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Why a market closure and an API outage need different tests
A trading agent may see no trades or receive errors in either situation, but the causes and safe responses differ. A scheduled closure comes from the venue’s calendar. An API outage means a dependency is unavailable or unreliable, even if the venue is open. A halt or missing status feed creates a third condition: the venue’s current state may be uncertain.
Use the actual calendar and status source for each venue and instrument. As a U.S. example, NYSE lists Tape A core hours as 9:30 a.m.–4:00 p.m. Eastern Time and publishes holidays and early closes. Its 2026 schedule lists a 1:00 p.m. Eastern close on November 27 and December 24; eligible options have a 1:15 p.m. close. Those details apply to the stated NYSE schedule, not every market or instrument. Confirm the current venue calendar before using dates in production tests.
Build separate test fixtures for a scheduled full closure, an early close, a confirmed venue halt, unavailable venue-status data, and an API failure while the venue is open. The agent should report which state it can establish, rather than infer closure from a lack of trades or treat every error as evidence that the venue is down.
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What to include in the test environment
Model the full chain that can affect a decision or order, not just the agent’s call to one API. Federal Reserve interagency operational-resilience practices emphasize critical operations, interconnections, third parties, severe-but-plausible scenarios, and continuity objectives. In practical terms, include:
- The agent and its decision, logging, and alerting components.
- The API gateway, broker or venue connection, market-data source, account and order-state interfaces, and risk controls.
- Regional infrastructure and shared dependencies such as DNS, identity, network routing, data services, and power.
- Third-party services and the people expected to supervise failover or take over open orders and positions.
A secondary region is not proven independent merely because it is geographically separate. Check whether it relies on the same identity, routing, data, or other critical services as the primary path. Include correlated failures when those shared dependencies could defeat failover.
Run tests in a segregated simulation or test environment; do not create live orders to demonstrate failure handling. For firms and systems covered by them, FCA Handbook provisions distinguish testing environments for specified conformance testing and address venue-specific interaction, data flows, throttles, feed loss, and recovery. The exact obligations depend on the firm, activity, instrument, venue, and jurisdiction.
Build a scenario matrix with explicit pass conditions
For each injected fault, define expected agent behavior before running the test. The following are engineering assertions derived from continuity, testing, and trading-system controls; they are not direct quotations of a universal regulatory checklist.
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| Scenario | Inject | Pass condition |
|---|---|---|
| Regional API isolation | With the venue open, make the primary-region connection time out or reset. | Retries are bounded; the agent declares degraded operation, alerts or escalates, and fails over only through a path shown to be independent. No duplicate order is submitted. |
| Partial outage or stale data | Keep the order API available while market data or account-state data is stale or unavailable. | Stale or incomplete inputs cannot authorize a new risk-increasing action. The agent reconciles current positions and live orders before resuming. |
| Rate limiting | Return throttling responses or slow service under load. | The agent respects backoff and message limits, does not amplify load through retries, and leaves risk controls active. |
| Lost order response | Allow an order request to reach the broker but drop its response. | The agent treats the order as uncertain, queries or reconciles its status before retrying, and escalates if the state cannot be resolved. |
| Scheduled closure | Set the authoritative calendar to a full-session closure. | The agent identifies expected closure rather than an API failure, follows its queue-or-block policy, and reports the next session accurately. |
| Early close | Set an early-close session and exercise requests around the cutoff. | The agent respects the session boundary and applicable auction timing rather than applying ordinary full-session hours. |
| Halt or unavailable venue status | Inject a confirmed halt, then separately make the status endpoint unavailable. | The agent distinguishes confirmed halt from unknown status, holds risky actions until authoritative status is available, and notifies an operator. |
| Regional failover | Disable primary infrastructure and activate the secondary region. | Market data, risk controls, staff communications, and outstanding order and position states are verified. Recovery time and data loss are measured against local objectives. |
| Orderly shutdown | Make safe recovery impossible. | Stop controls, cancellation policy, position management, audit trail, and operator handoff leave orders and positions in a known, escalated state without disorderly trading. |
How to run and evaluate each test
- Set the objective. Identify the critical service, minimum acceptable capacity, and locally chosen disruption tolerance before defining pass or fail. The Federal Reserve interagency paper connects continuity testing to a firm’s objectives; it does not prescribe one recovery-time target for every financial agent.
- Record the expected state. Capture the venue calendar and status, instrument, session boundary, market-data freshness, and account/order baseline. This makes it possible to tell an expected closure from an outage introduced by the test.
- Inject one fault, then correlated faults. Start with deterministic failures such as a timeout or dropped response. Then test plausible combinations, such as regional network impairment alongside identity or market-data degradation and unavailable supervisory staff.
- Check safety controls before availability. Confirm limits remain active, stale prices cannot authorize new orders, retry counts are bounded, and uncertain orders are reconciled instead of blindly resubmitted.
- Exercise the human fallback. Verify who receives the alert, who may disable the agent, who owns open orders and positions, and how normal operation is restored. FINRA’s AI guidance recommends extensive testing across lifecycle stages, users, data sets, and scenarios, and fallback plans if an AI application fails.
- Restore service deliberately. Require fresh venue status, market data, account state, and order state before enabling normal decisions. Verify recovery and any required shutdown or restart procedure rather than assuming that a successful connection means the system is safe to trade.
- Retain replayable evidence. Keep the injected fault, requests and responses, order identifiers, data-freshness decisions, agent and risk-control decisions, operator actions, and recovery outcome. Record remediation and approvals where applicable.
Choose test methods that match the risk
No single test method covers everything. Use a combination appropriate to the system’s dependencies and the consequences of an incorrect order.
| Approach | Useful for | Limitation to address |
|---|---|---|
| Deterministic mocks or fault injection | Repeatable timeouts, dropped responses, stale data, throttles, and boundary cases. | Mocks may not reproduce provider behavior, venue protocols, or dependencies shared across regions. |
| Provider or venue sandbox | Checking integration behavior and venue-specific protocol or data handling in a controlled setting. | A sandbox may not reproduce production scale, correlated regional failure, or real operational handoffs. |
| Controlled failover exercise | Testing regional transition, staffing, communications, recovery objectives, and order/position reconciliation. | Requires strong safeguards, agreed ownership, and a non-production or otherwise controlled execution boundary. |
Compare approaches on failure realism, coverage of correlated dependencies, market fidelity, execution safety, replayable evidence, and clear ownership across engineering, risk, compliance, operations, and third parties. The SEC’s 2003 policy statement on trading-market continuity is useful historical continuity context: it emphasizes testing backup effectiveness and considering operational capability when deciding whether to reopen. It is not a substitute for checking current requirements applicable to a particular firm or venue.
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When to rerun tests and what the rules do—and do not—say
Rerun relevant scenarios after material changes to the agent, venue connection, data feed, API provider, or regional architecture. FCA Handbook provisions for covered algorithmic-trading arrangements address conformance testing, continuity, open orders and positions, shutdown, and annual review and testing. FINRA Rule 4370 requires broker-dealers to maintain a written business continuity plan reasonably designed to let them meet obligations during an emergency or significant business disruption. Applicability varies: not every financial software agent or organization is directly subject to these provisions.
The Federal Reserve interagency paper consolidates existing regulations and guidance rather than establishing a universal new recovery target. Set recovery objectives for the service and firm locally, then test whether the agent meets them without sacrificing order and risk safety.
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