The publication by the Central Bank of Ireland of its “Cross Industry Guidance on Operational Resilience” in December 2021 prompted the insurance industry in Ireland to formally consider its operational resilience. Almost two years on, as the implementation deadline of December 2023 looms (by which time firms are expected to “be in a position to evidence actions/plans to apply the Guidance”), we take a look at some of the practical challenges firms have faced along the way, both in Ireland and in the UK (where a similar requirements in relation to operational resilience are already in place), identifying some of the more common pitfalls.