What if the PA/FSCA Joint Standard is not a cybersecurity standard?

It is a prudential risk and resilience standard. Cybersecurity is simply the mechanism regulators use to test whether a financial institution can:

• prevent material disruption,

• detect incidents early,

• respond decisively, and

• recover within acceptable business tolerances.

That distinction matters……

In supervisory reviews, most compliance failures are not technical failures. They are operational failures:

• controls exist on paper but are not embedded into day-to-day operations,

• responsibilities are unclear between IT, risk, and third parties,

• detection, response, and recovery capabilities are untested in practice.

Smaller financial institutions often misinterpret control intent by focusing on:

• tools instead of outcomes,

• policies instead of evidence,

• outsourcing instead of accountability.

The Joint Standard does not reward complexity. It rewards demonstrable operational resilience aligned to the institution’s size, risk profile, and dependency landscape. “Cyber” is not the objective, resilience is.

If any of this resonates with challenges you are seeing in your organisation, get in touch.