Business Continuity Plan vs Disaster Recovery Plan for Cyber Incidents

TL;DR: A business continuity plan (BCP) keeps essential operations running across the whole company during a disruption, while a disaster recovery plan (DRP) restores information technology (IT) systems and data. In a cyberattack, incident response (IR) contains the threat first, recovery follows, and continuity may run in parallel. Each plan needs a named owner and a written measure. Both need a tabletop exercise and a real restore test.

What is a business continuity plan, and how is it different from a disaster recovery plan

A business continuity plan (BCP) keeps essential operations running across the whole company during a disruption. A disaster recovery plan (DRP) restores information technology (IT) systems and data. The first protects the business. The second rebuilds the technology the business runs on.

Keiser University puts the split plainly: "While business continuity addresses the whole organization, disaster recovery zooms in on the technical infrastructure that powers modern operations" (Keiser University). J.P. Morgan notes that the two terms are sometimes used interchangeably, and says "knowing the differences is important" (J.P. Morgan).

What each plan covers

A BCP is not mainly a technology document. Prey's guide describes its focus as keeping the business moving "by coordinating people, processes, communications, and external dependencies" (Prey). In practice that means how orders get taken, how customers hear from you and how staff work when the usual tools are gone.

A DRP is narrower and more technical. IBM describes DR plans as protecting "data and IT systems from many different disaster scenarios" (IBM). J.P. Morgan's description includes plans to restore both data access and access to data backups after a disaster (J.P. Morgan).

Where cyber incidents fit

A cyberattack brings in a third plan: incident response (IR). Prey's summary is direct: "Incident response contains the active threat, disaster recovery restores the systems, business continuity keeps the business running" (Prey).

Sequence matters. Prey states that "In a ransomware attack, IR goes first and DR follows." It also warns that recovery time objective (RTO) and recovery point objective (RPO) are recovery measures, writing that "RTO and RPO measure recovery, not containment" (Prey). Restoring from backup before the attacker is out can bring the problem straight back.

Many companies now combine the two plans. IBM observes that more businesses are "practicing the two disciplines together, asking executives to collaborate on BC and DR practices rather than work in isolation" (IBM). In our reading, a combined program still needs two clearly named owners, so a quick check is to ask who declares each plan active and who signs off when it ends.

Business continuity and disaster recovery compared side by side

The first section set out what each plan covers. This one puts the two plans in a single grid, so a reader can see how they differ on the questions a board or an auditor tends to ask: who owns it, what sets it off, how long it runs and how success is judged.

Reading the grid

The owner row matters most for a security leader. Disaster recovery sits with the people who run the servers. In our reading, Continuity sits with the executives who run the business, which means the chief information security officer is usually a contributor to the continuity plan rather than its author. See our glossary entry on the CISO role for how that reporting line varies.

The success row is where the two plans split cleanly. A recovery plan can hit its targets while the business still fails its customers, because maximum tolerable downtime is a business measure, not a system one.

The two standards

On the continuity side, ISO 22301 is the international standard for Business Continuity Management Systems (BCMS). Teams certified to the 2019 edition should track the revision.

In our reading, on the recovery side, the National Institute of Standards and Technology guide is written for federal systems but is widely read beyond them. Its stated aim includes describing interrelationships between information system contingency planning and other types of security and emergency management-related contingency plans. It also ships a Business Impact Analysis (BIA) Template, which in our reading is the most practical place to start setting recovery targets.

We think the useful check for a reader is simple: put both plans side by side and confirm that each row has a named owner and a written measure. Where a row is blank, the plan is incomplete.

Where incident response sits between the two plans

The three plans run on different clocks. Incident response handles the attacker, disaster recovery handles the systems, and business continuity handles everything the business still has to deliver while both are underway. The sequence changes with the trigger, so a security leader should not assume a fixed order.

The order follows the trigger

Prey sets out a sequence for each type of disruption:

The physical case runs almost the reverse of the cyber case. In an office fire, Prey says disaster recovery and business continuity start together and incident response never enters. Prey's own warning is that activating the wrong plan first can delay recovery or increase risk.

Why incident response gates recovery in a cyber event

In an attack, restoring too early can bring the attacker back with the data. Prey puts it directly: until the threat is under control, attempting recovery or restoration can make things worse.

That is why the incident response team needs its own scorecard. Prey lists its measures as detection time, containment time and response speed. Those numbers belong to a different team and a different phase from the recovery targets covered in the comparison above.

Business continuity does not wait its turn

Continuity is the plan with the loosest start time. Prey says it may activate in parallel with incident response or disaster recovery, or when downtime extends beyond acceptable limits.

In our reading, this is the decision boards most often leave unassigned. Someone has to judge, while containment is still running, that the outage has gone on long enough to move customers to manual workflows. That call should sit with a named executive, not with the incident commander.

Where siloed plans fail

Prey points out that all three share the same inventory, contacts, and dependencies, and that writing them separately is paid for on the day all three activate at once. A ransomware event is that day: the attacker is still active, systems are down, and customers are calling.

A practical starting test, again from Prey: take your last incident and answer which of the three plans activated, who declared it, and whether anyone wrote it down afterward. If those three answers take more than a few minutes to find, the handoffs between plans need work before the next event. For how disclosure duties overlap with these phases, see the Form 8-K Item 1.05 glossary entry.

What NIST SP 800-34 and ISO 22301 actually require

In our reading, two documents sit behind most continuity and recovery programs. One is federal guidance for information systems. The other is an international requirements standard for a management system. Knowing which is which keeps a policy from citing the wrong edition.

