Recital 11
Commission Delegated Regulation (EU) 2025/1190 on threat-led penetration testing (TLPT) under DORA · UE 2025/1190
| (11) | There are inherent elements of risks associated with TLPT as critical functions are tested in a live production environment, with the possibility of causing denial-of-service incidents, unexpected system crashes, damages to critical live production systems, or the loss, modification, or disclosure of data. Those risks highlight the need for robust risk management measures. To ensure that the TLPT is conducted in a controlled manner all along the testing, it is very important that financial entities are at all points aware of the particular risks that arise in a TLPT and that those risk are mitigated. In that respect, without prejudice to the internal processes of the financial entity and the responsibility and delegations already provided to the control team lead, information about the TLPT risk management measures, or, in particular cases the approval of those risk management measures by the financial entity’s management body itself, may be appropriate. To be able to deliver effective and most qualified professional services and to reduce those risks, it is also essential that the testers and threat intelligence providers (together, the TLPT providers) have the highest level of skills, expertise, and an appropriate experience in threat intelligence and TLPT in the financial services industry. |
In Luxembourg, the TLPT authority under DORA article 26 is the CSSF, which runs the TIBER-LU framework jointly with the BCL. The TIBER-LU Implementation Document revised on 20 June 2025 sets out local expectations on test risk management and provider selection, consistent with CSSF circulars 22/806 and 25/882 that bring ICT providers into the tested scope.
Luxgap practice: align your TLPT risk register with the TIBER-LU Implementation Document of 20 June 2025 and have the management body formally approve mitigation measures before the test window, to present evidence directly readable by the CSSF and the BCL.