IncidentsComplianceOps

A Postmortem Template for Identity Incidents Caused by Infrastructure Outages

vverify

2026-02-03

11 min read

A ready-to-use postmortem template for identity/KYC incidents caused by cloud outages — SLAs, RCA fields, regulatory checklists, and remediation timelines.

Hook: When a cloud outage breaks KYC, your onboarding — and regulator trust — breaks faster

Cloud outages in late 2025 and early 2026 (notably incidents affecting major providers and CDNs) highlighted a hard truth for identity teams: availability problems become identity incidents the moment KYC pipelines fail. Fraud risk spikes, onboarding conversion collapses, and compliance teams need answers — fast. This postmortem template is built specifically for identity/KYC incidents triggered by infrastructure outages. It gives you SLA frameworks, detailed root cause analysis fields, a regulatory notification checklist, and a practical remediation timeline you can drop into your incident management system.

Why you need an identity-focused outage postmortem in 2026

Traditional postmortems assume application logic failures. Identity incidents are different: they combine user-facing availability, data-sensitive processing, third-party KYC providers, and regulatory obligations. In 2025–2026 regulators and examiners sharpened emphasis on operational resilience (DORA enforcement actions in the EU, expanded supervisory attention in financial services, and stronger incident reporting expectations more broadly). Meanwhile, identity fraud evolved — synthetic and AI-assisted attacks increased pressure on verification platforms. Those trends make a focused postmortem mandatory, not optional.

Key risks unique to identity outages

Compliance breach risk from delayed/failed identity checks (AML/KYC deadlines, audit trails lost).
Exposure to fraud as attackers exploit gaps in automated screening or forced fallbacks.
Conversion loss and revenue impact from higher friction or full stoppage of onboarding.
Regulatory scrutiny when outages affect large volumes of personal data or cause systemic service outages.
Third‑party cascading failures — failure at a cloud provider, CDNs, or identity vendor can propagate across verification flows.

How to use this template

This template is modular. Use it for your internal postmortem repository, to satisfy compliance teams, and as a starting document for regulator communications. Fill each field with evidence-backed answers; avoid assumptions. Attach logs, timelines, config snapshots, and vendor incident reports.

Ready-to-use identity incident postmortem template

1 — Executive summary (for executives & regulators)

Incident ID: [YYYYMMDD-org-incident-number]
Date/time window: Start: [ISO timestamp], End: [ISO timestamp] (UTC/aligned).
Impact summary: Number of users affected, failed verifications, geographic scope, percentage of onboarding blocked.
Severity level: S1 / P1 (See SLA definitions below).
Primary systems affected: KYC service, verification API, document OCR, identity graph, SSO, fraud engine, etc.
High-level cause: e.g., cloud provider network partition causing degraded access to identity provider endpoints.
Immediate mitigations taken: traffic re-routing, fallbacks, manual verifications, rate limiting.
Regulatory notifications: Completed / Pending — list recipients and timestamps.

2 — Timeline

Provide a chronological list of events with precise timestamps (UTC), actor (system/human), and source link to logs or dashboards.

[T+00:00] Alert triggered by monitoring: [alert name], metric threshold
[T+00:03] On-call engineer acknowledged
[T+00:10] Root cause hypothesis posted
[T+00:25] Mitigation A (e.g., roll-forward, config change) applied
[T+01:12] Partial recovery observed
[T+04:00] Full recovery confirmed

3 — Severity definitions and SLA mapping

Define severity consistently. Map each severity to SLA commitments that matter for identity flows (onboarding uptime, verification latency, escalation windows).

S1 / Critical: >50% of identity verifications failing or systemic outage affecting multiple regions. SLA: 15-minute on-call acknowledgement; 2-hour mitigation plan; target MTTR < 6 hours.
S2 / Major: 10–50% of verifications failing, single-region impact. SLA: 30-minute acknowledgement; 4-hour mitigation plan; MTTR target < 24 hours.
S3 / Minor: <10% of verifications failing, degradations in latency or accuracy. SLA: 2-hour acknowledgement; mitigation in next business day; MTTR target < 72 hours.

For commercial contracts with identity vendors, include SLOs for:

Verification success rate (e.g., >99.5% per 30-day window)
API uptime (e.g., >99.9%)
95th percentile verification latency
Mean time to acknowledge incidents
Compensation clauses for SLA breaches

4 — Root cause analysis (RCA) fields (evidence-first)

Use a disciplined RCA. Attach logs, traceroutes, screenshots of provider status pages, and vendor postmortem links.

