A financial technology startup, set an ambitious goal: win the European Union tender to deliver a robust and compliant pre and post-trade real-time consolidated tape. This system would provide investors across the EU with a transparent, low-cost view of trading data for all shares and ETPs.
The stakes were enormous. ESMA (European Securities and Markets Authority) would expect all bidders to demonstrate comprehensive cybersecurity compliance. For this organization, this meant competing against established financial institutions with decades of compliance experience.
Their starting point? Two founders, a handful of consultants, and virtually no cybersecurity infrastructure in place.
"Thank you for all your contributions since you joined in December and helping us with a solid foundation for our company's InfoSec, Risk Management and Compliance setup."
BARE Cybersecurity partnered with the organization in December 2024 to build their cybersecurity foundation from the ground up.
Over the course of nine months, we executed multiple workstreams in parallel:
Strategic Foundation:
Comprehensive security policy development
Initial Threat Modeling exercises
IT Risk assessment
Technical Implementation:
System hardening to CIS IG2 standards
Security reviews of the initial architecture
Robust onboarding/offboarding procedures
Compliance Preparation:
ISO 27001 gap analysis and remediation
Risk management framework implementation
Audit-ready documentation and processes
Before: A promising startup with ambitious goals but minimal security infrastructure.
After: An enterprise-grade organization progressing toward ISO 27001 certification with comprehensive DORA compliance.
The transformation was comprehensive:
Zero to enterprise-grade internal security posture
Complete policy framework covering all aspects of information security
Strategic roadmap for sustained compliance and growth
Competitive positioning for the EU tender through demonstrable security maturity.
The robust security posture now serves as a competitive advantage in their bid for the EU consolidated tape tender. While competitors scramble to meet baseline security requirements, the organization can focus on its technical innovation and market approach.
The cybersecurity foundation positions them to:
Meet ESMA's stringent compliance expectations
Handle sensitive trading data across multiple EU jurisdictions
Scale securely as they grow their market presence
Demonstrate operational resilience to regulators and partners.
This journey highlights a critical reality: ambitious fintech goals necessitate enterprise-grade security from the outset.
Whether you're pursuing regulatory approval, enterprise partnerships, or investor funding, cybersecurity readiness isn't optional—it's your competitive edge.
The lesson? Don't wait until compliance becomes a pressing issue. Start building your security foundation early, and transform regulatory requirements from obstacles into advantages.
For the full case study, contact us at sales@bare-consult.nl.
