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What Is the Digital Operational Resilience Act (DORA)?
The Digital Operational Resilience Act (DORA) is a EU regulation designed to strengthen the resilience of financial entities and ICT service providers across the European Union. Under this regulation, financial institutions must implement robust ICT risk management frameworks, conduct operational resilience testing, and manage third-party and critical ICT risks effectively.
DORA compliance is mandatory for a wide range of financial entities and ICT providers, ensuring preparedness against ICT-related incidents, cyber threats, and operational disruptions. At A2CO, we help you understand DORA, build compliance strategies, and engage with supervisory authorities across the EU.
Understanding the DORA Regulation and Compliance Framework for Financial and ICT Service Providers
Understanding DORA and the EU Digital Operational Resilience Act
The DORA regulation (2023/2554) sets uniform compliance requirements for ICT risk management across the financial sector. It applies to banks, payment institutions, investment firms, crypto asset service providers, and ICT third-party service providers. Critical ICT third-party service providers are subject to an EU oversight framework, which includes inspections, investigations, and possible penalties.
Who Is Impacted by DORA and How It Affects Financial Entities
DORA applies to almost all EU financial entities together with ICT service providers that support them. This means that organisations must strengthen their operational resilience to withstand cyber threats and systemic risks. For critical ICT third-party service providers, DORA introduces specific requirements under direct oversight from European supervisory authorities.
Key DORA Requirements for Financial Services and ICT Providers
Entities must establish and maintain an ICT risk management framework that reflects their size, complexity, and risk profile. This framework must:
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Define governance arrangements, clear roles, and responsibilities.
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Include an ICT risk strategy supported by policies for identifying, monitoring, and mitigating ICT risks.
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Address asset management, detection and response mechanisms, backup and recovery, and learning from past incidents.
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Undergo regular testing and continuous improvement, overseen by the management body.
For further guidance, you may also review our services in AML and KYC Outsourcing, Audit Coordination, and GDPR Compliance.
The DORA Framework: Scope, Oversight, and Compliance Requirements
he DORA framework introduces uniform requirements for managing ICT third-party risk:
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Keeping a register of all outsourcing arrangements.
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Carrying out risk assessments before contracts are signed.
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Ensuring contracts address data protection, audit rights, service levels, access controls, and termination clauses.
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Preparing contingency and fallback solutions to deal with possible disruptions.
While services can be delegated, accountability remains with the leadership of financial institutions.
Cyber Resilience and Risk Management Under DORA
DORA requires structured handling of ICT-related incidents. This includes:
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Early warning indicators and incident classification systems.
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Clear responsibilities and communication strategies for staff, stakeholders, clients, and media.
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Escalation procedures and reporting to senior management.
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Appointment of a designated contact for public communication.
These measures ensure the cyber resilience of financial entities and protect the stability of the EU financial sector.
Understanding DORA and the EU Digital Operational Resilience Act
The DORA regulation (2023/2554) sets uniform compliance requirements for ICT risk management across the financial sector. It applies to banks, payment institutions, investment firms, crypto asset service providers, and ICT third-party service providers. Critical ICT third-party service providers are subject to an EU oversight framework, which includes inspections, investigations, and possible penalties.
Who Is Impacted by DORA and How It Affects Financial Entities
DORA applies to almost all EU financial entities together with ICT service providers that support them. This means that organisations must strengthen their operational resilience to withstand cyber threats and systemic risks. For critical ICT third-party service providers, DORA introduces specific requirements under direct oversight from European supervisory authorities.
Key DORA Requirements for Financial Services and ICT Providers
Entities must establish and maintain an ICT risk management framework that reflects their size, complexity, and risk profile. This framework must:
-
Define governance arrangements, clear roles, and responsibilities.
-
Include an ICT risk strategy supported by policies for identifying, monitoring, and mitigating ICT risks.
-
Address asset management, detection and response mechanisms, backup and recovery, and learning from past incidents.
-
Undergo regular testing and continuous improvement, overseen by the management body.
For further guidance, you may also review our services in AML and KYC Outsourcing, Audit Coordination, and GDPR Compliance.
The DORA Framework: Scope, Oversight, and Compliance Requirements
he DORA framework introduces uniform requirements for managing ICT third-party risk:
-
Keeping a register of all outsourcing arrangements.
-
Carrying out risk assessments before contracts are signed.
-
Ensuring contracts address data protection, audit rights, service levels, access controls, and termination clauses.
-
Preparing contingency and fallback solutions to deal with possible disruptions.
While services can be delegated, accountability remains with the leadership of financial institutions.
Cyber Resilience and Risk Management Under DORA
DORA requires structured handling of ICT-related incidents. This includes:
-
Early warning indicators and incident classification systems.
-
Clear responsibilities and communication strategies for staff, stakeholders, clients, and media.
-
Escalation procedures and reporting to senior management.
