Elevate Consulting

CyberSecurity Compliance

DORA

Your Guide to DORA Compliance:

Building Digital Resilience for the Financial Sector

As an integrated compliance partner, we guide financial institutions and third-party providers through the Digital Operational Resilience Act (DORA), helping ensure Information and Communication Technology (ICT) systems meet EU standards for operational resilience and cybersecurity.

Understanding DORA

The Digital Operational Resilience Act (DORA) is an EU regulation aimed at enhancing operational resilience within the financial sector. Effective January 17, 2025, DORA provides a unified framework for managing ICT risks across the EU, promoting secure, resilient financial systems.

Key Objectives:

Establish consistent ICT risk management practices across the EU.

Increase resilience against disruptions and cyber threats.

Streamline incident reporting to improve sector-wide response.

Mitigate risks posed by third-party ICT providers.

The Five Core Pillars of DORA Compliance

DORA is structured around five essential pillars to promote comprehensive ICT resilience within financial entities:
ICT Risk Management and Governance

Organizations are required to implement strong ICT risk management frameworks and governance structures, including:

Risk assessment and mitigation strategies

Business continuity planning for potential disruptions

Cybersecurity policies aligned with industry best practices

Incident Reporting

Entities must establish procedures to monitor, manage, and report ICT-related incidents, covering:

Immediate notification of significant incidents to relevant authorities

Regular progress updates and root cause analysis reports

Transparent communication with affected stakeholders

Digital Operational Resilience Testing

Regular testing of ICT systems is mandated, including:

Basic annual resilience tests to assess cyber readiness.

Advanced threat-led penetration testing every three years to identify system vulnerabilities.

Documentation of test results and remediation efforts.

Third-Party Risk Management

DORA requires firms to monitor and manage risks associated with third-party ICT providers, which includes:

Contract audits and performance benchmarks.

Defined exit strategies in case of risk exposure.

Regular compliance reviews for service providers.

Information Sharing and Learning

DORA encourages proactive incident learning and threat intelligence sharing to improve resilience across the financial sector while safeguarding sensitive data under GDPR.

Scope of Compliance

DORA establishes comprehensive guidelines to enhance ICT resilience in the EU's financial sector, impacting 21 categories of financial activities, including:
  • Credit institutions
  • Payment institutions
  • Account information service providers
  • Electronic money institutions
  • Investment firms
  • Crypto-asset service providers
  • Central securities depositories
  • Central counterparties
  • Trading venues
  • Trade repositories
  • Managers of alternative investment funds
  • Management companies
  • Data reporting service providers
  • Insurance and reinsurance undertakings
  • Insurance intermediaries
  • Institutions for occupational retirement provision
  • Credit rating agencies
  • Administrators of critical benchmarks
  • Crowdfunding service providers
  • Securitization repositories
  • ICT third-party service providers

The responsibility for DORA compliance resides with the financial entities themselves as they must implement and maintain the necessary measure to ensure digital resilience. Some exceptions do apply including the following:

Small financial entities (under 10 employees, with revenues/balance sheets under €2 million) have simplified requirements.

Proportionality: The application of DORA requirements should be proportionate to the size, nature, scale, and complexity of the financial entity’s services and operations.

ICT Third-Party Providers: While not directly regulated by DORA, critical ICT third-party service providers will be subject to an oversight framework established by the European Supervisory Authorities.

Micro-enterprises: In some cases, very small financial entities may be exempt from certain DORA requirements, though they are still expected to maintain a basic level of digital operational resilience.

Non-Compliance Penalties

Entities may face penalties up to 2% of annual global turnover, with individuals facing fines up to €1 million. Additional penalties, such as operational suspension, may be levied by EU member states or competent authorities.

