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ARTICLE · 04 AUGUST 2025

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EU Standards For Threat-Led Penetration Testing: New Cyber Compliance Imperatives For Financial Institutions

Jones Day
Jones Day
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The EU has introduced Delegated Regulation (EU) 2025/1190, establishing the first harmonized standards for threat-led penetration testing ("TLPT") across the financial sector.

European UnionTechnology
Marco Frattini
Marco Frattini
Michael R. Fischer
Michael R. Fischer
Michèle Grégoire
Michèle Grégoire
Philippe Goutay
Philippe Goutay
Jörg Hladjk
Jörg Hladjk
Olivier Haas
Olivier Haas
Iván Martín-Barbón
Iván Martín-Barbón
Undine Von Diemar
Undine Von Diemar
Céline Hoffmann
Céline Hoffmann
+1 more
Author LinkedIn connections

In Short

The Situation: The EU has introduced Delegated Regulation (EU) 2025/1190, establishing the first harmonized standards for threat-led penetration testing ("TLPT") across the financial sector. The regulation aims to strengthen the cyber resilience of systemically important financial institutions and harmonize supervisory requirements throughout the EU.

The Result: The new regulation imposes uniform, binding requirements for all phases of TLPT on designated financial institutions, standardizing expectations for test planning, execution, remediation, and supervisory coordination across the EU.

Looking Ahead: In-scope financial institutions should immediately assess the new TLPT standards, including conducting gap assessments, engaging with supervisors, and establishing robust internal processes, as action is critical to avoid regulatory or operational disruptions. Failure to comply may lead to supervisory action, enforcement measures, and

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