One Strategy, Many Regulators - A Practical Guide for cyber Leaders in Financial Services
If you’re leading cyber in financial services, you already know that complying with the current international regulatory landscape is becoming more complex.
Whether it’s GDPR, DORA, NIS2, FCA, PRA, SEC, APRA CPS 230, HKMA guidelines, and now, the upcoming UK Cyber Resilience Bill, set to land later this year, alignment becomes a significant overhead for organisations. Each brings its own flavour, with different expectations, definitions, and timeframes.
Simultaneously, you’re asked to deliver a unified, risk aligned security strategy across the business. You need to build resilience, enable the business to move quickly, and be ready to answer to multiple regulators at once… no small task!
The average cost of a data breach in the UK climbed to £3.58 million between March 2023 and February 2024, with financial services often facing even greater costs, sometimes surpassing £5.4 million per incident (IBM, 2024)¹. However, this goes beyond regulatory penalties, and is also a consideration of lost business, customer trust, and ultimately, your ability to keep operating.
Why This Keeps Getting Harder
Most of us have been in environments where each new regulation triggers its own isolated response. One team reads the rules and starts designing controls, while another scrambles to update policies. Meanwhile, budgets are already set for the year, and security teams try to retrofit compliance into an existing plan.
We’ve seen:
Legal and cyber teams interpreting scope differently, especially with DORA
Delays to security enhancements because funding wasn’t secured in time
Business teams purchasing new tools without going through privacy or security review
Multiple assurance cycles for different regulators, burning time and resources
Add to that the rising cost of compliance. UK banks and fintech firms now spend roughly £21,400 per hour on financial crime and fraud compliance, pushing the annual regulatory bill to about £38.3 billion, which has increased by nearly a third since 2021 (Thomson Reuters, 2023) ². With compliance this expensive, a fragmented approach simply isn’t viable anymore.
As the Cyber Resilience Bill introduces new expectations around continuity and critical service recovery, these challenges are only going to intensify.
A Practical Way Forward
Regulations are continually changing, and it can feel impossible to keep on top of them all, but you can build a way to manage them better. In our combined 30+ years of experience at Cyro Cyber, here’s what we’ve seen work across multiple complex financial services environments:
1. Start with One Core Cyber Security Framework – A Strategic Anchor
Think of this as your strategic anchor, your north star. A core framework gives you a consistent language, a clear structure for your control environment, and a reference point for mapping incoming regulations. Most regulators don’t dictate how you meet their expectations, only that you do. Therefore, using a central framework stops duplication and inconsistency across regions and it becomes easier to assess maturity, track assurance, and prioritise investment.
How to choose:
NIST CSF works well for global organisations needing flexibility and modularity
ISO27001 is another international standard, which is ideal for organisations with strong governance and audit cultures
CAF (NCSC’s Cyber Assessment Framework) aligns closely to UK regulatory thinking, particularly for operational resilience
Many financial institutions benefit from using NIST CSF as the backbone, with overlays from ISO or CAF where local expectations require it. The key is to choose one and embed it across your cyber and risk functions. This will become your benchmark for control design, implementation, and evidence.
2. Map Regulatory Requirements to That Framework
Once your core framework is in place, every new regulation can be mapped to it. This avoids duplication, supports clearer reporting, and helps different teams work off the same model.
How to do it:
Break each regulation into control level statements
Map those to your framework, control by control
Identify any gaps in process, tooling, documentation or ownership
Record those gaps in a regulatory control register or GRC platform
Example:
If DORA requires IT resilience testing for critical systems, that aligns with NIST’s categories for incident response and system recovery. If you’re already testing for those, you only need to ensure the scope and evidence meet DORA’s expectations. If not, you’ve just surfaced an actionable gap.
This approach turns compliance into a structured enhancement of your existing programme, rather than an ad hoc project. It also reduces audit fatigue and makes your assurance processes far more efficient.
3. Build Clear, Reusable Regulatory Playbooks
You don’t need to build a new programme every time a new regulation drops. What you need is a modular playbook for each regulation that connects back to your core framework.
A strong playbook should include:
What’s in scope: systems, services, or functions
What’s different: any control requirements that go beyond your standard
What’s needed: specific documentation or audit artefacts
Who owns it: operational, cyber, and legal responsibilities
When it’s reviewed: update schedules and ownership for changes
For example, your DORA playbook might include your approach to major incident reporting, IT third party contract language, and testing protocols for critical services.
When the Cyber Resilience Bill takes effect, we recommend a UK specific playbook that aligns with its new expectations.
What should UK FS organisations review ahead of the Cyber Resilience Bill?
Here are the key areas likely to require attention:
Incident response protocols - are they timely, structured, and repeatable? Do they meet new reporting thresholds?
Third party dependencies - have you identified which outsourced services are critical? Are contracts clear on resilience expectations?
Resilience testing - are you regularly testing continuity of business services, not just infrastructure?
Board level engagement - can you show evidence of board oversight on cyber risk and resilience?
Operational continuity planning - do you have real world, validated plans in place to maintain critical operations during disruption?
Align Legal and Cyber, Early and Often
This is where things often fall apart. Legal reads the regulation and decides whether it applies. Cyber gets told the outcome, but not the rationale. That resultant gap leads to missed obligations or unnecessary work.
The solution? Joint ownership. Set up a regular working group that brings Legal, Cyber, GRC, and Privacy together. Review upcoming regulations collaboratively. Share tools and registers. Agree on how you decide scope, ownership, and response timelines.
These conversations matter more than ever with laws like the Cyber Resilience Bill. Interpreting “materiality,” “critical services,” and “reportable incidents” will require more than legal analysis. You need shared interpretation, based on real operational knowledge.
Bake Regulatory Requirements into Budget and Planning
Too often, compliance obligations show up late and aren’t funded. The business agrees it’s important, but the money has already been allocated elsewhere.
If you want to avoid that scramble, include regulatory foresight in your annual planning process. That means:
Keeping a regulatory horizon map that flags emerging obligations
Estimating resource impact for each one
Logging risks for any deferrals and assigning ownership
This shifts compliance from a reactive burden to a forecastable part of the security roadmap. It also helps make the case for budget, headcount, and tooling well ahead of deadlines.
Start With Clarity
You already know this space is complex, but there is possibly a better way to handle it.
Start with a strong, flexible framework, and map everything to it. Build clear playbooks that your teams can actually use. Bring Legal, Cyber, and GRC together before the rules hit your inbox. You’re probably doing a lot of this already, but without taking time to pause, reflect, and structure it, the value can get lost. Security leaders who bring order to the chaos are the ones who stay ahead.
At Cyro Cyber, we work with financial services organisations to cut through regulatory complexity and build cyber resilience that stands up to scrutiny. Whether you’re mapping multiple frameworks or preparing for the Cyber Resilience Bill, our team can help you design pragmatic, auditable, and effective strategies tailored to your risk appetite.
Get in touch to see how we can support you.
References
¹ IBM Cost of a Data Breach Report UK, 2024
² Thomson Reuters Regulatory Intelligence, 2023
