MAS impact tolerances — what changed, what to do next
MAS's refreshed expectations on impact tolerances are clearer than they look. A practitioner's read of the consultation response.
MAS's response to the recent consultation on operational resilience tightened expectations around how impact tolerances are derived, tested, and reported. Several themes are clear.
Tolerances must be linked to specific intolerable harms — financial stability, consumer detriment, market integrity. Generic recovery time objectives no longer satisfy. Severe-but-plausible scenarios are expected to include cross-border and intra-group dependencies, with an explicit assumption that primary recovery options may not be available.
What to do next: revisit your important business service inventory, retest tolerances against the new scenario set, and prepare to evidence both the test and the board's discussion of the results.