NIST SP 800-34 Rev. 1

The National Institute of Standards and Technology (NIST) publishes SP 800-34 Rev. 1 as the Contingency Planning Guide for Federal Information Systems. The current record is dated May 2010, updated November 11, 2010. The original May 2010 release was withdrawn on November 11, 2010, and the 2002 edition was withdrawn on May 31, 2010.

It is guidance, not a certification scheme.

The abstract covers the interrelationships between information system contingency planning and other security and emergency management plans, organizational resiliency and the system development life cycle. That is where the IT contingency plan connects to the business plans around it.

NIST also provides contingency plan templates for low, moderate and high impact systems. The 2002 edition defined a seven-step contingency process. A team that still quotes that list as current is quoting withdrawn text.

ISO 22301:2019

ISO describes it as a framework for a documented management system to protect against, reduce the likelihood of, and ensure recovery from disruptive incidents.

An amendment, ISO 22301:2019/Amd 1:2024, added climate action changes. ISO notes that a standard is reviewed every 5 years. The 2019 edition now sits at stage 90.92, to be revised, and ISO lists a committee draft, ISO/CD 22301, under development as its replacement.

In our reading, the split is practical. NIST explains how to build an IT contingency plan. ISO 22301 sets requirements that an auditor can test a continuity program against.

Two quarterly checks

1. Check the NIST citation. The plan owner and a reviewer from internal audit read the continuity and recovery policies and search for the citation string. It should read SP 800-34 Rev. 1 Update 1 of November 2010. Any reference to the 2002 text, or to its seven-step list as current guidance, gets rewritten.
2. Check the ISO citation. The same two readers search for ISO 22301:2019. They note whether the policy addresses the 2024 amendment, and they record the current ISO/CD 22301 status each quarter so a gap analysis can start before the next edition is published.

How to test both plans against a cyber scenario

A plan that has never been exercised is a draft. Test the business continuity plan and the disaster recovery plan in two ways: a discussion-based tabletop for the people who make decisions, and a hands-on restore test for the systems. Then run one cyber scenario that forces both plans to work together.

Tabletop exercises with the ready.gov kit

The federal preparedness site ready.gov publishes three working documents for a business continuity plan test (ready.gov):

• Situation manual. The scenario participants read and respond to.
• Exercise planner instructions. How to scope, schedule and build the exercise.
• Facilitator and evaluator handbook. How to run the session and record what happened.

In ready.gov's six-step training sequence, the final step addresses how organizations should "test" their plans (ready.gov). The older Business Continuity Planning Suite software is no longer supported or available for download (ready.gov), so the three documents are the usable kit.

We think the evaluator role matters most. Assign someone who is not playing, and have them log each decision, who made it and how long it took.

Technical restore tests

A tabletop shows whether people know the plan. It does not show whether a backup restores. Travelers advises reviewing the continuity plan yearly, running tabletop exercises, and testing backup systems and data integrity so recovery is possible when needed (Travelers).

NIST (the National Institute of Standards and Technology) frames its Special Publication 800-34 as guidance to help personnel evaluate information systems and operations and set contingency planning priorities (NIST). Use that priority list to choose what to restore first. Restore a real system from backup into an isolated environment, time it against the target in your plan, and confirm the data is complete.

One ransomware scenario for both plans

Ransomware is the scenario we would pick, because it touches the business side and the technical side in the same hour. Build it from injects, released one at a time, and follow the activation order covered earlier in this guide.

Pair the tabletop with a restore test of the same systems the scenario named. If the room assumed a system would be back by midday and the restore took two days, that gap is the finding. Write it down, assign an owner and date, and rerun the test once it is fixed.

Who owns each plan and how they connect to disclosure decisions

Ownership of the two plans rarely sits in one place, and that split matters most in the first days of a cyber incident. The continuity plan answers to the business. The recovery plan answers to technology. The chief information security officer (CISO) usually sits between them, holding the incident facts that both plans depend on.

How the split usually looks

One university guide describes the disaster recovery team as typically led by the IT department. It sets business continuity apart because it addresses the whole organization, and it lists assign clear roles among its implementation steps.

The topic has also moved up the CISO's agenda. Ryan Whelan, global head of cyber intelligence at Accenture, is quoted saying disaster recovery and business continuity "skyrocketed from not even in the top 10 in 2024 to No. 3 in 2025" among CISO priorities.

Why recovery timelines feed the materiality question

A public company assessing a cyber incident under Form 8-K Item 1.05 has to judge whether the incident is material. In our reading, the CISO's technical findings are only part of that picture. The disclosure committee also needs to know how long operations were impaired and how long restoration will take. Those answers live in the continuity and recovery plans, owned by people outside security.

We think this is where a split ownership model breaks. If the continuity lead tracks outage hours in one place and IT tracks restore status in another, the people weighing materiality get two partial timelines. A plain example: the recovery plan logs core systems as restored, while the continuity plan shows order processing still running on manual workarounds. Both are true, and the gap between them is the operational impact.

NIST publishes a Business Impact Analysis (BIA) Template (docx) alongside SP 800-34. In our reading, an analysis done in advance gives the committee a baseline. It sets out what each function's downtime was expected to cost, so actual outage figures can be compared against it.

What a reader can check

• Whether each plan names an owner who reports outage and restore status to the disclosure committee, and on what schedule.
• Whether the continuity and recovery logs record timestamps that can be reconciled into one timeline.
• Whether the CISO's reporting line gives a direct route to the people who make the disclosure call.

This section does not say when an incident becomes material. That is a judgment for the company and its counsel. Our materiality decision guide sets out how the Item 1.05 decision is structured.

What this guide does not cover

This guide does not say when a cyber incident becomes material for Form 8-K Item 1.05 purposes: that is a judgment for the company and its counsel. For the rules and the record behind it, see CISO Personal Liability: What SEC v. SolarWinds and the Uber Case Actually Decided.