DORA Compliance Explained

DORA — the Digital Operational Resilience Act — applies to a broad range of financial entities and, crucially, their critical ICT service providers. It harmonizes operational resilience requirements that were previously scattered across different rules. If you operate in or supply the financial sector, here's the shape of it.

Five pillars

• ICT risk management — a comprehensive framework owned by the management body.
• ICT incident management — classification, handling, and reporting of major incidents.
• Digital operational resilience testing — including threat-led penetration testing for significant entities.
• ICT third-party risk — oversight of providers, with key contractual requirements.
• Information sharing — voluntary exchange of threat intelligence among entities.

Third-party risk is the headline

DORA puts real weight on ICT third-party risk. Financial entities must maintain a register of information on their ICT arrangements, ensure contracts contain specific provisions, and assess concentration risk. Critical providers face direct EU oversight.

How it relates to what you already have

If you've implemented ISO 27001 or aligned with NIS2, you have a strong foundation — but DORA is more prescriptive in places, particularly around testing and third-party contracts. Treat it as an extension, not a parallel universe.

DORA's emphasis on resilience testing and supplier contracts catches many organizations that thought their existing program was enough.

Practical first steps

• Confirm whether you are a financial entity or an ICT provider to one.
• Build or update your register of ICT third-party arrangements.
• Review supplier contracts against DORA's required provisions.
• Establish an incident classification and reporting process aligned with the technical standards.
• Plan your resilience testing program proportionate to your size and risk.

DORA is demanding but logical. Start by understanding your role in the chain, get your third-party house in order, and build resilience testing into your routine rather than treating it as a one-off.