Cyber Coordination Group insights 2025

Good and poor practice Published: 24/04/2026 Last updated: 24/04/2026

This is a summary of discussions held throughout 2025 with industry members of our Cyber Coordination Group (CCG) programme.

CCG members shared cyber resilience insights on 3 topics:

  • Incident response practices and recovery at scale.
  • Implications for cyber security of AI, quantum computing, and other emerging technology.
  • Insider risk management.

Our CCG programme brings together up to 140 firms. Members have contributed their insights into these topics, and we’ve included those that reflect what’s worked well for CCG members and the challenges they’ve found within their firms.

By publishing this, we’re not introducing any additional regulatory expectations – we’re making these insights available so that firms can consider them in the context of our existing expectations, learn from others, and strengthen their cyber resilience capabilities. 

Who this publication applies to

  • Cyber resilience leaders.
  • Operational resilience leaders.
  • Operational risk professionals.
  • Internal audit professionals.
  • Cyber resilience specialists.

Insights summary

1. Prepare senior managers for incident response

Active and sustained involvement from senior management in incident response exercises and testing materially improves organisational decision-making, clarity of communications, and confidence during live incidents.

2. Develop testing approach to strengthen preparedness

Robust testing – especially in live and sandbox environments – reveals operational nuances that tabletop exercises miss, strengthening preparedness for severe but plausible incident scenarios.

3. Be clear with third parties on roles and expectations

Effective third-party engagement remains essential yet challenging. 

Members emphasised the need for clearer contractual obligations, stronger supply chain transparency (especially around AI), and including key suppliers in response and recovery testing. 

This avoids priorities misaligning during a crisis. 

4. Build emerging technologies into your risk framework

AI adoption and post-quantum cryptography (PQC) migration need to be embedded within existing risk frameworks, supported by strong cryptographic hygiene and risk-based prioritisation, to manage transition challenges.

5. Managing insider risk

Insider risk management is most effective when considered enterprise-wide, combining behavioural analytics; strong access management; and clear, trust-building communication. However, remaining conscious of privacy obligations, monitoring complexity, and differing jurisdictional rules and laws are often important considerations to navigate.

Topic 1: Incident response and recovery

Members discussed approaches to incident response and recovery at scale, focusing on how they test their capabilities, prepare and train internal stakeholders, and develop plans to recover after a severe disruption.

Insights from CCG members on incident response and recovery

Maintain comprehensive service mapping

It’s important to maintain a detailed map of key personnel, technology assets, and third-party services to strengthen response capabilities.  

Effective mapping helped prioritise recovery actions and interdependencies and were linked to the scenarios used for exercising.  

This can help with developing the technology to support a minimum viable service, essential to recovery.

Broaden testing strategies

Sandbox testing is carried out in a controlled environment that replicates live systems. 

Testing in a sandbox as well as live systems helped members challenge assumptions more commonly found in tabletop formats. 

It also revealed operational nuances, which they then used to help improve cyber resilience planning. These included network configurations, or firewall dependencies that otherwise may only be identified during real incidents.

Develop severe but plausible scenarios

Developing a diverse set of severe but plausible scenarios is critical to robustly testing important business services (IBS).  

Members found resources such as the Cross Market Operational Resilience Group (CMORG) Dynamic Scenario Library valuable for developing scenarios that reflect a range of incident types and operational impacts.

Engage senior managers early

Senior management engagement from an early stage, including taking part in incident response exercises, was essential for strengthening response capabilities and embedding them across organisations.

If senior managers have rehearsed incidents, tested decision-making roles and escalation paths, they’ll be able to handle live incidents with more confidence and certainty. 

They can make decisions more quickly and communicate more clearly, resulting in a more coordinated and efficient response.

Early Warning service – NCSC

Many members reported benefits from subscribing to the National Cyber Security Centre's (NCSC) Early Warning service. Embedding it into their response planning delivered tangible benefits. It enhanced threat intelligence, enabled earlier detection, and provided additional time to assess exposure to the potential threat. 

Common challenges for incident response

Mapping dependencies

Members reported finding it hard to develop and maintain an accurate map of dependencies, particularly in complex, multinational organisations with complex technology environments. Instead, some have taken a more focused approach, mapping the systems that underpin the most critical components of their IBS rather than attempting high-level mapping.

Working with senior managers

Among those that have less established relationships with their board, securing early and effective senior manager or board-level engagement was often difficult, mainly because of availability and competing priorities. 

