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BCM-006 BCM and DR Testing

Tier 2+ProviderDeployerGPAI Model ProviderManaged Service Provider

Description

Business continuity and disaster recovery plans are exercised at least annually using tabletop exercises, functional tests, or full simulation. Test scenarios cover the most likely disruptive events (e.g., availability zone failure, ransomware, key personnel unavailability). Results are documented, lessons learned are captured, and plans are updated accordingly.

Rationale

Plans that are never tested contain untested assumptions. Regular exercises expose gaps in procedures, tooling, and team readiness before a real event.

Applicability (9 profiles)

SaaS AI Providerstablerequiredcore
Enterprise AI Deployerstablerequiredcore
GPAI Model Providerstablerequiredcore
High-Risk Provider (EU)stablerequiredcore
Public Body Deployer (EU)stablerequiredcore
DORA ICT Provider (EU)stablerequiredrole duty

Art. 30(3)(c) requires the plans to be tested, not only held. RTS 2024/1773 Art. 9(2), point (a), then requires the results to reach the customer as a standing report on business continuity measures and testing.

NIS2 Cloud Provider (EU)stablerequiredcore

Framework Mappings (12)

BCR-06Business Continuity Exercisesfull
BCR-10Response Plan Exercisefull
BCR-06Business Continuity Exercisesfull
BCR-10Response Plan Exercisefull
DORA-Art.30.3.cBusiness contingency plans and ICT security measurespartial
HIPAA-164.308.a.7.ii.DTesting and Revision Proceduresfull
5.30ICT readiness for business continuityfull
NIS2-CIR-4.1Business Continuity and Disaster Recovery Planinformative
NIS2-CIR-4.3Crisis Managementinformative
CP-3Contingency Trainingpartial
CP-4Contingency Plan Testingfull
A1.3Recovery Plan Testingfull

Evidence (2)

recorddocumentmanual

BCM/DR exercise record documenting the test scenario, participants, findings, and lessons learned from the most recent tabletop, functional, or full simulation exercise.

Example: DR test report or BCM exercise after-action report (dated, within the last 12 months) showing scenario description, participant list, timeline of events, issues identified, and corrective actions raised

Test: Request the BCM/DR exercise record for the last two annual exercises. Verify: (1) exercises were conducted within the required frequency; (2) scenarios covered at least one realistic disruption type (e.g., AZ failure, ransomware, key personnel loss); (3) participants included personnel with defined response roles; (4) findings and lessons learned are documented; (5) corrective actions have been assigned and tracked.

reportdocumentmanual

Post-exercise lessons learned report showing corrective actions raised and tracked following the most recent BCM/DR exercise.

Example: Post-exercise improvement register or Jira/equivalent backlog showing issues identified during the exercise, assigned owners, target remediation dates, and current status

Test: Request the post-exercise lessons learned report and the corrective action register. Verify: (1) all significant findings from the exercise are in the register; (2) each finding has an assigned owner and due date; (3) actions from the prior exercise cycle were completed before the next exercise; (4) completed actions resulted in an update to the BCP, DRP, or related procedures.

Questions (3)

boolean

Are business continuity and disaster recovery plans exercised at least annually?

Exercises should include personnel with defined response roles. Lessons learned must be captured and result in updates to the BCP, DRP, or related procedures.

select

What type of BCM/DR exercise was most recently conducted, and when?

Full simulation or live failover test within the last 12 monthsFunctional test (partial systems or processes tested) within the last 12 monthsTabletop exercise within the last 12 monthsAny exercise type but more than 12 months agoNo BCM/DR exercise has been conducted

A tabletop exercise is the minimum acceptable exercise type. A full simulation or live failover test provides the strongest evidence of plan effectiveness.

multi

Which of the following follow each continuity or recovery exercise?

The result is recorded against the scenario exercisedPersonnel holding defined response roles took partLessons learned are recorded with named ownersThe continuity or recovery plan is updated where the exercise found a gapThe scenarios exercised are drawn from the disruptions most likely to affect the serviceNone of the above

Options run from the most commonly in place to the least. An exercise that produces no change to any plan is usually an exercise that tested the plan nobody doubted. Record the scenario as well as the outcome, because the scenario is what decides whether the test was worth running.