How Cybersecurity Became the Defining Challenge for European Banks

European banks are no longer preparing for a potential cyber crisis. They are operating within one.

For one thing, cyberattacks have shifted from isolated events to sustained campaigns that can disrupt core banking services, erode customer trust, and draw direct regulatory scrutiny. The 2025 Verizon Data Breach Investigations Report reinforces this reality, showing that the finance sector experiences an extremely high number of incidents and breaches, second only to manufacturing.

Adding to the already high level of risk, threat actors are now leveraging AI tools to accelerate their attacks. And these attack trends are colliding with problems uncovered by rapid digitalisation in the sector. Many banks have found themselves struggling with outdated systems, significant third-party dependencies, and security controls that aren’t designed for today’s speed or complexity.

These collective factors have transformed cyberthreats from a background technical risk into a board-level issue directly tied to operational continuity and financial stability.

The ECB Raises the Stakes

Regulators see the same shift. When the European Central Bank (ECB) ran its first cyber‑resilience stress test in 2024, banks were pushed to respond as though their core systems had been breached. Most could activate crisis plans, but many struggled with broader coordination and recovery efforts, including aspects that relied on external providers. This was a wake‑up call, and it shaped the ECB’s priorities for 2026–2028.

In this 2026-2028 cycle, the ECB has sharpened its focus by placing cyber and operational resilience at the centre of its supervisory agenda. Instead of treating cybersecurity as a technical add-on, ECB supervisors now expect banks to demonstrate that they can maintain critical services through severe disruption, whether triggered by geopolitical tensions, technology failures or the breakdown of key outsourced providers.

What the 2026–2028 Priorities Require

For the 2026-2028 cycle, banks are expected to fully implement DORA requirements, particularly in ICT (information and communications technology) third‑party risk, incident response, and cloud oversight, while also addressing long‑standing weaknesses in cybersecurity, outsourcing management, and risk data practices.

And this isn’t a matter of ticking a few control boxes: DORA demands an end‑to‑end operational resilience programme, including full ICT risk governance, incident reporting and testing, lifecycle third‑party/OSI oversight, and evidence that it all works in practice. We covered this approach in our earlier DORA strategies post.

The rise in sophisticated cyberattacks and greater reliance on external providers has highlighted the need for resilient systems, clearer governance, and well‑tested contingency plans across all critical operations.

ECB supervisors will also intensify their scrutiny of banks’ technology environments, from how they manage system changes to how they adopt emerging technologies such as AI. Targeted reviews, OSI campaigns, and threat‑led penetration testing will be used to assess how well banks can prevent, absorb, and recover from ICT disruptions.

The message is straightforward: operational resilience can no longer be aspirational, and banks must demonstrate it in practice, with technology, data and third‑party arrangements that remain stable even under severe stress.

The Shift Every Bank Now Faces

Today, the sector stands at a crossroads. Banks are expected to move from reactive fixes to building genuine, organisation‑wide resilience. That means stronger governance from the top down, better visibility of third‑party dependencies, modernizing legacy technology, and embedding security into digital transformation rather than adding it on later. It also means treating cyber incidents as inevitable and preparing for them with well‑rehearsed, end‑to‑end recovery processes that can be activated without hesitation.

The Growing Role of Cyber Advisors

For many banks, meeting these expectations requires structured support. This is where cybersecurity advisory services are increasingly becoming part of the compliance journey.

Firms are turning to consultants for DORA‑aligned gap assessments to understand where their ICT, governance, and operational processes fall short, and for hands‑on compliance programmes that help redesign policies, strengthen risk management, and build better reporting and oversight.

Retainer‑based advisory services are also becoming common, giving banks ongoing access to security specialists who can guide them through supervisory reviews, stress‑test preparation, incident simulations, and crisis exercises, as well as support remediation when new weaknesses appear.

What It Takes to Stay Ahead

Looking ahead, compliance is no longer about ticking boxes for regulators, but rather about proving resilience in practice. Banks that invest early in strengthening cyber governance, upgrading technology, tightening third‑party oversight, and testing their response plans will not only meet ECB expectations but also operate with far greater confidence. Those that don’t will find themselves exposed to both supervisory pressure and real-world threats that are now part of everyday banking.

The message is clear: cyber resilience has become one of the defining measures of a bank’s strength. Institutions that treat it as a strategic priority — backed by sustained internal commitment and the right external expertise — will meet regulatory expectations and build competitive confidence.

Get Help Meeting the ECB's Cyber Resilience Requirements from Bitdefender Advisory Services.