How to Build a Business Continuity Plan for EU Compliance (2025 Guide)

Introduction

Business Continuity Planning (BCP) is rapidly moving from best practice to business necessity for firms in the EU. While the Digital Operational Resilience Act (DORA) makes continuity planning a regulatory requirement for financial and related sectors, its principles are increasingly being referenced more broadly in supply chain, manufacturing, and logistics. Other frameworks, such as the Corporate Sustainability Reporting Directive (CSRD) and the NIS2 Directive, further reinforce the expectation that organisations can withstand not just IT-related disruptions, but any event that threatens their operations. If anything, these regulations underscore a simple truth: it is simply good business practice – if not vital – for any company today to have a solid Business Continuity Plan that covers the full spectrum of operational risks, not just those related to IT¹.

What is a Business Continuity Plan?

A Business Continuity Plan is a structured approach to keeping your business running during and after disruptive events. Disaster recovery is a subset of BCP, typically focused on IT. A full BCP covers every critical business function – from production lines and warehousing to procurement, HR, and customer service. Under new EU regulations, every organisation is expected to document, test, and regularly update their BCP, ensuring it is more than just a document on a shelf³.

Key EU regulatory requirements for BCP

The regulatory landscape is shifting fast. Here is what is now expected:

• DORA (Digital Operational Resilience Act): Mandates operational resilience for financial and, increasingly, non-financial firms, including robust BCPs that go beyond IT¹.
• NIS2 Directive: Expands cybersecurity and continuity obligations to a wider set of industries, including logistics and manufacturing⁴.
• CSRD (Corporate Sustainability Reporting Directive): Requires disclosure of continuity and resilience measures as part of ESG reporting⁵.
• Sector-specific rules: Some sectors (e.g., food, pharma, transport) have additional continuity and crisis management requirements⁶.
• Cross-border readiness: Firms operating across borders, even within the EU single-market area, must ensure their BCPs address differing local regulations and supply chain dependencies⁷.

Watch out: do not fall into the IT-only trap

Much of the BCP material you will find online is heavily focused on IT – cyberattacks, data loss, disaster recovery. While these are important, manufacturing, supply chain, and logistics businesses face a much broader set of threats: fire, flooding, microbial contamination, strikes (internal and external), supply interruptions, and, increasingly, geopolitical and trade risks. This guide addresses the full landscape of risks relevant to your operations – not just IT².

IT vs Operational risks: a broader view for BCP

The risk landscape is evolving rapidly. New threats such as trade conflicts and AI-driven disruptions can emerge with little warning, making regular risk reviews essential. Here’s a list of some of the main IT and Operational risks to consider:

How to build your Business Continuity Plan

 Step-by-step roadmap

1. Map your critical operations
   List all essential business functions – production, warehousing, order fulfilment, procurement, and more.
2. Identify risks and vulnerabilities
   Consider both IT and non-IT threats: fire, flood, contamination, strikes, cyberattacks, supplier failure. Include geopolitical tensions, climate events, and labour risks⁷.
3. Conduct a business impact analysis
   Assess how disruptions would affect your operations, finances, and customers. Prioritise what must be restored first.
4. Define recovery objectives
   Set clear recovery time objectives (RTOs) and recovery point objectives (RPOs) for each critical function³.
5. Develop recovery strategies
   Plan for alternative suppliers, backup sites, manual processes, and flexible staffing. Consider multi-sourcing and supplier segmentation to reduce dependency risks⁸.
6. Assign roles and responsibilities
   Ensure every department knows its part in an incident. Foster cross-functional collaboration and regular, transparent communication⁹.
7. Create your communication plan
   Prepare templates and escalation paths for both internal teams and external stakeholders.
8. Test and train
   Run regular drills – tabletop and live – and update the plan based on lessons learned. Treat every major disruption as a learning opportunity¹⁰.
9. Review and update regularly
   Regulatory requirements and business realities change. Review your BCP at least annually or after major incidents³.

How to get started & what to expect

•  Appoint a project lead and small task force (ideally cross-functional).
• Kick off with a high-level risk and process mapping workshop.
• Gather existing documentation (risk registers, crisis plans, supplier lists).
• Plan for a 4–8 month project timeline with a team dedicating around 15–20% of their time¹⁰.
• Engage leadership early for buy-in and resource allocation.
• Schedule regular check-ins and milestones to maintain momentum.

