When Your Bank Goes Dark: The Regulatory Double Standard of Banking Availability

If banks can’t offer something more valuable than Amazon Prime, then we’re probably in the wrong business”, Bradley Leimer

The banking availability paradox

𝐖𝐡𝐲 𝐝𝐨 𝐫𝐞𝐠𝐮𝐥𝐚𝐭𝐨𝐫𝐬 𝐚𝐥𝐥𝐨𝐰 𝐛𝐚𝐧𝐤𝐬 𝐭𝐨 𝐡𝐚𝐯𝐞 𝐥𝐨𝐧𝐠 𝐬𝐜𝐡𝐞𝐝𝐮𝐥𝐞𝐝 𝐦𝐚𝐢𝐧𝐭𝐞𝐧𝐚𝐧𝐜𝐞 𝐰𝐢𝐧𝐝𝐨𝐰𝐬 𝐨𝐟 𝟔 𝐡𝐨𝐮𝐫𝐬 𝐨𝐫 𝐦𝐨𝐫𝐞? During these periods most of their critical services are unavailable. This is interesting especially when banks are mandated to recover from an unscheduled outage in less than 4 hours.

On 23rd March 2025, over 6 banks in Singapore had maintenance windows stretching to 6 hours or more in the early morning. At least 3 of them have regular weekend scheduled maintenance windows of such durations. 𝐓𝐚𝐥𝐤 𝐚𝐛𝐨𝐮𝐭 𝐡𝐚𝐯𝐢𝐧𝐠 𝐚 𝐛𝐚𝐜𝐤𝐮𝐩 𝐚𝐜𝐜𝐨𝐮𝐧𝐭, 𝐣𝐮𝐬𝐭 𝐢𝐧 𝐜𝐚𝐬𝐞 𝐲𝐨𝐮 𝐧𝐞𝐞𝐝 𝐭𝐨 𝐦𝐚𝐤𝐞 𝐚 𝐩𝐚𝐲𝐦𝐞𝐧𝐭 𝐨𝐫 𝐭𝐫𝐚𝐧𝐬𝐟𝐞𝐫!

Banks may debate that their maintenance windows are during periods of reduced activity. But if they are offering digital services, they are promising 24×365 availability with global access.

𝐓𝐡𝐢𝐬 𝐢𝐬 𝐥𝐚𝐫𝐠𝐞𝐥𝐲 𝐝𝐮𝐞 𝐭𝐨 𝐭𝐡𝐞 𝐟𝐫𝐚𝐠𝐢𝐥𝐢𝐭𝐲 𝐨𝐟 𝐦𝐨𝐬𝐭 𝐛𝐚𝐧𝐤𝐢𝐧𝐠 𝐭𝐞𝐜𝐡 𝐬𝐭𝐚𝐜𝐤𝐬, 𝐰𝐡𝐢𝐜𝐡 𝐚𝐫𝐞 𝐢𝐧 𝐚 𝐝𝐢𝐫𝐞 𝐧𝐞𝐞𝐝 𝐨𝐟 𝐝𝐞𝐜𝐨𝐮𝐩𝐥𝐢𝐧𝐠 𝐚𝐧𝐝 𝐦𝐨𝐝𝐞𝐫𝐧𝐢𝐬𝐚𝐭𝐢𝐨𝐧. This modernisation needs to include their practices and operating models. And it does not have to be disruptive to their business.

Last year, a similar “𝒎𝒂𝒊𝒏𝒕𝒆𝒏𝒂𝒏𝒄𝒆 𝒘𝒊𝒏𝒅𝒐𝒘” inconvenienced Amna, my wife. In a 15 minutes conversation narrated below, this digital banking user with no banking or technology background made a compelling strategic case for banking systems modernisation in plain speak.

A customer questions

My wife, Amna, is not a technical person and not familiar with practices in large banks and financial institutions. Still she had a very thought provoking conversation with me at breakfast one day.

