Recital 8

Recital 8

Commission Delegated Regulation (EU) 2025/1190 on threat-led penetration testing (TLPT) under DORA · UE 2025/1190

(8)

It is important, for consistency with the TIBER-EU framework, that the TLPT authority closely follows the testing in each of its stages. Considering the nature of the testing and the risks associated to it, it is fundamental that the TLPT authority is involved in each specific phase of the testing. In particular, the TLPT authority should be consulted and should validate those assessments or decisions of the financial entities that may, on the one hand, influence the effectiveness of the test and, on the other hand, have an impact on the risks associated with the test. The fundamental steps on which a specific involvement of the TLPT authority is necessary include the validation of certain fundamental documentation of the testing, and the selection of threat intelligence providers and testers and risk management measures. The involvement of the TLPT authorities, and in particular for validations, should not result in an excessive burden for those authorities and should therefore be limited to those documentation and decisions that directly affect the conduct of the TLPT. Through the active participation in each phase of the testing, the TLPT authorities may effectively assess compliance of the financial entities with the relevant requirements, which should allow those authorities to issue attestations pursuant to Article 26(7) of Regulation (EU) 2022/2554.

Luxembourg specificity
TIBER-LU Implementation Document (BCL/CSSF), revise le 20 juin 2025

In Luxembourg, the TLPT authority is the CSSF, which runs the national TIBER-LU framework jointly with the BCL. The TIBER-LU Implementation Document was revised on 20 June 2025, consistent with the ECB TIBER-EU revision of 11 February 2025. In practice, the validations required by recital 8 run through a BCL/CSSF Test Cyber Team that accompanies each phase.

Luxgap practice: identify your TIBER-LU contact early and align the validation schedule with the milestones of the 20 June 2025 Implementation Document, rather than improvising phase by phase.