BMA Requires Greater Operational Resilience

• Published date: 14 October 2025
• Law Firm: Appleby
• Author: Duncan Card and Richard Collis

Last month, the Bermuda Monetary Authority issued its code of conduct to bolster the resiliency of registrants when they are faced with operational disruptions.

Previously the domain of business continuity programmes and disaster recovery policies, the Resilience Code takes the governance and operational requirements of business continuity to an entirely new level of compliance.

The code applies, in part, to banks and deposit companies, insurance enterprises, investment businesses and digital-asset businesses, and it addresses all operational circumstances of disruption even though the title of the Resilience Code may misleadingly suggest that outsourcing transactions are the primary focus of attention.

The BMA will require registrants to proactively adopt measures to avoid, minimise, recover from and respond to operational disruptions from all causes to enhance their ability to operate in the face of such disruptions by March 31, 2028, although banks and deposit companies must be compliant by January 1, 2027.

Bermuda is not alone in this regulatory development.

Born from the recognition that financial services are essential and...