title: US-PA — Operational Resilience & Critical Infrastructure (W3) | World Payments Monitor canonical: https://payments.gi/jurisdictions/united-states-pennsylvania/w3/ ### W3 Operational Resilience & Critical Infrastructure 1 gap Probable re-verified 2026-10-18 · changed 2026-07-05 Pennsylvania lacks a payments-specific operational-resilience regime; DoBS points regulated entities to federal FFIEC/OCC/FDIC/Fed third-party risk guidance rather than issuing its own binding rules for payment firms. The Commonwealth's own binding cyber-incident law (the Breach of Personal Information Notification Act) is a general data-breach notification statute, not payments-sector operational resilience, and the newer PA Insurance Data Security Act is scoped to insurance licensees, not payment/money-transmission licensees. Kept on Dataprotection.gi, not restated here: data and cloud switching obligations on service providers, including notice periods and charges. [Open its jurisdiction pages on Dataprotection.gi →](https://dataprotection.gi/jurisdictions/) Open gap — wpm-int-1 No delta this cycle located for W3 Operational Resilience & Critical Infrastructure._no under-indexing note recorded_ Standing sub-brief · as of 5 July 2026 133 words · last cycle 2026-07-05 #### Operational Resilience & Critical Infrastructure Pennsylvania has no payments-specific state operational-resilience regime. Payment/money-transmission licensees; DoBS refers regulated entities to federal FFIEC/OCC/FDIC/Fed third-party risk guidance rather than issuing a binding state-level operational-resilience rule of its own. The one operational-resilience-adjacent state statute identified, the Insurance Data Security Act (Act 2 of 2023), is scoped to insurance licensees only and does not reach payment or money-transmission licensees. This leaves Pennsylvania payments operators reliant entirely on federal supervisory guidance for operational-resilience expectations, a materially lighter-touch position than DORA-style regimes emerging elsewhere. #### Outlook No legislative or regulatory move toward a dedicated state operational-resilience regime for payments was identified this cycle. This remains a standing structural gap in Pennsylvania's regulatory architecture worth monitoring should DoBS or the General Assembly move toward a state-level analogue to federal third-party risk-management expectations. no periodic updates on record for this sub-brief ** Sources and findings (4 unique sources · R-3/R-4)** 1. [W3-E1] T1 Derived: Confirmed [in_force https://www.legis.state.pa.us/WU01/LI/LI/US/HTM/2005/0/0094..HTM](https://www.legis.state.pa.us/WU01/LI/LI/US/HTM/2005/0/0094..HTM) re-verified 2026-07-05 "Breach of the security of the system" is defined as the unauthorized access and acquisition of computerized data that materially compromises the security or confidentiality of personal information maintained by the entity and that causes or the entity reasonably believes has caused or will cause loss or injury to any resident of the Commonwealth. 2. [W3-E2] T1 Derived: Confirmed [in_force https://www.pa.gov/agencies/dobs/cybersecurity](https://www.pa.gov/agencies/dobs/cybersecurity) re-verified 2026-07-05 The Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency released a guide intended to assist community banks when developing and implementing their third-party risk management practices, which DoBS references directly rather than issuing its own binding standard. 3. [W3-E3] T3 Derived: Probable [in_force https://www.lexology.com/library/detail.aspx?g=f7293fa7-0b88-432c-9f3a-9cf3ba1effed](https://www.lexology.com/library/detail.aspx?g=f7293fa7-0b88-432c-9f3a-9cf3ba1effed) re-verified 2026-07-05 The generalized threats to banking that DOBS highlights in its letter and the newly created DOBS Cybersecurity Task Force are nothing new; the Task Force's website includes a litany of links and suggestions for regulated institutions, but all are pre-existing resources from other government agencies including FFIEC and the SEC. 4. [W3-E4] T3 Derived: Probable [in_force https://www.righthandtechnologygroup.com/blog/compliance/pennsylvania-cybersecurity-regulations-2025-guide](https://www.righthandtechnologygroup.com/blog/compliance/pennsylvania-cybersecurity-regulations-2025-guide) re-verified 2026-07-05 The Pennsylvania Insurance Data Security Act (PIDSA), signed into law as Act 2 of 2023, is scoped to insurance licensees and aligns with national cybersecurity standards, but does not extend to money-transmission or payments licensees, leaving a payments-specific operational-resilience gap at state level.