Members reported that the NCSC’s Cyber Security Toolkit for Boards was a valuable resource. It supported their messaging with independent guidance and provided a framework for governance discussions. It helped ensure that boards or senior managers considered cyber resilience in the context of existing governance responsibilities, in non-technical language, with clearly structured questions intended to enable confident discussions.

Third-party roles during incidents

It’s important to clearly understand the role of third parties during outages and where possible, introducing them into firms’ response and recovery testing. However, it can be difficult to engage third parties on incident response expectations and negotiate obligations where contractual requirements are limited or there’s no shared history of expectations.


Topic 2: Emerging technologies

Members discussed their firms’ approaches to adopting emerging technologies, including AI, and their implications for cyber resilience.

CCG discussions covered:

  • How members identify the right guidance.
  • How they’re preparing for the transition to post‑quantum cryptography (PQC).
  • Broader technological shifts shaping their cyber resilience strategies. 

Insights from CCG members on emerging technologies

Integrating AI-related risks

Firms are integrating AI related risks into existing governance frameworks. This maintains consistency and avoids fragmented processes. They are identifying all current as well as anticipated generative AI use cases and mapping them to existing risk categories. 

Establishing cryptographic hygiene

Establishing good cryptographic hygiene is an effective foundation for preparing for PQC migration. 

Organisations that practised good hygiene had cryptographic estates that were easier to map, had clear ownership of key lifecycle processes, and vulnerable assets that were simpler to identify. This shifts migration away from a broad discovery exercise to a targeted, risk-led programme. 

Use risk to prioritise migration

PQC migration is important, but because it’s long term and complex in nature, it’s beneficial to prioritise efforts and planning using a risk-based approach.  

Sources of migration guidance

Members said this was particularly useful when identifying which assets were critical for migration and when setting migration objectives to those assets. 

Members discussed how they identify the best guidance for PQC migration, highlighting the value of sources such as the NCSC and the G7 Cyber Experts Group (CEG). These provide technically detailed guidance in clear language, setting out quantum risks alongside mitigating actions.

Role-specific training on emerging technologies

Members are developing role-specific technology literacy programmes, enhancing staff awareness of how emerging technologies, like PQC and AI, may affect operational resilience. This includes delivering targeted awareness sessions, establishing communities of practice, and providing clear reference guidance to promote secure, consistent and informed use. 

Common challenges for emerging technologies

Oversight of third parties implementing AI

Third-party AI oversight remains a concern. Members noted that it’s still hard to understand how external suppliers are deploying AI, due to limited visibility and vendors’ inconsistent engagement. 

Assessing whether supplier-led AI activities align with firms’ own risk frameworks can be difficult, and without clearer oversight, built into contractual requirements, firms risk inheriting unknown vulnerabilities. 

Threat actors using AI

Members have observed a rise in threat actors using AI to enhance phishing, vishing and deepfake-enabled attacks. AI makes these more convincing, harder to detect and faster to scale. This heightens operational risk.

Without strengthened defences and no instantaneous solution, members said they’re working to enhance their detection capabilities as well as user training. Firms found value in threat information published by NCSC as well as the G7 CEG Statement on AI and cyber security.

Lack of senior buy-in

For some boards, PQC is viewed as a distant and abstract issue, making it hard to secure sustained senior leadership support. 

Because the benefits are not immediately visible and PQC competes with other operational priorities, firms noted that it can be difficult to gain sustained executive sponsorship.

Training for non-technical teams 

Members highlighted that while PQC training is more available than in 2024, it’s still too often limited to technical training or academic guides and can be difficult to translate into practical steps for non-technology teams. 


Topic 3: Insider risk

Members discussed their experiences of insider risk management from a cyber resilience perspective, including good practice, detection challenges and stakeholder engagement. 

Insights from CCG members on insider risk

Stay joined up

Insider risk management is inherently enterprise-wide across cyber security, financial crime, conduct and ethics, operations, HR, legal and technology. Because of this, it can be extremely challenging to update an approach.

Successful methods for working across so many functions included establishing joint operating forums or cross-functional triage groups to ensure potential risks were not missed, for example as the result of new technology.

Configuring detection tools

When discussing methods to strengthen detection capabilities or insider risks, effectively configuring behavioural analytics and data loss prevention tools was critical, particularly tools that support role-based activity, detect anomalous access or data movement, and enable the correlation of user activity across systems.

Insider scenario testing

Insider risk scenarios have been effective in strengthening risk understanding and are valuable across both red team and tabletop exercises. 

These scenarios helped members understand how processes could be subverted by a malicious insider with sufficient knowledge and access.

