FCA Operational Resilience Findings: Resilience Is Not Static
Summary of the FCA’s latest report of insights and observations one year after the Operational Resilience transition.
27 May 2026
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If you sell or build software in the UK, you’ve just been handed a new benchmark to hit. The Department for Science, Innovation and Technology (DSIT) has introduced a new Software Security Code of Practice. It’s voluntary—for now—but if you’re a CTO, CISO or technical leader in a SaaS business, vendor firm, or IoT provider, it’s already showing up in audits and RFPs.
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It’s a new government-issued benchmark outlining what “good security” should look like for organisations that develop or distribute software in the UK. The goal: make software less vulnerable, by design.
It borrows from best practice frameworks like the EU Cyber Resilience Act and NCSC guidance, and it sets the bar across four domains:
UK businesses are increasingly reliant on SaaS, but many vendors don’t fully secure their development environments. Common weak points include:
Even if you’re “doing your best”, that may not meet the new bar. If you’re asked to demonstrate secure-by-design practices, can you?
Start with NCSC-backed frameworks. Ensure developers are trained, third-party components are reviewed, and security testing is part of every release.
Your dev pipeline should be monitored and access-controlled. Assume it’s a target.
Make it easy for users to report vulnerabilities. Communicate clearly on patching, support windows, and end-of-life timelines.
Whether it’s an auditor, client, or procurement team—be ready to show how your security practices align to these principles.
Complying with the Code isn’t just good hygiene—it’s becoming a market requirement. Boards and buyers are increasingly treating voluntary codes as de facto standards.
FoxTech can help. Our team audits secure development lifecycles, stress-tests your build pipeline, and helps embed cyber by design.
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Summary of the FCA’s latest report of insights and observations one year after the Operational Resilience transition.
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