Ahmed Ashfaq

Critical services disruption: the importance of financial institutions’ ability to demonstrate their response and how

As of early 2026, cyber and operational resilience regulation in Hong Kong and Abu Dhabi Global Market (ADGM) has shifted from guidance‑led expectations (which offer flexibility as to how the regulated institution implements the regulation) to enforceable obligations. The differentiator is no longer about the number of policies in place, but whether an institution can produce audit‑ready evidence that statutory duties have been discharged under pressure – when facts are incomplete and reporting clocks are already running. This article sets out four practical pillars that increasingly determine supervisory outcomes: clock readiness (reporting within statutory guidelines), evidence readiness, privilege readiness and vendor readiness.