Effective identity and access controls

Identity and access management, if applied effectively, can help prevent, detect and respond to insider activity. 

Members suggested that ensuring access is proportionate to a role, and with regular review, was likely to reduce insider risk and especially where anomalous activity is quickly identified.

Privileged access management, especially when regularly reviewed, is a further key source of risk reduction.

Senior management support

Members with strong insider risk management said this was down to consistent, senior management-supported messaging.

Practices that supported effective insider risk management included:  

  • Routinely considering insider risk in board risk discussions.
  • Clear senior level accountability.
  • Active challenge on risk appetite, escalation, and outcomes.

Create a culture of security and trust

Members highlighted the importance of fostering a positive security culture in which staff feel trusted, while understanding insider risk monitoring and controls.

Proactive, clear and transparent communication of acceptable use standards and the rationale for monitoring helps reinforce trust, reduce uncertainty, and encourage the right behaviours. This avoids both overreliance on controls and unintended cultural resistance, while supporting consistent application across the organisation.

Common challenges for insider risk

Monitoring user activity

Privacy obligations and employment regulations, particularly in the EU, can limit a firm’s user activity monitoring, such as in relation to vetting and behaviour analysis. This necessitates differentiated approaches to manage insider risk between jurisdictions which increases complexity and operational overhead.

Controls seen as punitive 

Insider risk controls can be perceived as punitive or disproportionate, rather than protective. 

This risk is heightened by the complexity of consequence management, where decisions must balance legal, HR, regulatory and ethical considerations. 

Without clear governance and consistency in control implementation, security outcomes can appear arbitrary, undermining trust of employees and security culture.

High volumes of activity alerts

User activity and monitoring tools generate data in volumes that can be overwhelming for security teams. 

Some members have responded to this with automation and prioritisation, helping to filter out the lower-level alerts.

Calibrating AI tools

AI tools can be successful but are sometimes limited because they don’t understand behavioural context and don’t have sufficiently mature baselines.

They can be made more efficient at insider risk management through well-configured testing and calibration, as well as reviewing alerts to assess whether they are generated appropriately and proportionately.

Definining 'insider risk'

Members observed that the scope of insider risk is not always well defined. Some have strengthened their insider risk management by expanding the categorisation of ‘insiders’ to include:

  • Internal employees (including current, prospective and former).
  • Third-party suppliers.
  • Contractors with access to systems and data. 

Background to the CCG programme

We have run the CCG programme since 2017. It currently has 140 member firms within 5 groups; each aligned to a sector. These are:

  • Insurance.
  • Wholesale banking.
  • Retail banking.
  • Investment and asset management.
  • Payments, platforms and trading venues.

The FCA CCG programme also includes an additional group, the Trade Associations Cyber Information Group (TACIG), which includes members from finance sector trade associations.

The CCGs bring together industry cyber resilience and information security leaders to exchange insights and learn from each other. Within the CCGs, members may also meet with representatives from the Bank of England, the Prudential Regulation Authority and the National Cyber Security Centre.

The CCGs are held quarterly and promote engagement across the financial services sector.

We would like to thank CCG members for continuing to contribute their cyber resilience insights. 

Glossary

Term Definition 
Cryptographic hygiene 

How well an organisation manages its encryption, keys and certificates across systems. 

Back to Insights summary.

Identity and access management

Controls that ensure individuals only have the access they need, for as long as they need it. 

Back to Topic 3: Insider risk.

Important business services (IBS)

A service provided by a firm, or by another person on behalf of the firm, to one or more clients of the firm which, if disrupted, could:  

  • Cause intolerable levels of harm to any one or more of the firm’s clients; or  
  • Pose a risk to the soundness, stability or resilience of the UK financial system or the orderly operation of the financial markets. 

Back to Topic 1: Incident response.

Insider risk

The risk of harm from people with legitimate access to systems or data, whether malicious or accidental. 

Back to Insights summary.

Minimum viable service

The lowest level of service needed to continue delivering an important business service during disruption. 

Back to Topic 1: Incident response.

Severe, plausible incident scenarios

High-impact scenarios that could realistically occur.

Back to Insights summary.

Post‑quantum cryptography (PQC)

Cryptographic algorithms that are designed to secure information against future quantum computers. 

Back to Insights summary.

Privileged access management

Controls over powerful system access rights. 

Back to Topic 3: Insider risk.

Red team

A group of authorised security testers who emulate a potential threat actor’s tactics and techniques on an organisation’s cyber security defences in order to identify potential vulnerabilities. 

Back to Topic 3: Insider risk.