Regulation (EU) 2022/2554 sets uniform requirements for digital operational resilience for practically the entire European financial sector. The goal is to strengthen resilience against ICT disruptions and cyber incidents – with harmonized rules instead of a patchwork of national requirements.
DORA applies to financial entities and ICT third-party providers. The regulation harmonizes previously fragmented requirements for reporting, testing and third-party risk in a coherent framework – lex specialis to NIS2 for the financial sector.
DORA structures digital operational resilience into five pillars – from ICT risk management to incident reporting to third-party risk management.
Comprehensive framework across entire lifecycle
Harmonized reporting of major ICT incidents
Broad testing spectrum up to TLPT
Strategy, register, due diligence, contracts
Supervisory framework for systemically relevant ICT third-party providers
Chapter II (Art. 5-16) defines comprehensive requirements for governance, protection, detection, response and recovery. The board bears ultimate responsibility – ICT resilience becomes a board-level issue.
Board bears ultimate responsibility
Complete stocktaking
Policies for network/infrastructure management
Multi-layered detection mechanisms
ICT-BCP and response/recovery plans
Post-incident reviews, lessons learned
DORA harmonizes reporting obligations for major ICT incidents across the entire financial sector. Direct reporting to competent authority, coordinated with CSIRTs and data protection authorities. Unified taxonomy and thresholds.
Definition via ESA standards
Direct reporting to competent authority
Unified classification
Voluntary threat reporting
Chapter IV requires a broad testing spectrum – from vulnerability scans to demanding Threat-Led Penetration Tests (TLPT) following TIBER-EU principles. Mandatory for large and systemically relevant institutions.
Regular vulnerability scans
Simulated attacks on systems
Highest test level following TIBER-EU/G7 principles
Test program with multi-year plan
Chapter V, Section I defines comprehensive requirements for managing ICT third-party risks. Financial institutions remain fully responsible – even when outsourcing critical functions.
Mandatory complete register of all ICT contracts
Systematic review before contract signing
DORA defines mandatory clauses
Transparency about sub-contractors
Assessment of provider concentrations
Special diligence for non-EU providers
Chapter V, Section II establishes an EU supervisory framework for critical ICT third-party providers. Lead Overseer (EBA/EIOPA/ESMA) with comprehensive powers – from inspections to sanctions.
Systematic relevance assessment
Comprehensive supervisory powers
Mandatory EU subsidiary
Regular reports to Lead Overseer
Our Software Delivery Platform and Managed Services systematically support financial institutions with DORA compliance – from ICT risk management to testing to third-party risk management.
ISO 27001-certified processes
Zero-trust architecture, strong authentication
Comprehensive observability stack
Tested backup/restore processes
Structured incident processes
Test infrastructure for vuln scans to TLPT
Standard clause library
EU-only operating models available
Turnkey compliance roadmaps
DORA is part of the comprehensive EU digital/cybersecurity ecosystem. It integrates with NIS2, CRA, Cloud Sovereignty Framework, Data Act and other EU regulations.
DORA is lex specialis for financial sector
NIS2 applies in principle to critical/important entities; DORA specifies and expands for financial institutions. No double compliance: DORA-compliant financial entities typically also fulfill NIS2.
Complementary at product/operations level
CRA addresses cybersecurity of products with digital elements (software, hardware). DORA requires operational resilience when using these products in the financial sector. Together: secure products + resilient operations.
Digital sovereignty as risk mitigator
The EU Cloud Sovereignty Framework evaluates independence, control and exit capability – factors that directly address DORA third-party risks. EU-based, sovereign ICT stacks reduce jurisdictional and concentration risks.
Data portability and lock-in avoidance
The Data Act requires technical/contractual measures against vendor lock-in – directly relevant for DORA exit strategies with ICT third-party providers. Interoperability and standardized interfaces become the regulatory standard.
Complementary requirements
GDPR focuses on data protection and privacy. DORA addresses ICT resilience and availability. Overlaps: incident reporting (DORA to financial supervisors, GDPR to DPA), security measures (Art. 32 GDPR). Coordinated compliance required. DORA compliance presupposes GDPR-compliant data processing.
Integration with banking supervision/insurance law
Comprehensive compliance approach
How ayedo systematically addresses DORA, NIS2, CRA, GDPR, ISO 27001 and other standards. Certifications, processes, technical measures and audit readiness – find our complete compliance roadmap here.
DORA fundamentally changes how financial institutions manage ICT risks, govern third-party providers and test resilience. From board responsibility to exit strategy – here are the core implications.
ICT resilience becomes a board-level issue
Comprehensive documentation mandatory
24/7 monitoring/detection mandatory
Consistent DORA clauses required
From vuln scans to TLPT
Critical ICT providers under direct supervision