Building resilience: best practices for modern BCP

Resilience as a competitive advantage

A well-designed Business Continuity Plan is a source of long-term value creation, not just risk mitigation. Resilient firms maintain steady operations, protect customer trust, and minimise reputational damage during disruptions².

Supply chain transparency and data integrity

Transparency across your supply network, and ensuring data integrity, are now seen as critical to resilience. Map your supply chains, improve data sharing with key partners, and invest in data quality as part of your BCP⁹.

Accelerated technology and automation

Accelerating automation and digital transformation can support resilience, not just in IT, but across operations, quality management, and supply chain processes. However, new digital tools introduce new dependencies and risks, which must be considered in your BCP⁷.

Agility and flexibility

The ability to adapt quickly – by reallocating resources, shifting suppliers, or changing production schedules – is a hallmark of resilient firms. Build flexibility into your plans and review them regularly to reflect changing business realities².

Regulatory and quality management integration

Integrating your BCP with existing quality, safety, and regulatory management systems (such as ISO 9001:2015) is now best practice. This supports efficiency, audit readiness, and a holistic approach to risk management¹¹.

Common pitfalls and how to avoid them

1. Focusing only on IT risks and neglecting operational or supply chain threats.
2. Treating BCP as a paperwork exercise rather than a living, tested process.
3. Failing to assign clear, cross-functional ownership.
4. Not involving suppliers and partners in continuity planning.
5. Infrequent testing and updates, leading to outdated or unworkable plans.
6. Overlooking local and cross-border regulatory differences within the EU single-market.

Practical checklist: is your BCP ready for EU compliance?

1. Have you identified and prioritised all critical business functions?
2. Does your risk assessment cover both IT and operational threats, including geopolitical, climate, and labour risks?
3. Are recovery objectives (RTO/RPO) clearly defined for each area?
4. Do you have alternative suppliers, multi-sourcing, and backup plans in place?
5. Is your communication plan documented and tested?
6. Are roles and responsibilities assigned and understood across teams?
7. Do you regularly test and update your BCP, and learn from each disruption?
8. Does your plan address all relevant EU and local regulatory requirements?
9. Is your BCP integrated with your quality and regulatory management systems?

Advanced and emerging insights:
What leading organisations are doing

The following concepts reflect the practices and technologies being adopted by the most advanced and resilient organisations. They are not required for every business, but offer inspiration for those seeking to push their continuity planning further or future-proof their operations.

Deep supply chain visibility & digital control towers

Real-time tracking of materials and products across all supply chain tiers using GPS, RFID, and AI-powered platforms enables proactive risk detection and dynamic rerouting during disruptions. These “digital control towers” are increasingly accessible to mid-sized firms and can significantly improve resilience¹³.

Strategic diversification & redundancy

Maintaining alternative suppliers, production sites, and logistics partners reduces vulnerability to single points of failure. Companies with built-in redundancy were far less likely to face major disruption during recent global crises¹⁴.

Immutable data for chain integrity

Using immutable storage (e.g., WORM, object lock) to secure inventory records and transaction logs deters fraud and ensures transparency—helpful for compliance and audit-readiness¹⁵.

Elevated risk assessment for logistics nodes

Advanced firms assess not just suppliers, but also transport corridors, warehousing hubs, and third-party logistics (3PL) partners for risk exposure, integrating these into their continuity frameworks¹⁶.

Cross-functional scenario testing

Leading organisations conduct drills involving simultaneous disruptions—such as supplier delays, transport breakdowns, and workforce shortages—to validate and refine their continuity plans¹⁷.

Data-driven forecasting & demand agility

Predictive analytics and AI are used to sense demand shifts and simulate disruption scenarios, enabling faster, more agile responses to volatility¹⁸.

Strengthened supplier & 3PL partnerships

Moving beyond transactional relationships, advanced firms co-create resilience plans, share data, and centralise documentation with key vendors and logistics partners¹⁹.

Sustainable packaging & logistics efficiency

Designing packaging for reuse, recycling, and transport efficiency not only reduces costs and carbon footprint but also enhances operational resilience²⁰.

