October 2026 Summaries

DORA requires EU financial institutions to define recovery objectives, test them regularly, and demonstrate with evidence that critical services can be restored despite incidents or third-party cloud failures. The discussion argues that data backups alone are insufficient because operational recovery also depends on current infrastructure configurations, including IAM roles, networking, Kubernetes resources, DNS, load balancing, secrets, and monitoring systems; outdated infrastructure-as-code can therefore delay restoration even when data is intact. It cites a July 2026 ECB request for significant euro-area banks to prepare for AI-enabled cyber threats through tested recovery capabilities covering ransomware, zero-day compromises, and cloud-service disruption. The proposed Disaster Recovery-as-Code approach involves maintaining a complete, continuously updated and version-controlled inventory of cloud resources and dependencies, validating RTO and RPO targets through repeated tests, rebuilding environments into clean regions or accounts, and retaining logs as audit evidence. Firefly is presented as a tool intended to support these practices through cloud discovery, drift detection, recovery-readiness assessment, full-environment restoration, and compliance reporting.

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