A fresh warning from European supervisors makes a practical question urgent: which essential work could you keep running without your preferred AI provider?
OUR VIEW
Before making an AI supplier essential to a business service, rehearse how that service will continue without it. A second contract is not a tested fallback.
Key points
What this paper means for leaders
Choose the business service that cannot wait, not the most impressive AI demonstration.
Test a reduced but acceptable service before assuming another supplier is interchangeable.
Separate binding local obligations, supervisory expectations and voluntary guidance.
Fund the people, access and operating capacity needed to carry out the fallback.
01
The Board Decision
Start with the work that cannot wait
At the next AI investment review, ask for a demonstration with the preferred supplier unavailable. Can the organisation still answer urgent customers, review priority cases or prepare the information an accountable person needs? An impressive primary service and a well-negotiated contract do not answer that question. A rehearsal can reveal what the business would actually have left.
On 23 September, the European Supervisory Authorities warned that external technology dependencies could magnify disruption in the EU financial system, alongside cyber risks associated with more capable AI. This is a supervisory risk update, not a new global AI law. It is a timely reason to revisit a decision already forming inside organisations: which services are becoming dependent on a supplier they cannot readily replace? 1
Before expanding that dependence, test one important service under supplier loss. This is not a prediction that a particular provider will fail. It is a way to discover whether the approved operating plan includes the day when the preferred option is missing.
02
What the Contract Can Miss
Two suppliers can still share one weak point
Begin with a short map of the service, not an exhaustive inventory of every AI tool. Identify the provider doing the work, where essential information is held, how staff gain access and which other services the fallback requires. Ask the proposed alternative the same questions. Two different brands may not provide two independent recovery paths.
The Financial Stability Board has identified third-party dependencies and concentration as AI-related vulnerabilities, while noting significant monitoring gaps. Its work is an international policy reference, not a licence to declare every supplier relationship unsafe. The lesson is to investigate the dependency beneath the product label before counting it as diversified. 2
A useful fallback might be another supplier, a smaller local system or a carefully limited manual process. None should be assumed superior in advance. A second provider that staff cannot access, that lacks the necessary records or that struggles with the customer's language may add procurement work without adding continuity.
03
What Applies Now
Keep the legal map separate from the rehearsal
For financial entities within its scope, the EU's Digital Operational Resilience Act has applied since 17 January 2025. Article 28(8) requires exit strategies for technology services supporting critical or important functions, with documented plans that are sufficiently tested and periodically reviewed. Applicability depends on the entity and arrangement; this is not an obligation imposed on every business using a chatbot. 3
In the UK, the PRA's current outsourcing statement expects continuity and exit planning for material outsourcing arrangements. Its November 2024 version is current; the March 2026 revision is listed as taking effect in March 2027. Treat a future-effective document differently from today's supervisory expectations. 4
Singapore's agentic-AI framework offers governance guidance, not a cross-border prudential rule. Map the sector, entity and service before deciding which obligations apply. 6
04
Where Development Matters
A substitute must work, not merely connect
Changing the provider or infrastructure may also change the result. A new arXiv study examines how the same language model and prompt can produce different outputs across graphics processors, and reports a method to improve reproducibility on specified hardware. It is a bounded technical preprint, not a measurement of enterprise failover failures. The executive implication is narrower: verify the work after a change instead of equating a successful connection with a successful replacement. 7
Supplier products are also evolving. Anthropic's 22 September Opus release describes changes to capabilities and integration behaviour. Those are the supplier's claims, not an independent comparison or a reason to recommend that product. They illustrate why a recovery procedure tied to one model version can age even while the commercial relationship remains unchanged. 8
Use a small set of representative tasks to check the alternative. Include an ordinary case, an ambiguous case and one that should be stopped or referred to a person. Assess whether staff can recognise the limits. The fallback does not need to reproduce every sentence; it needs to deliver an acceptable service within the boundaries management has approved.
05
The Operating Test
Rehearse a reduced service safely
Choose one service and define what must continue, what can wait and who may decide. An illustrative customer-service team might prioritise urgent enquiries while holding complex cases for qualified staff. This is a proposed exercise, not a reported customer deployment. Use representative material in a controlled setting; do not interrupt a live service merely to prove a point.
Measure the time to recognise the loss, activate the alternative and complete the priority work. Record missing records, unavailable permissions, additional review and the queue that accumulates. Include the people cost. A manual fallback that needs twice the available staffing is a funding decision, not a completed control.
Agree the conditions for returning to normal service as well as leaving it. Who reconciles work completed during the interruption? Who checks that no case was duplicated or lost? Who can stop the fallback if quality deteriorates? The exercise is useful when it changes an operating decision, even if its first result is that the planned rollout must remain smaller.
06
The Global Decision
Buy continuity appropriate to the market
The operating question travels further than any one legal regime. North American buyers should examine their own sector rules and contracts rather than import DORA wholesale. European and UK firms need the correct entity-level scope. Across Asia-Pacific, test the actual languages and service locations in the proposed alternative.
For operations in African, Middle Eastern and Latin American markets, check connectivity, local supplier availability, information-transfer restrictions and the people available to run a reduced service. Do not assume either that local provision is adequate or that an overseas alternative is accessible. These are due-diligence questions, not claims that entire regions share the same infrastructure or law.
At renewal, ask the business owner to show what the rehearsal changed: a better alternative, retained access to essential records, extra capacity or a narrower rollout. A supplier can remain the best primary choice while the organisation reduces its dependence on uninterrupted access. The goal is not to buy two of everything. It is to know which work will continue, who will deliver it and what that promise costs.
Three questions for the next renewal
CONTINUE
Essential work
What must still be delivered when the preferred supplier is unavailable?
Institute proposalREHEARSE
Acceptable fallback
Can the people, records and alternative service deliver it in time?
Institute proposalFUND
Recovery capacity
What staffing, access and supplier changes make the plan credible?
Institute proposal
Research record
Method and limitations
Method
Institute analysis of official supervisory communications, current statutory and prudential texts, international policy work, a vendor release and one newly submitted arXiv preprint. Source statuses and commencement dates were checked separately. The rehearsal is an original management proposal, not an evaluated intervention or legal advice. No private-chat wording, third-party artwork or endorsement is used.
Limitations
The EU warning concerns the financial system and cannot establish failure probabilities for individual suppliers or other sectors. Research is hardware-specific and not peer-reviewed in this record. Regional recommendations are questions for local review, not a complete legal inventory. No provider outage, switching performance or global adoption rate is inferred.
First published 24 September 2026 · Updated 24 September 2026 ·Research period September 2026 – September 2026 · Research current to 24 September 2026 · Version 1.1 · Suggested citation: The AI Institute, Rehearse Losing Your AI Supplier (2026).