Amna needed to transfer some money to our daughter, who is studying in the UK. In the morning, she tried using her UK bank’s (Acme for anonymity) mobile app for this and was disappointed on seeing a banner covering the app reading:

𝘞𝘦 𝘢𝘳𝘦 𝘱𝘦𝘳𝘧𝘰𝘳𝘮𝘪𝘯𝘨 𝘳𝘰𝘶𝘵𝘪𝘯𝘦 𝘮𝘢𝘪𝘯𝘵𝘦𝘯𝘦𝘯𝘤𝘦 𝘰𝘧 𝘰𝘶𝘳 𝘴𝘺𝘴𝘵𝘦𝘮𝘴 𝘴𝘰 𝘵𝘩𝘪𝘴 𝘢𝘱𝘱 𝘪𝘴 𝘯𝘰𝘵 𝘢𝘷𝘢𝘪𝘭𝘢𝘣𝘭𝘦 𝘣𝘦𝘵𝘸𝘦𝘦𝘯 𝘮𝘪𝘥𝘯𝘪𝘨𝘩𝘵 𝘵𝘰 6 𝘢𝘮 𝘰𝘯 4 𝘍𝘦𝘣𝘳𝘶𝘢𝘳𝘺 2024. 𝘞𝘦 𝘢𝘱𝘰𝘭𝘰𝘨𝘪𝘴𝘦 𝘧𝘰𝘳 𝘵𝘩𝘦 𝘪𝘯𝘤𝘰𝘯𝘷𝘦𝘯𝘪𝘦𝘯𝘤𝘦.

This led to the following exchange between us:

Amna: What maintenance do they need on Acme’s banking app?

Me: They may need to add new features, fix existing defects, upgrade the hardware, networking, storage. It is not just the app that you see on the mobile, there is a lot of software running on the computers in their datacenters?

Amna: But why would they need six hours? I mean, it’s software isn’t it and aren’t they using computers. It’s not as if they are doing this manually with all those computers around them?

Me: Yes, ideally software should be changed with automation and even computers and networks can be configured automatically with little or no manual work. But then they have to test if the maintenance they have done has not broken anything else and everything works fine before they let their customers back into the system.

Amna: Again, why would they need hours for testing? Don’t tell me that they do that manually too. Can’t computers test themselves and other computers?

Me: Yes they can if they are programmed for it. All banks are different, some have more automation than others. I don’t know the state of Acme in this case.

Amna: Ok, but why then can they not have a spare set of computers and networks on which they can test to their heart’s content while their customers keep using the app on the other set of computers and networks. When they are happy with their testing, they can switch the customers to the new kit?

Me: (Almost speechless) Perhaps because it is very expensive to have spare kit lying around.

Amna: Can they not rent it?

Me: (Absolutely speechless – 𝐀𝐜𝐦𝐞, 𝐲𝐨𝐮𝐫 𝟲 𝐡𝐨𝐮𝐫 𝐦𝐚𝐢𝐧𝐭𝐞𝐧𝐚𝐧𝐜𝐞 𝐰𝐢𝐧𝐝𝐨𝐰 𝐢𝐬 𝐢𝐧𝐝𝐞𝐟𝐞𝐧𝐬𝐢𝐛𝐥𝐞 𝐚𝐜𝐜𝐨𝐫𝐝𝐢𝐧𝐠 𝐭𝐨 𝐲𝐨𝐮𝐫 𝐜𝐮𝐬𝐭𝐨𝐦𝐞𝐫𝐬!)

In less than 15 minutes, a digital banking customer not familiar with banking or technology has made a case for continuous delivery, testing automation, blue-green deployment and public cloud for banking. And she may not be the only one thinking all this.

Banks need to listen

Banks entered digital banking making promises of banking anywhere, anytime. Above is the voice of banks’ customers that they need to listen – denying them the 24×365 availability can be taken by the customers as a breach of promise, leading to erosion of trust. What will the banks do to prevent that?

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