# Go-Live Gates Owner: Operations with Engineering, Security, Compliance, Legal, Risk, Finance, Support and Executive Last updated: 2026-08-14 This document is an engineering and operations launch-control map. It is not legal advice and does not replace regulator, bank, provider, PCI, DORA, security, compliance or executive approval. ## Official Reference Points - De Nederlandsche Bank states that payment services in the Netherlands require DNB authorisation or an exemption: https://www.dnb.nl/en/sector-information/open-book-supervision/open-book-supervision-sectors/payment-institutions/licensing-requirement-for-payment-service-providers-overview/provision-of-payment-services/ - The European Commission describes DORA as the EU framework for financial-sector digital operational resilience, including ICT risk, incident handling and critical ICT third-party oversight: https://finance.ec.europa.eu/digital-finance/cyber-resilience_en - PCI SSC states that PCI DSS protects environments where payment account data is stored, processed or transmitted: https://www.pcisecuritystandards.org/standards/ - The European Commission identifies GDPR as the EU data-protection legal framework: https://commission.europa.eu/law/law-topic/data-protection/legal-framework-eu-data-protection_en ## Launch Rule Real-money launch remains blocked until every required go-live gate is `approved` or formally `waived` with evidence, approver name and audit trail. The API stores go-live evidence references in `go_live_gate_controls`. Production-like environments must also set config evidence references: - `BANKING_GO_LIVE_STAGING_SECRETS_REFERENCE` - `BANKING_GO_LIVE_PROVIDER_WEBHOOK_E2E_REFERENCE` - `BANKING_GO_LIVE_STAGING_OBSERVABILITY_REFERENCE` - `BANKING_GO_LIVE_SEED_USERS_REFERENCE` - `BANKING_GO_LIVE_GATE_A_REFERENCE` - `BANKING_GO_LIVE_CICD_EXERCISE_REFERENCE` - `BANKING_GO_LIVE_SECURITY_SCANNING_REFERENCE` - `BANKING_GO_LIVE_BETA_LEGAL_WORDING_REFERENCE` - `BANKING_GO_LIVE_SUPPORT_INCIDENT_CHANNELS_REFERENCE` - `BANKING_GO_LIVE_KNOWN_RISK_REGISTER_REFERENCE` - `BANKING_GO_LIVE_LEGAL_LICENSING_APPROVAL_REFERENCE` - `BANKING_GO_LIVE_PROVIDER_PRODUCTION_REFERENCE` - `BANKING_GO_LIVE_RECONCILIATION_LIVE_REFERENCE` - `BANKING_GO_LIVE_SECURITY_REVIEW_REFERENCE` - `BANKING_GO_LIVE_KYC_AML_OPS_REFERENCE` - `BANKING_GO_LIVE_DORA_APPROVAL_REFERENCE` - `BANKING_GO_LIVE_PCI_VALIDATION_REFERENCE` - `BANKING_GO_LIVE_BCDR_PRODUCTION_EVIDENCE_REFERENCE` - `BANKING_GO_LIVE_EXECUTIVE_SIGNOFF_REFERENCE` ## Gate A: Staging Launch Gate A proves the product can run safely in a production-like staging environment. Required gates: - 133. Staging uses non-default secrets. - 134. Test provider webhooks are verified end to end. - 135. Live staging dashboards and alerts are deployed and evidence is attached. - 136. Seeded test users cover customer, admin, KYC, AML, wallet, cards, SEPA, crypto, savings and FX flows. Minimum evidence: - Config snapshot or secret-manager evidence proving non-default secrets. - Staging webhook replay, signature, ordering and idempotency evidence. - Dashboard URLs, alert route test, on-call escalation evidence and screenshots or exported reports. - Seed command output and seeded user matrix. ## Gate B: Closed Beta With Test Money Only Gate B allows limited beta only after Gate A is complete and all customer-facing limitations are clear. Required gates: - 137. All Gate A items complete. - 138. CI/CD release and rollback process is exercised. - 139. Security scanning is active. - 140. Legal confirms beta wording does not imply real banking services. - 141. Customer support and incident channels exist. - 142. Known-risk register is approved by product, engineering, security and compliance. Minimum evidence: - Gate A evidence pack. - Release notes, migration plan, deployment manifest and rollback exercise. - Latest dependency, vulnerability, secret, DAST and container scan evidence. - Legal-approved beta wording and test-money disclaimers. - Support, complaint, security incident and major incident channel evidence. - Known-risk register with accountable owners and accepted residual risk. ## Gate C: Real-Money Production Gate C is the real-money launch decision. Code can record and enforce evidence gates, but it cannot grant licences, provider approval or regulatory permission. Required gates: - 143. Legal/licensing model approved for every target jurisdiction. - 144. Real providers integrated and contractually approved for production traffic. - 145. Reconciliation and break management are live. - 146. Security review, penetration test and remediation are complete. - 147. KYC/AML/sanctions/fraud operations are live with accountable owners. - 148. Formal DORA-style ICT risk, incident reporting, third-party risk and resilience controls are approved if EU financial regulation applies. - 149. PCI DSS scope and validation path are approved if cardholder data is handled. - 150. Backups, restore drills, DR plan and incident runbooks are tested with production-like evidence. - 151. Executive go/no-go signoff is recorded. Minimum evidence: - Counsel-approved legal memo pack and jurisdiction eligibility rules. - Signed provider contracts, credentials references, certification reports and production enablement approval. - Daily reconciliation evidence, break queue ownership, SLA and finance reporting. - External penetration-test report, remediation evidence and retest signoff. - KYC/AML provider readiness, sanctions/PEP/adverse-media monitoring, fraud escalation and regulatory reporting owner evidence. - ICT risk register, incident reporting workflow, third-party risk assessment and resilience testing evidence where DORA-style controls apply. - PCI DSS scoping memo, tokenization approach and QSA/issuer/acquirer aligned validation path where cardholder data is handled. - Backup/restore drill evidence, BCDR test, runbook exercise and incident notification drill. - Executive launch decision naming launch scope, risk acceptance, accountable owner and final approver. ## Admin Operations Admin endpoints live under `/v1/admin/go-live/*`: - Dashboard and all gates. - Staging Gate A controls. - Closed beta Gate B controls. - Real-money production Gate C controls. Writes require admin write scope and step-up authentication. Every write records an audit event with gate number, gate key, phase and status. ## Status Rules - `pending`: Work or external evidence has not started. - `in_progress`: Evidence is being collected. - `ready`: Evidence is attached and waiting for approval. - `approved`: Accountable approver accepted the gate. - `blocked`: Gate blocks launch. - `failed`: Verification failed and needs remediation. - `waived`: Formally accepted exception with evidence. `ready`, `approved` and `waived` require `evidence_reference`. `approved` requires `approver_name`. ## Closure Evidence Before any launch decision: - Export `/v1/admin/go-live/dashboard`. - Export relevant provider, legal, security, reconciliation and compliance evidence packages. - Verify audit events for each gate decision. - Attach executive go/no-go signoff for Gate 151.