Compliance-ready traceability

End-to-end visibility and immutable records help meet due diligence and forced labour regulations, and streamline customs and quality audits¹⁵.

Talent development & cross-training

Investing in cross-functional training and building talent pipelines ensures continuity of expertise and operational flexibility during disruptions²¹.

Final thought:

Business Continuity Planning is no longer just about ticking a box for compliance – it is about protecting your operations, reputation, and future growth. By focusing on the full spectrum of risks and aligning with new EU requirements, manufacturing, supply chain, and logistics leaders can build resilience and stay ahead of the curve.

If you would like support, or to organise a Business Continuity Planning workshop or training session, please do not hesitate to contact us.

 References

1.        European Commission. “Digital Operational Resilience Act (DORA).”
https://finance.ec.europa.eu/regulation-and-supervision/financial-supervision-and-risk-management/digital-operational-resilience-act-dora_en

2.        Harvard Business Review. “How to Build a More Resilient Business.”
https://hbr.org/2020/04/how-to-build-a-more-resilient-business

3.        ISO. “ISO 22301: Business Continuity Management Systems.”
https://www.iso.org/iso-22301-business-continuity.html

4.        ENISA. “NIS2 Guidance.”
https://www.enisa.europa.eu/topics/csirt-cert-services/nis-directive

5.        European Commission. “Corporate Sustainability Reporting Directive (CSRD).”
https://finance.ec.europa.eu/capital-markets-union-and-financial-markets/company-reporting-and-auditing/corporate-sustainability-reporting_en

6.        European Commission. “Sector-specific rules for continuity.”
https://ec.europa.eu/info/business-economy-euro/banking-and-finance/financial-supervision-and-risk-management/managing-risks/operational-risk_en

7.        McKinsey & Company. “The resilience imperative in supply chains.”
https://www.mckinsey.com/capabilities/operations/our-insights/the-resilience-imperative-for-supply-chains

8.        BCG. “Building resilient operations for the next normal.”
https://www.bcg.com/publications/2020/building-resilient-operations-for-the-next-normal

9.        Gartner. “Supply chain resilience best practices.”
https://www.gartner.com/en/supply-chain/insights/resilience

10.     Continuity Central. “How long does it take to develop a business continuity plan?”
https://www.continuitycentral.com/index.php/news/business-continuity-news/5774-how-long-does-it-take-to-develop-a-business-continuity-plan

11.     ISO. “ISO 9001:2015 Quality Management Systems.”
https://www.iso.org/iso-9001-quality-management.html

12.     KPMG. “As trade challenges peak, focus on supply chain risk is urgent.”
https://kpmg.com/lu/en/home/insights/2025/06/trade-challenges-peak-focus-supply-chain-risk-urgent.html

13.     Financial Times. “How digital control towers are transforming global supply chains.”
https://www.ft.com/content/ea7e8b7e-9a9b-4b7c-9b8e-1e0d5b9b8e2f

14.     Vogue Business. “How fashion supply chains are diversifying after COVID-19.”
https://www.voguebusiness.com/companies/fashion-supply-chains-diversifying-covid19

15.     Flexxon. “Why immutable storage matters for supply chain integrity.”
https://estore.flexxon.com/blogs/news/immutable-storage-supply-chain

16.     NetSuite. “How to manage risk in your supply chain.”
https://www.netsuite.com/portal/resource/articles/inventory-management/supply-chain-risk.shtml

17.     Cadre Technologies. “Scenario planning for logistics and supply chain resilience.”
https://www.cadretech.com/blog/scenario-planning-logistics-supply-chain

18.     Intuendi. “AI-driven demand forecasting for supply chain agility.”
https://intuendi.com/blog/ai-demand-forecasting-supply-chain

19.     Security Magazine. “Building resilient supplier partnerships in logistics.”
https://www.securitymagazine.com/articles/99123-building-resilient-supplier-partnerships-in-logistics

20.     Wikipedia. “Sustainable packaging.”
https://en.wikipedia.org/wiki/Sustainable_packaging

21.     Bryghtpath. “Talent development and cross-training for continuity.”
https://bryghtpath.com/talent-development-business-continuity/