The regulatory shift firms are underestimating
Across DIFC and ADGM, many regulated firms still structure IT risk around inherited distinctions. Cybersecurity is handled as a technical discipline focused on protection. Operational resilience is addressed separately, framed around recovery and continuity. Governance sits above both, approving frameworks and reviewing periodic reports.
This structure no longer reflects how DFSA and FSRA assess risk.
Supervisory attention has moved towards a single interpretation of technology risk, one that considers security controls and resilience outcomes together. Regulators focus on whether an organisation can remain within acceptable limits when controls are tested, degraded or fail.
The shift tends to surface gradually through audit questions, supervisory findings and remediation discussions. Firms often overlook it by continuing to optimise individual domains while giving less attention to how the overall control environment behaves under stress.
From incidents to impact
In regulatory terms, the significance of a cyber incident is increasingly assessed through its operational consequences.
An access failure, misuse of authority or loss of system trust may originate in the security domain. Regulatory concern arises when such events disrupt critical services, compromise data integrity or delay regulatory obligations.
DFSA and FSRA assessments follow this sequence closely. Attention moves from cause to consequence:
Which services were affected?
- Were predefined tolerances exceeded?
- How effectively did management respond?
- Was recovery timely, controlled and visible to senior oversight?
These questions sit at the intersection of security and resilience. They centre on preparedness, judgement and accountability rather than technical detail.
Identity as a governance concern
The convergence of security and resilience is especially visible in how regulators now view identity and access.
Many material incidents involve legitimate access used in unintended ways. From a supervisory perspective, identity systems represent points of organisational authority. They determine who can act, what can be changed and how quickly control can be restored.
Regulators therefore expect firms to understand:
- Whether loss of access could disrupt critical services.
- How authority is constrained during periods of uncertainty.
- Where accountability lies for access and recovery decisions.
Identity features prominently in resilience discussions because it concentrates operational risk in a way that boards are expected to recognise and oversee.
How audits now test leadership understanding
Recent DFSA and FSRA audits place growing emphasis on scenario-driven evaluation.
Auditors explore how leadership would respond when conditions deteriorate, examining escalation paths, decision rights and trade-offs between speed of recovery and control integrity.
This approach reveals misalignment that documentation alone cannot address. Organisations frequently discover that while responsibilities are understood within individual teams, expectations across technical, operational and governance layers remain uneven.
For boards, this reinforces the importance of oversight grounded in realistic scenarios rather than abstract assurance
Evidence of coherence, not activity
Looking ahead to 2026, regulators are expected to place greater weight on coherence across controls.
Evidence that carries authority demonstrates alignment:
• between security scenarios and resilience assumptions,
• between operational priorities and recovery decisions,
• between board-approved tolerance and actual capability.
Regulatory confidence is shaped by whether controls function as a system that behaves predictably under pressure.
Many organisations struggle at this level. Investment is often strong within individual control domains, yet weaker when those domains are viewed collectively.
What this means for senior oversight
For boards and executive management, the convergence of security and resilience reshapes oversight responsibilities. Technology risk now represents a continuous governance concern with direct implications for regulatory trust and organisational credibility.
For CIOs and CISOs, it requires framing technical decisions in terms of impact, tolerance and recoverability, allowing senior leadership to exercise informed judgement.
DFSA and FSRA supervision reflects how failures propagate in complex environments. Security and resilience are assessed together as a single control environment.
In IT compliance, this convergence is now established. It defines the audit baseline.
