A Leading UK Life and Pensions Provider Secures Data Sovereignty and Measurable Operational Resilience for 2 Million UK Policies on AWS

Under FCA and PRA operational resilience rules, one of the UK's largest life and pensions providers partnered with Wipro and AWS to keep policyholder data under UK jurisdiction and customer control while modernizing a 7,000-server estate, with resilience that can be measured and evidenced, not asserted.

The Opportunity

What the client needed to unlock

The client is one of the UK's largest long-term savings and retirement businesses, managing more than £290 billion in assets under administration for millions of customers. Through one of its subsidiaries, the firm operates the ALPHA Platform, its proprietary policy administration and business orchestration engine. ALPHA supports approximately two million life and pension policies. Each policy holds personal, financial and health data about UK citizens for which the firm is legally accountable.

As the business consolidated acquired books of business onto ALPHA, the firm needed a technology foundation that could grow with the platform while satisfying a new and demanding regulatory standard. The Financial Conduct Authority (FCA) operational resilience policy (PS21/3) and the Prudential Regulation Authority (PRA) parallel requirements (SS1/21) required the firm to identify its important business services and set impact tolerances. By March 31, 2025, the firm also had to demonstrate that it could stay within those tolerances through severe but plausible disruption. The PRA’s outsourcing rules (SS2/21) added that any cloud arrangement must preserve the firm’s control over its data, its ability to audit and exit, and full visibility for supervisors. Separately, UK General Data Protection Regulation (GDPR) governed where policyholder data could reside and who could access it.

The timing mattered. The existing estate of roughly 7,000 on-premises servers, hosting business applications, virtual desktops and Oracle and SQL Server databases, was approaching end of life and concentrated on a single site. The estate could support today's operations, but it could not generate the continuous, auditable proof of data residency, access control and tested recovery that supervisors now expected. Success meant more than a migration: it meant a platform on which digital sovereignty and resilience were properties of the architecture, with recovery objectives proven under test rather than documented on paper, achieved without any interruption to policyholders.

The Strategy

Our consulting-led, AI-powered approach

Wipro shaped a 36-month program with the client and AWS that treats sovereignty and resilience as design principles rather than post-migration checks. Three choices defined the approach.

Sovereign by design. Rather than asking every application team to prove compliance individually, Wipro embedded the controls into the AWS Landing Zone so that each workload inherits them. Service control policies and AWS Control Tower guardrails confine production to the AWS Europe (London) Region and disaster recovery replicas to the EU. AWS Key Management Services (KMS) customer-managed keys keep decryption authority with the firm; the AWS Nitro System prevents operator access to customer data. AWS CloudTrail and Virtual Private Cloud (VPC) VPC Flow Logs record every action and data flow across every account. Compliance became something the platform generates continuously through AWS Config conformance packs and AWS Security Hub, rather than something assembled for an audit.

Resilience that is measured, not described. Working from the client's impact tolerances, Wipro classified every workload into resilience tiers and matched each tier to an AWS disaster recovery pattern with an explicit recovery target including:

Warm Standby in Frankfurt for mission-critical services such as ALPHA Core, payments, claims, customer portals and the contact centre
Pilot Light for business-critical workflow, document management and API services; and backup-and-restore for reporting and batch.
Continuous database replication, automated failover orchestration and immutable, air-gapped backups give each tier its target, and a defined drill protocol measures recovery time and data loss against those targets so that evidence accumulates with every exercise.

Evidence gated at every milestone. The migration is organized into nine phases, each gated on regulatory evidence rather than on technical completion. Powered by Wipro Intelligence™, Wipro's migration factory applied automated discovery and dependency mapping across the full estate, classifying data by sensitivity and regulatory scope so that sequencing decisions were driven by risk and business criticality. Modernization was folded into the same waves including:

Citrix desktops moved to Amazon WorkSpaces
Oracle to Oracle Exadata Database Service on AWS and SQL Server to Amazon RDS, each with customer-controlled encryption, so the firm gains modern platforms without a separate transformation program.

The Proof

Measurable outcomes, powered by Wipro Intelligence™

Across the phases completed to date, the program has delivered measurable results in sovereignty, resilience, compliance and cost:

Two million policies retained under UK jurisdiction in EU-West-2, with Region lock enforced by SCPs and Control Tower guardrails and DR replicas held within the EU in EU-Central-1.
100% of regulated data encrypted under customer-managed AWS KMS keys, with key policies and access logging owned by the client.
Recovery objectives of minutes RTO and seconds RPO defined for ALPHA Core and other mission-critical services through Warm Standby and continuous Aurora Global Database replication; under 60 minutes RTO and minutes RPO for business-critical services; 24-72 hours for standard workloads. DR event handling demonstrated on foundational and test workloads at Landing Zone readiness, with Security Incident Response Simulations (SIRS) SIRS scenarios completed and timestamped records retained as supervisory evidence.
100% regulatory compliance maintained through every completed migration phase, with continuous evidence from AWS Config and Security Hub and 7-year retention of resource history, data-flow logs and backups.
7,000 servers discovered, dependency-mapped and classified by regulatory scope, with initial migration waves live in the London Region across a 36-month, nine-milestone roadmap.
3,500+ virtual desktops modernized on Amazon WorkSpaces, with an estimated 40% reduction in virtual desktop licensing cost at full implementation.
Milestone-based AWS investment secured against delivery outcomes, reflecting shared commitment across the client, Wipro and AWS.

The Impact

What this unlocked for the business

The client's regulators asked for a demonstrable ability to remain within impact tolerances and for control over its data in the cloud. The client now has both, enforced by architecture. Where resilience was once a statement in a policy document, it is a tiered recovery capability that is exercised, measured and reported at every migration milestone, and where data residency was once a contractual assurance, it is a Region lock that cannot be bypassed even by accident.

That changes how the organization operates. Compliance evidence is generated by the platform as a by-product of running it, so supervisory requests are answered from live posture rather than from assembled artefacts, and the operational resilience team can show sustained performance rather than a one-off test. Because every new workload inherits the same sovereignty and recovery posture, the firm can take on additional books of business and launch new capabilities, from advanced analytics to AI-driven policy management, without reopening the regulatory conversation each time.

For a business whose licence to operate rests on protecting the retirement savings of millions of people, the result is an enterprise that can modernize at the pace the market demands while giving the FCA and PRA evidence, at any time, that policyholder data stays where it should, is accessed only by those who should access it, and can be recovered within the limits the firm has committed to. The client, Wipro and AWS are showing that regulated financial institutions can achieve digital sovereignty, operational resilience and innovation on the public cloud without compromise.