A-P06 · TOPIC · cloud-and-outsourcingGRA dossier · service level R0
GRAFinancial Cyber and Operational ResilienceIn development
Topic dossier · Financial Cyber and Operational Resilience

Cloud and outsourcing

Financial firms run core services on cloud platforms and outsource operations to specialist providers. Outsourcing can improve resilience and security, and it also creates dependence on providers the firm does not control. This page sets out how cloud and outsourcing risks arise, how they are governed and measured, and who decides.

01In brief

The short answer.

Cloud and outsourcing risk is the risk financial firms take on when they run services on cloud platforms or rely on outsourced providers they do not control. It covers misread responsibilities, sector concentration, oversight rights and exit. Boards, supervisors, vendor managers and providers hold the decisions.

02Spatial finance

Settlement dependencies, and what fails with a node.

How a failure at one financial centre can spread through settlement links. Design links, not real dependencies.

Sixteen financial centres, and how a failure at one spreads through settlement links.Design links, not the real dependencies of any infrastructure.
03Console

Important business services, in outline.

The working screen behind this subject: its structure, terms and states. Names are placeholders and values illustrative.

Important business services

Cloud and outsourcing · Bank B services · Self-assessment 3

One service outside toleranceGRA · Financial Cyber and Operational Resilience

Services vs impact tolerance

Make a payment31Cloud region lossOutside
Access cash237Cyber attackWithin
Mortgage servicing4939Data centre lossWithin
Claims payment2670Third-party failureOutside

Dependency map

people · process · technology · third parties

Remediation

  1. R-1Second claims platform supplierExit plan tested93 d
  2. R-2Immutable backups for paymentsCyber recovery94 d
Important business services: the screen's structure, terms and states for Cloud and outsourcing.Placeholder names and illustrative values; a design, not a record or a live system.
04The question

Cloud and outsourcing: how the risk develops.

Concentration and resilience. The dossier below sets out how the risk develops, what is measured, where the data come from, how it is modelled and who decides.

Mechanism

Shared responsibility is misread

Cloud providers secure the platform; customers secure their configuration and data. Misunderstanding the split leaves gaps such as exposed storage.

Mechanism

Concentration across the sector

Many firms use the same few providers. An outage at one affects many firms at the same time.

Mechanism

Oversight depends on rights

Firms need audit, access and information rights in contracts. Without them, they cannot assess the provider or show supervisors they can.

Mechanism

Exit is slow

Moving a core service away from a provider can take years. Exit plans must be realistic and tested to be credible.

05Key terms

Terms used on this page.

Each term as this page uses it. Where a standard-setting body defines the term, the wording follows that body.

TermDefinition
Shared responsibility modelThe split of security duties between a cloud provider and its customer.
Material outsourcingAn outsourcing arrangement important enough to a firm's critical services to need extra governance.
Audit rightsContract rights allowing a firm and its supervisor to inspect a provider's controls.
06Indicators

What is measured, and how well.

Each indicator carries its unit, its cadence, the kind of source behind it and the evidence label a value would carry. No values are shown: a programme supplies them under its own authority.

IndicatorUnitCadenceSource typeLabel
Material outsourcing arrangementscountannualOutsourcing registersDECLARED
Critical services hosted on public cloudshare of critical servicesannualFirm and supervisory surveysREPORTED
Contracts with full audit and access rightsshare of material arrangementsperiodicContract reviewsDECLARED
Cloud misconfiguration incidentscountannualIncident recordsREPORTED
Exit plans testedshare of material arrangementsperiodicFirm recordsDECLARED
Provider outages affecting financial firmscount and durationannualIncident reportsOFFICIAL
07Canvas

From sources to decisions.

The topic as a computational graph: named sources feed the methods, an evidence review gates the outputs, and the decisions stay with the authorities that hold them.

Pipeline canvas · Cloud and outsourcing as a run graphDesign, not a record
Cloud and outsourcing: operational resilienceImportant business services are identified and impact tolerances set; people, processes, technology and third parties are mapped; severe but plausible scenarios test whether services stay within tolerance; vulnerabilities are remediated and the board self-assesses. Design of the process, not a record of a run.

