution. When a critical vendor goes down, the ripple effects can halt essential systems, delay customer service, and introduce unexpected regulatory and operational exposure.
Start by validating your vendor inventory. Make sure every active relationship — especially newly added or recently replaced vendors — is reflected accurately in your plan. Outdated inventories are one of the fastest ways for continuity plans to fail in real-world conditions.
From there, identify all critical vendors, document the services they support, and define what continuity looks like if each one experiences an outage. Outline your fallback processes, alternative workflows, and communication expectations so your team can act quickly and consistently. This becomes a living set of instructions that must be updated anytime a vendor relationship, dependency, or system integration changes.
The 2024 CDK Global cyberattack made this clear. When CDK’s dealer-management system was taken offline by a ransomware incident, auto dealerships across the country lost access to core functions like sales processing, financing workflows, service management, and customer communications. Many were forced to shift to manual workarounds for days or weeks, underscoring how a single vendor disruption can cascade through essential operations.
Events like CDK highlight why vendor dependencies must be explicitly reflected in a business continuity plan. When institutions understand which systems rely on which vendors—and what alternative processes exist — they’re in a better position to maintain operations when a third-party outage occurs.
A strong continuity plan doesn’t just acknowledge vendor dependencies — it integrates them into how the organization prepares for and responds to disruption.
4. Regulatory Expectations Have Evolved
Regulators increasingly expect continuity plans to be function-based, not simply event-based. Instead of planning for “a fire” or “a cyberattack,” supervisors want financial institutions to identify the critical functions they must deliver under any circumstance — and to demonstrate how those functions will continue when systems, vendors, people, or facilities are disrupted.
This shift aligns with modern operational-resilience guidance: map your essential business services, understand the dependencies that support them (people, processes, technology, data, and vendors), and build continuity strategies around preserving those capabilities.
If your plan is still organized around traditional scenarios like fires, floods, or power outages — with limited attention to how your institution will maintain core functions during cyber incidents, vendor outages, or technology disruptions — it’s behind the times.
Your plan should show how your institution will continue delivering its critical functions when key resources are disrupted — whether that’s technology, facilities, staff, data, or a third-party service. That means identifying the alternate processes, workarounds, and dependencies that support each function, and documenting how they activate during an interruption. It also includes clear escalation and communication expectations so leadership, employees, customers, and regulators know what to expect as the situation evolves.
Function-based planning ensures your institution can deliver what matters most — regardless of the specific event that triggers the disruption.
5. Testing Reveals Gaps, But the Plan Never Changes
One of the clearest indicators of an outdated continuity program is when exercises routinely surface weaknesses, yet the plan stays the same. If recurring issues show up test after test without being addressed, the plan stops functioning as a readiness tool and becomes a static document.
For instance, if a recent tabletop showed that key personnel were unsure how to access alternate communication channels, the follow-up shouldn’t end with meeting notes. The plan should be updated, responsibilities clarified, and staff given training or drills to reinforce those steps.
Continuity testing only improves resilience when the findings drive real updates. Otherwise, the same vulnerabilities reappear during the next disruption — only this time, they’re not hypothetical.
Your business continuity plan should be a living document that evolves with your institution, your technology, and your risk environment. The warning signs above are strong indicators that your plan may no longer match how your organization actually works today.
When was your plan last substantially updated? Who was involved in that review, and did it include voices from across the institution or just the compliance team? Most importantly, if a significant disruption happened tomorrow, would your team reach for your business continuity plan as a trusted resource, or would they improvise around it?
Using tools like business continuity solutions help you consistently manage your business continuity plans, simplifying planning, testing, recovery, and reporting. Platforms like Ncontracts make you more prepared for the next disaster.
Your plan doesn’t need to be perfect, but it does need to be current, tested, and genuinely useful — not just compliant on paper.