Problem statement: One-line description of what failed and why it mattered to identity/KYC flows.
Scope & blast radius: Number of accounts, geographies, product surfaces affected.
Observable symptoms: API 5xx rates, latency spikes, queue growth, failed webhooks.
Evidence: Timestamps, request IDs, logs, Cloud provider incident IDs, CDN error pages.
Root cause: Use causal language (not blame). E.g., “A network control-plane change at CloudProvider X caused regional egress failures that prevented our verification webhooks reaching Provider Y, producing retries that exhausted our queue and caused timeouts in the KYC orchestration service.”
Contributing factors: list systemic issues: insufficient circuit breakers, lack of multi-region endpoints for vendor, missing telemetry, inadequate retry/backoff configuration.
Why it wasn't detected earlier: monitoring blind spots, missing healthchecks, aggregation thresholds too high.
Corrective actions (short-term): steps to restore service and temporarily mitigate risk.
Preventive actions (long-term): design changes, runbook updates, vendor contract changes.

Suggested RCA techniques

5 Whys (to connect symptom → systemic cause)
Fishbone diagram (categorize causes: Network, Vendor, App, Data, Process, People)
Time-correlated log aggregation across regions and vendors — for approaches to embedding observability, see Embedding Observability into Serverless Clinical Analytics — Evolution and Advanced Strategies (2026)
Replay tests in staging to confirm fix

5 — Regulatory & compliance notification checklist

Identity incidents often straddle incident reporting and data breach regimes. Use this checklist to prepare regulator-ready notifications. Always confirm local legal obligations and consult counsel.

Classify the incident: Availability outage vs personal data breach vs compliance service failure. Classification drives obligations (e.g., GDPR breach rules vs operational incident reporting).
Collect required facts:
- Start/end timestamps
- Systems and processes affected
- Number and type of persons affected (customers, employees)
- Types of personal data processed in the affected flows (IDs, biometric hashes, KYC documents)
- Immediate mitigations and remediation steps
Regulatory timing notes (guidance level):
- GDPR (EU): Personal data breaches — 72 hours for initial notification to supervisory authority when feasible. Provide details and follow-ups as new info emerges.
- DORA / EU operational resilience: heightened focus on ICT incidents; initial contact timelines have tightened in supervisory practice during 2025; notify competent authorities as required by your sector rules.
- Financial sector (varies by jurisdiction): Many supervisors expect early and ongoing engagement — often within 24–72 hours for major outages affecting KYC capabilities.
- U.S. state breach laws: timelines vary (commonly “without undue delay”); consult counsel for PII exposures.
Note: These are starting points. Validate specific timelines with legal/compliance. In 2025–2026, regulators increased enforcement activity and expect timely, evidence-backed updates.
Notification content checklist:
- Incident ID and classification
- Start and end timestamps and current status
- Systems and geographies impacted
- Estimated number of affected individuals/accounts
- Types/categories of data processed or exposed
- Root-cause summary and contributing factors
- Immediate mitigations and recovery steps taken
- Planned remediation and timelines
- Point of contact (name, role, secure contact channel)
- Commitment to regular updates and timeline for next update
Internal compliance steps:
- Engage legal counsel and Data Protection Officer (DPO)
- Notify internal risk committee and board if thresholds met
- Prepare customer communications and FAQs
- Coordinate with vendor(s) for joint communications and evidence

6 — Remediation timeline (sample)

Below is a practical remediation timeline you can adopt. Tailor owners and SLAs to your org size and regulatory obligations.

T+0–1 hour (Immediate):
- Escalate to SRE & Identity on-call
- Enable emergency fallbacks (e.g., route to alternate identity vendor, enable manual KYC queue)
- Open incident bridge and start timeline log
T+1–4 hours (Containment):
- Apply short-term mitigations (rate limits, feature flags to disable noncritical ops)
- Communicate internal stakeholders and compliance
- Start data collection for RCA
T+4–24 hours (Recovery):
- Restore verified traffic via fallback or region failover
- Confirm verification integrity and spot-check KYC approvals
- Prepare initial regulator/customer notification if required
T+24–72 hours (Stabilize):
- Monitor for residual errors
- Run reconciliation: reprocess or flag failed verifications
- Draft and send formal notifications and customer advisories
T+72 hours–30 days (Remediate & Prevent):
- Complete full RCA and publish to internal stakeholders
- Implement preventive changes (multi-region vendor endpoints, circuit breakers, synthetic transaction monitoring)
- Update runbooks and SLA contracts
- Deliver a postmortem report to regulators or auditors as required

7 — Evidence & attachments

Always attach the following:

Log exports (request IDs, correlated traces) — and ensure you have an automated, safe backup routine in place; see Automating Safe Backups and Versioning Before Letting AI Tools Touch Your Repositories for patterns that help preserve evidence.
Provider status pages and incident IDs
Network captures or traceroute outputs
Snapshots of queue/backlog metrics
Verification samples (redacted) showing failure modes
Slack/IMS bridge transcripts for timeline verification

8 — Post-incident checklist (ownership & verification)

Was the incident classification correct? (Yes / No — explain)
Are all affected users identified for remediation or notification?
Were regulatory obligations met? If not, explain gap and remediation plan.
Have runbooks been updated and tested?
Is additional testing or a post-fix deployment scheduled?
Did SLA or contractual commitments trigger credits or penalties with vendors?

