Turn guidance into an action plan
Agree the systems and business processes in scope, assign a decision-maker and technical owner, and record what evidence will demonstrate progress. Separate immediate risk treatment from longer-term improvement, and set a review point for outstanding actions.
What leaders should do
- Identify customer and transaction journeys with the highest fraud, availability, privacy, and operational risk.
- Map accountability across teams, technology partners, agents, processors, and service providers.
- Maintain evidence for access, monitoring, vulnerability management, change, incident response, and recovery.
- Exercise scenarios that test payment continuity, communications, regulator escalation, and supplier coordination.
Treat readiness as an ongoing assurance programme that improves resilience while making evidence easier to retrieve.