-
Appointment of a designated contact for public communication.
These measures ensure the cyber resilience of financial entities and protect the stability of the EU financial sector.
Preparing for DORA Compliance and Meeting EU Digital Operational Resilience Requirements
Preparing for DORA Compliance
From January 2025, financial entities must achieve DORA compliance and show they can withstand ICT threats and disruptions. Practical steps include:
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Reviewing ICT risk management frameworks.
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Updating outsourcing agreements with ICT service providers.
-
Implementing structured incident management procedures.
-
Conducting regular testing of digital operational resilience.
DORA Compliance Checklist for Financial Entities and ICT Service Providers
The DORA compliance checklist includes:
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A functioning ICT governance and risk management framework.
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Registers of all third-party service provider contracts.
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Documented incident response and reporting procedures.
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Regular testing of digital operational resilience.
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Participation in trusted cyber threat information-sharing arrangements.
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Notification to supervisory authorities when joining or leaving such arrangements.
Alignment of DORA with EU Directives and Regulations
The EU Digital Operational Resilience Act complements other EU directives and regulations such as GDPR and MiCA. Together, these frameworks strengthen the operational resilience of financial entities within the EU, addressing cybersecurity, digital risk, and data protection in a unified way.
Incident Reporting and Testing of Digital Operational Resilience
Under the DORA regulation, entities must regularly test ICT systems that support critical functions and report major ICT-related incidents promptly. Requirements include:
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Annual vulnerability assessments, performance tests, and penetration testing.
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Advanced Threat-Led Penetration Testing (TLPT) for critical ICT services.
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Full cooperation from ICT third-party service providers during resilience testing.
Regulation Summary: Long-Term Impact of DORA
The Digital Operational Resilience Act establishes a permanent framework for digital resilience across the EU financial sector. It ensures that financial entities can resist ICT disruptions, recover from incidents, and contribute to sector-wide cyber resilience through reporting and information sharing.
Preparing for DORA Compliance
From January 2025, financial entities must achieve DORA compliance and show they can withstand ICT threats and disruptions. Practical steps include:
-
Reviewing ICT risk management frameworks.
-
Updating outsourcing agreements with ICT service providers.
-
Implementing structured incident management procedures.
-
Conducting regular testing of digital operational resilience.
DORA Compliance Checklist for Financial Entities and ICT Service Providers
The DORA compliance checklist includes:
-
A functioning ICT governance and risk management framework.
-
Registers of all third-party service provider contracts.
-
Documented incident response and reporting procedures.
-
Regular testing of digital operational resilience.
-
Participation in trusted cyber threat information-sharing arrangements.
-
Notification to supervisory authorities when joining or leaving such arrangements.
Alignment of DORA with EU Directives and Regulations
The EU Digital Operational Resilience Act complements other EU directives and regulations such as GDPR and MiCA. Together, these frameworks strengthen the operational resilience of financial entities within the EU, addressing cybersecurity, digital risk, and data protection in a unified way.
Incident Reporting and Testing of Digital Operational Resilience
Under the DORA regulation, entities must regularly test ICT systems that support critical functions and report major ICT-related incidents promptly. Requirements include:
-
Annual vulnerability assessments, performance tests, and penetration testing.
-
Advanced Threat-Led Penetration Testing (TLPT) for critical ICT services.
-
Full cooperation from ICT third-party service providers during resilience testing.
Regulation Summary: Long-Term Impact of DORA
The Digital Operational Resilience Act establishes a permanent framework for digital resilience across the EU financial sector. It ensures that financial entities can resist ICT disruptions, recover from incidents, and contribute to sector-wide cyber resilience through reporting and information sharing.
Our Services
A2CO offers tailored support to help you achieve DORA compliance:
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End-to-end advisory on DORA requirements.
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Gap analysis and ICT risk assessments.
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Support with ICT risk management and resilience planning.
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Third-party risk management solutions.
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Policy drafting, governance reviews, and internal controls.
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Incident management and reporting readiness.
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Coordination of penetration testing and resilience testing.
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Ongoing compliance monitoring and regulatory updates.
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Liaison with European supervisory authorities.
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Solutions for ICT service providers and critical third parties across the EU.
Why Choose A2CO
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Experienced in EU regulatory frameworks, including DORA.
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Deep understanding of the financial and ICT sectors.
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Tailored compliance strategies for financial entities and service providers.
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Clear, actionable guidance from assessment to implementation.
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Trusted by EU financial institutions and service providers.
Frequently Asked Questions
DORA is an EU regulation that sets compliance requirements for ICT risk management and digital resilience in financial entities and ICT service providers.
All EU financial entities and ICT service providers identified as critical must comply.
It covers ICT governance, third-party risk management, incident reporting, resilience testing, and participation in information-sharing arrangements.
It is the ability of financial institutions and ICT service providers to withstand and recover from ICT-related incidents.
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