A system separation can be postponed. An unbundling under the supervision of the Federal Network Agency cannot. There the deadline is a law, not a suggestion.
Honest about my role: in this carve-out I was responsible for the base and infrastructure sub-area, not the overall lead. That is the usual lot of the external for the central functions. Still it holds: an industry project is an industry project. A regulatory carve-out is more critical than a purely business-driven one, because alongside the operational separation, unbundling, verifiability and formal compliance also have to be met.
Four things drive the criticality: the unbundling obligations themselves, official approval and notification processes, critical components with their security requirements, and the significantly heightened documentation and evidence burden. Punctuality here is not a project goal but a compliance factor. When deadlines, day-1 readiness or transitional arrangements break, delay quickly turns into non-compliance.
Why the cutover was the risk
It was about 15 systems in six test phases. Because the procedures were played through completely six times, one could be fairly sure of the mechanics. The test systems were freshly copied from the productive environment at every restart, so you always tested against the most current state. The actual cutover was thus the most critical moment, and the organizational change management the real mammoth task, not the technology.
The internal supervision, audit team and steering committee, was involved throughout. To my knowledge, no escalatory intervention by the external supervisor was necessary. That is no coincidence. Where the examiner sits in the room, „it’ll be fine“ is no answer, and you build from the start so that he does not have to intervene.
When your next deadline is regulatorily armored, do not treat it like a project milestone. A postponed milestone costs time. A missed deadline under supervision costs compliance.