Strategic Implications for IT Leaders

While DORA decentralizes ICT management to involve various executive roles, IT remains central to risk management. IT leaders must drive compliance by assessing current systems, updating governance, and potentially investing in advanced tools like segregated vaults for immutable backups. Creating a culture of resilience includes collaboration with regulatory bodies, aligning closely with DORA guidelines, and staying adaptable as future updates arise.

DORA Compliance Timeline

Time for required DORA compliance is approaching for financial entities and ICT providers. Below is a representation of key dates for the DORA transition.

Our DORA Compliance Approach

Our tailored compliance approach helps organizations achieve DORA readiness with a focus on the following processes:

We begin by working with organizational stakeholders to set the stage for DORA compliance. This includes:

  • Develop an ICT risk management framework and define governance structure.
  • Mapping all ICT systems and interconnections (e.g., inventory, diagrams).
  • Identifying and classifying critical assets.
  • Documenting ICT dependencies including third-party systems and services.

We work with your team to assess ICT risks, evaluate your current security posture, and identify gaps based on DORA’s risk management requirements. This foundational assessment enables you to understand how to build resilience in your organization’s digital operations. Outcomes include:

  • Risk assessment of ICT systems.
  • Documented cyber threats.
  • Identification of threat management protocols.
  • Definition of risk tolerance levels.

We assist in developing policies for ICT risk management, incident reporting, and business continuity planning. These policies support effective governance, covering all aspects of ICT resilience, and ensuring senior management engagement in compliance efforts.

With a focus on resilience DORA requires creation of or updates to BC/DR documentation. We support enhancements to these documents including:

  • Conducting business impact analyses (BIAs).
  • Creating or updating business continuity plans.
  • Creating or updating Disaster recovery plans and supporting the creation of strategies.
  • Conducting tabletop exercises to test scenarios of potential disruptions.

Our team oversees resilience testing, including:

  • Organizing and executing annual tests and every three-year threat-led penetration tests.
  • Documenting test results, vulnerabilities found, and remediation actions taken.
  • Updating test processes based on incident trends and regulatory guidance.

Our approach to third-party risk management ensures that your ICT service providers align with DORA requirements, including:

  • Performance monitoring and risk assessments for third-party providers.
  • Development of exit strategies and continuity plans for third-party dependencies.
  • Ongoing compliance checks to meet regulatory standards.

We help design enhanced incident response protocols. From initial notifications to root cause analyses, our team ensures your organization fulfills DORA’s reporting requirements and maintains clear communication with stakeholders.

Incident reporting under DORA requires several expanded capabilities, for example:

  • Reporting major ICT incidents to authorities (doing so within 48 hrs. of discovery).
  • Sending intermediate reports of incidents is still in progress.
  • Communicating incidents to DORA authorities and customers.
  • Voluntarily reporting significant threats, the organization has discovered.

DORA compliance requires rigorous documentation to demonstrate resilience and adherence to standards. Our team assists with:

  • Organizing and maintaining evidence of compliance, including policies, test reports, and incident documentation.
  • Preparing reports for regulatory reviews and audits.
  • Ensuring data retention in alignment with GDPR.

DORA is a resource intensive compliance effort that requires annual efforts. We provide the option to stay partnered with our client year after year to ensure smooth and continual compliance.

Why Choose Us for DORA Compliance?

Our consultants are well-versed in EU cybersecurity regulations, financial resilience, and third-party risk management, ensuring a thorough understanding of DORA’s requirements.

We adapt our services to your organization’s unique structure, ICT needs, and compliance levels, balancing regulatory demands with practical risk management.

Our structured approach to DORA compliance simplifies the readiness process, reducing time, complexity, and resources required for implementation.

We provide continuous support to help you navigate new challenges, regulatory changes, and cybersecurity threats, ensuring your organization remains resilient and compliant.

Ensure your organization meets the highest standards of ICT resilience with DORA compliance. Partner with us to navigate DORA’s requirements and secure your organization’s digital operations. Contact us today to start your journey toward enhanced digital resilience with DORA compliance.