Fig. 02Nodes carry their type, two metric rows and a state; connectors show what feeds what; dashed frames name the owners; the timeline is the cadence. Design of the pipeline, not a record of a run.

08Sources

Where the evidence comes from.

Named public datasets and institutional records, each with its licence class. Sources by agreement are used only under their terms and never republished.

SourceWhat it givesLicence class
EBA guidelines on outsourcing arrangementsEU expectations for bank outsourcingFree, EU reuse terms
PRA supervisory statement on outsourcing and third-party risk managementUK expectationsFree, Bank of England terms
FSB toolkit for third-party risk management and oversightCommon tools and termsFree, FSB terms
DORA register of information requirementsEU register of ICT third-party arrangementsFree, EU reuse terms
Provider post-incident reportsRoot causes of cloud outagesFree to read, terms per provider
09Decisions

Who decides, and what the evidence serves.

Financial Cyber and Operational Resilience prepares evidence. The decisions below are taken by the authorities named, under their own rules, and never by the platform.

Who decidesThe questionEvidence this page serves
Boards and senior managementWhich services to outsource and to whomRisk assessments, contract terms and concentration evidence
SupervisorsWhether outsourcing governance is adequateRegisters and contract reviews
Procurement and vendor managementWhich contract terms to requireRegulatory requirements and practice
Cloud and service providersHow to support customers' regulatory obligationsRegulatory expectations

Outputs this topic produces

  • Guide to the shared responsibility model
  • Comparative notes on outsourcing rules
  • Method note on exit planning and testing
  • Questions for boards on material outsourcing
10Core questions

What concentration analysis asks.

  • How many important services across the sector depend on the same provider, region or service?
  • Can a firm exit a provider or switch to another in a crisis, and how long would it take?
  • How visible are a provider's own dependencies, including its sub-contractors?
  • How do contracts allocate responsibility for security, recovery and information during an incident?
11Mechanisms

Benefits and concentration.

Concentration is the paradox at the heart of this topic. Each firm moving to a well-run provider may become more resilient, while the sector as a whole becomes more dependent on that provider.

Benefits

Scale and expertise

Large providers can invest in security and redundancy beyond what most firms can afford alone.

Concentration

Shared failure

An outage or compromise at a major provider can affect many firms at once.

Lock-in

Exit difficulty

Proprietary services and data volumes make switching slow and costly.

12Methods and limits

How concentration is studied.

  1. 01

    Dependency and concentration mapping

    Aggregating which services rely on which providers, using network science. Limits: firm-level data is sensitive and incomplete.

  2. 02

    Exit planning analysis

    Studying feasibility of exit and substitution. Limits: plans are rarely tested at scale.

  3. 03

    Contract review

    Comparing contractual terms for audit, information and recovery. Limits: contracts are confidential.

  4. 04

    Outage scenario analysis

    Exploring provider failure scenarios, using resilience engineering. Limits: illustrative.

13Methods

How it is studied, and what the methods cannot say.

14Questions

Questions and answers.

What is the shared responsibility model?
The division of security duties between a cloud provider, which secures the underlying platform, and the customer, which secures its own configuration, identities and data.
What makes an outsourcing arrangement material?
Its importance to the firm's critical services; definitions in each regime set criteria such as the effect of failure on customers and the firm.
Why test exit plans?
Because an untested plan may assume capacity, data portability or time that is not available when a provider fails or must be replaced.
Is cloud less safe than in-house systems?
Not in general. For many firms it improves security. The systemic concern is concentration across the sector, not the safety of cloud as such.
Can a firm outsource its accountability?
No. Firms remain responsible for services they outsource, under supervisory expectations.
Does the platform name concentrated providers?
No. It describes patterns and does not name or rate providers.
Is multi-cloud the answer to concentration?
It can reduce dependence on one provider but adds complexity and cost, and some services are hard to run across providers. It is one option among several.
Financial Cyber and Operational Resilience

Bring your expertise to this field.

The current service level is R0: information and enquiries. An enquiry receives a reference and names the next step; applications, payments, compute allocations and registrations open only when their team, terms and review capacity exist.

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