Disruptive effects for critical entities

The Critical Entities Resilience (CER) Directive sets a new benchmark for how essential services in the European Union should be protected and governed in the face of disruption. Unlike previous approaches that often focused narrowly on physical protection or sectoral compliance, the CER Directive introduces a system-level perspective, requiring Member States and operators to assess the significance of disruptive effects. This shift matters because resilience today is not simply about preventing for example, accidents but rather about anticipating how disruptions cascade across interconnected societies, economies and ecosystems.

To operationalise this shift, six key criteria are outlined to guide assessments of disruptive effects. These criteria are not checkboxes but rather lenses through which organisations, regulators and policymakers can understand vulnerabilities and prioritise resources. They help bridge technical, societal and economic dimensions of resilience.

Defining “Disruptive Effect” in the CER Context

The CER Directive introduces the notion of a “disruptive effect” as the central threshold for determining whether an incident involving an essential service is significant. This is not simply a linguistic distinction it marks a shift in European resilience policy from focusing on hazards and threats toward understanding consequences and systemic impacts.

In operational terms, a disruptive effect can be defined as an interruption, degradation or loss of function in an essential service that materially undermines the continuity of society, the economy, public safety or the environment. This definition goes beyond immediate outages. It includes slow-building crises such as supply shortages or cumulative impacts like reputational erosion that may weaken institutional trust over time.

Importantly, the Directive requires that the significance of a disruptive effect be assessed through six criteria. This recognises that “significance” is not an abstract legal category but the result of structured evaluation, balancing quantitative thresholds (e.g. number of users affected) with qualitative judgements (e.g. vulnerability of specific groups, public trust implications).

In this sense, “disruptive effect” is best seen as both an analytical construct and a governance tool. It enables Member States and operators to speak a common language when prioritising risks, allocating resources and coordinating cross-border responses. The following sections explore these criteria in more detail.

The first criterion is the scale of reliance i.e. how many people, organisations and communities depend on a service. This is not a purely quantitative exercise. While headcounts matter, the type of reliance is equally important. Direct reliance is straightforward such as households consuming water or electricity. Indirect reliance captures the role of services in enabling broader societal functions, such as ICT supporting healthcare, finance and logistics.

Intensity of use and the presence of vulnerable groups add qualitative weight. A disruption to electricity during winter affects elderly populations more severely than other groups. Similarly, the failure of public transport has disproportionate impacts on low-income households with no alternative mobility options. Estimation tools such as population registries, census data or demand modelling can help quantify these dynamics, but decision-makers must also account for context-specific vulnerabilities. Sector-specific examples like airports serving as regional lifelines illustrate that reliance is often about function rather than sheer numbers.

Resilience assessments must also consider interdependencies, as essential services are woven into complex systems. Dependencies may be one-directional such as hospitals depending on uninterrupted energy while interdependencies can also reflect reciprocal reliance, such as between ICT and energy. Disruptions often cascade, triggering secondary and tertiary failures across supply chains, sometimes extending across borders.

Analytical tools such as system mapping, dependency matrices and network analysis allow for structured identification of critical nodes and weak links. For example, a port is not just a transport node but also a hub for energy imports, food supply chains, and industrial logistics. Understanding these interdependencies highlights why resilience cannot be siloed by sector. For policymakers, this criterion reinforces the importance of cross-sector coordination and information-sharing platforms that can anticipate ripple effects before they materialise.

This criterion broadens the scope of assessment beyond immediate operational losses to the full spectrum of consequences. Economically, disruptions can erode productivity, destabilise supply chains and reduce competitiveness in the long term. Societal continuity can be threatened when disruptions undermine public confidence, trigger unrest or stall vital services like education and mobility.

Environmental consequences, often overlooked, are equally significant. For instance, wastewater system failures can lead to pollution incidents, while transport breakdowns may heighten carbon intensity by forcing reliance on less efficient alternatives. Safety and health dimensions are paramount, from acute risks such as accidents or delayed emergency responses to chronic outcomes like psychological stress or increased inequality. Structured methods, including cost-benefit analysis, epidemiological surveillance and climate models, provide ways to monitor and anticipate these impacts. Collectively, this criterion underlines resilience as a multi-dimensional public good.

Market structure influences systemic importance in ways that are not always intuitive. Entities with high market share, such as a dominant national telecom provider, clearly present concentrated risk. Yet smaller entities can also be critical when they provide unique or non-substitutable services. A regional operator maintaining a specialised energy interconnector may have outsized importance despite modest overall market share.

Decision-makers need to weigh concentration risks alongside qualitative assessments of uniqueness and substitutability. Policymakers must balance two imperatives, reducing monopolistic exposure while also recognising the irreplaceability of niche actors. This criterion therefore acts as a reminder that market dynamics and resilience are closely intertwined, requiring regulators to look beyond size alone.

The disruptive impact of a service failure depends heavily on the geography involved. Localised disruptions may be severe but containable, while failures with national or cross-border reach can destabilise entire regions. Vulnerable geographies amplify risks such as islands with limited redundancy, rural communities with fewer service alternatives and dense urban areas where small failures can scale rapidly.

For example, a failure in a single energy substation may affect only one district, but a disruption to a national grid interconnector could spill into neighbouring countries. Understanding geographic scope allows governments and operators to calibrate response measures proportionately, ensuring that both local vulnerabilities and systemic interconnections are accounted for in resilience planning.

Finally, the presence or absence of alternatives determines the severity of disruption. In some domains, redundancy is built in with, for example, ICT services being rerouted across networks and freight being able to possible shift from rail to road. In other domains, however, alternatives simply do not exist. Drinking water, emergency care and air traffic control are examples where substitutes are either unavailable or inadequate.

Even where alternatives exist, cost, quality and accessibility must be factored in. Substitution may buy time but at higher financial or environmental cost or at reduced service quality. Comparative examples highlight the diversity of outcomes: the redundancy of multiple mobile networks contrasts with the non-substitutability of certain medicines. Policymakers can use this criterion to guide investment in redundancy, clarify minimum service obligations and avoid over-reliance on fragile single points of failure.

From criteria to capability

The six criteria outlined in this article provide a comprehensive framework for understanding disruptive effects. Together, they encourage decision-makers to look beyond technical continuity and consider resilience as a systemic, multi-dimensional challenge.

For public administrations, the criteria demand a more integrated style of governance. Demographic vulnerabilities must be linked with economic dependencies, cross-border interconnections must be mapped alongside national assets and resilience planning must be elevated from sectoral silos to whole-of-society strategies. This requires institutions not only to coordinate across ministries and borders, but also to invest in foresight and intelligence-sharing mechanisms that anticipate cascading disruptions before they materialise.

For operators of essential services, the criteria call for a reorientation of strategy. Risk management must evolve from compliance-driven exercises to proactive resilience design. This involves embedding interdependency mapping into investment decisions, stress-testing business continuity against both acute shocks and chronic pressures and transparently communicating resilience measures to regulators, investors and the public. In doing so, organisations reinforce not only their operational robustness but also their social licence to operate.

At a broader level, the Directive underscores an important truth in that resilience is inseparable from trust. Essential services are the backbone of societal continuity and the ability to anticipate, absorb and adapt to disruption determines public confidence in institutions and markets alike. Applying the six criteria rigorously will therefore serve a dual purpose by securing the continuity of essential services and reinforcing the legitimacy of European resilience governance.

Ultimately, the Directive recognises that resilience is not a fixed state but an adaptive capacity. By applying these six criteria thoughtfully, Member States and essential service providers can better anticipate vulnerabilities, prioritise investments, and maintain the trust of the societies they serve.