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EUIn ForceFinal

RTS on Threat-Led Penetration Testing (TLPT)

Commission Delegated Regulation (EU) 2025/1190 supplementing Regulation (EU) 2022/2554 with regard to regulatory technical standards specifying the criteria for identifying financial entities required to perform threat-led penetration testing, requirements for internal testers, testing methodology, results, remediation, and supervisory cooperation

European Commission
Updated Jun 18, 2025
vFinal

Abstract

Regulatory Technical Standards under DORA establishing detailed rules for threat-led penetration testing (TLPT), including criteria for identifying entities subject to testing, governance and organisational requirements, testing phases and methodology, roles of control teams and testers, risk management measures, reporting, remediation, and supervisory cooperation, largely aligned with the TIBER-EU framework.

Key Takeaways

  • Defines criteria and supervisory factors used to determine which financial entities must perform TLPT based on systemic importance, ICT risk profile, and operational impact.
  • Establishes detailed requirements for TLPT lifecycle phases including preparation, threat intelligence, red-team testing, reporting, closure, and remediation.
  • Specifies governance roles such as control team, blue team, testers, threat-intelligence providers, and TLPT authorities, including requirements for independence and qualifications.
  • Requires structured reporting, remediation planning, and supervisory attestation following completion of a TLPT.
  • Aligns testing methodology with the TIBER-EU framework and introduces provisions for joint and pooled TLPT exercises and mutual recognition across Member States.

Keywords

EU 2025/1190DORATLPTArticle 26TIBER-EUred teamingdigital operational resilience

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