DORA for Financial Services: An Overview of Operational Implications

DORA: More Than Another Compliance Obligation

The Digital Operational Resilience Act (DORA) has been mandatorily applicable since January 2025 for banks, insurers, investment firms, payment service providers, and a wide range of other financial market participants in the EU. While many regulatory requirements are primarily documentary in nature, DORA goes significantly further: the regulation demands real, demonstrable operational resilience – the ability not just to prevent attacks and outages, but to withstand them.

The Five Pillars of DORA

1. ICT Risk Management: Companies must establish a comprehensive framework for managing ICT (Information and Communication Technology) risks that captures all assets, dependencies, and potential impacts of failures or attacks.

2. Incident Reporting: DORA prescribes strict reporting obligations for ICT-related incidents. Serious incidents must be reported to the competent authority within 4 hours (initial report), 72 hours, and 30 days. This requires functioning detection and classification processes.

3. Resilience Testing: DORA obligates significant financial entities to regular Threat-Led Penetration Tests (TLPT) – penetration tests based on real threat scenarios, not generic test plans.

4. Third-Party Risk Management: Financial entities must systematically manage their dependencies on ICT third-party providers, especially critical providers. A particularly strict supervisory framework applies to critical third-party providers.

5. Information Sharing: DORA actively promotes the exchange of threat intelligence between financial entities – an aspect underrepresented in many DORA analyses but offering considerable practical benefits.

What Distinguishes DORA from NIS2

Both regulations address cyber resilience, but DORA is sector-specific and stricter in many aspects. Importantly, DORA and NIS2 are not mutually exclusive – financial companies subject to DORA must also comply with NIS2 if they qualify as essential or important entities. In practice: DORA compliance regularly fulfills NIS2 requirements in relevant areas, but not automatically all of them.

External Threat Monitoring Under DORA

One aspect particularly relevant under DORA: the continuous monitoring of the external threat environment. DORA requires financial entities to have current knowledge of the threat landscape affecting their critical systems – including real-time monitoring of third-party risks.

Note: This article provides a general overview. A DORA compliance assessment tailored to your company requires individual legal and technical consulting.