9 — Sample remediation & preventative controls (identity-specific)

Multi-vendor verification routing: maintain two independent KYC providers and a smart router that fails over by latency and success rates — this aligns with consortium approaches like the Interoperable Verification Layer: A Consortium Roadmap for Trust & Scalability in 2026.
Regional vendor endpoints: prefer vendors with multi-region endpoints and include geographic fallbacks in orchestration logic.
Synthetic transaction monitoring: run hourly synthetic verifications from multiple regions to detect degraded behavior quicker than user complaints — pair that with embedded observability patterns referenced earlier (Embedding Observability).
Circuit breakers and backoff: protect downstream KYC vendors and your own queues from cascading retries; consider automating parts of your runbook and recovery flows with prompt-chain-assisted workflows (Automating Cloud Workflows with Prompt Chains).
Manual verification pathways: defined capacity, secure storage, and audit trails so identity teams can approve critical accounts during vendor downtime.
Telemetry for compliance: capture audit trails (who, what, when) for each KYC decision; store immutably to satisfy regulators.
Data residency-aware failovers: ensure fallbacks do not cause unlawful cross-border processing; pre-approve vendor failover regions in contracts.

Practical examples and patterns from recent 2025–2026 incidents

Incidents affecting CDNs and cloud control planes in late 2025 and early 2026 showed repeated patterns: large-scale network degradations that prevented webhook deliveries, causing orchestration systems to stall and verification queues to grow until timeouts triggered. In one widely reported outage affecting multiple providers, identity platforms that relied on single-region vendor endpoints experienced full verification blackouts for hours; those with multi-provider routing kept onboarding working with minor delays. Lessons learned include the need for synthetic checks, circuit breakers, and explicit vendor SLA clauses tied to identity throughput. For a focused guide on reconciling vendor SLAs across major clouds and platforms, see From Outage to SLA: How to Reconcile Vendor SLAs Across Cloudflare, AWS, and SaaS Platforms.

“When the cloud becomes opaque, your identity pipeline must be explicit.” — common refrain among identity engineering leads in 2026

Metrics to track post-incident

MTTD (Mean time to detect) — goal: under 5 minutes for S1
MTTA (Mean time to acknowledge)
MTTR (Mean time to recover)
Onboarding conversion delta — compare baseline to outage period
Number of manual verifications performed
False positives/negatives induced by fallback checks

How to communicate to customers during identity outages

Be precise and transparent. Customers care about whether their identity data was exposed, whether their KYC status is delayed, and what they should expect next.

Open with what you know and what you don't yet know.
Give actionable guidance: e.g., “If you are mid‑onboarding, please do not resubmit documents until 60 minutes after our next update.”
Offer escalation channels for high-value customers (dedicated support line, expedited manual review).
Follow up with a full postmortem to impacted customers where appropriate.

Actionable takeaways

Instrument synthetic identity flows and run them from multiple regions to detect vendor and network failures before customers do.
Define identity-specific SLAs (success rate, latency, MTTA/MTTR) and bake them into vendor contracts.
Adopt a disciplined, evidence-first RCA process; collect logs and provider incident IDs during the outage — they are required for regulator and auditor trust.
Create pre‑approved manual verification playbooks with clear audit trails and capacity planning.
Coordinate with legal/compliance early — initial notifications are often required within 24–72 hours depending on jurisdiction.

Final checklist (paste into your incident ticket)

Incident ID assigned
SLA severity set
Incident bridge created and recorded
Vendor status page links attached
Initial regulator notification drafted (if required)
Evidence bundle uploaded
RCA owner and remediation owner assigned

Closing: Why this matters in 2026

Identity incidents from infrastructure outages are no longer edge cases. Rising fraud sophistication, combined with regulators’ tightened operational resilience expectations in late 2025 and early 2026, make fast, rigorous postmortems essential. A structured, identity-specific postmortem reduces downstream risk — from regulatory fines to fraud losses to reputational damage — and helps you keep onboarding friction low while preserving compliance.

Call to action

If you want a downloadable, editable copy of this template (JSON/MD/Confluence), or a short workshop to adapt it to your identity stack and contracts, contact our team at verify.top. We help engineering, compliance, and risk teams operationalize identity resilience across cloud providers and KYC vendors — with runbooks, synthetic monitoring blueprints, and SLA contract language you can use in procurement. If you’d like an example micro-app to host templates and trigger postmortem workflows, consider this starter kit on shipping a micro-app with Claude/ChatGPT: Ship a micro-app in a week.

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