Financial entities are required to establish and maintain mechanisms for the timely detection and reporting of significant ICT-related incidents to relevant authorities.

Financial entities must regularly test their digital resilience capabilities through various means, including threat-led penetration testing, to identify vulnerabilities and address them proactively.

Entities must manage and monitor the ICT risks stemming from their reliance on third-party service providers, including cloud computing services, ensuring that these relationships do not undermine their digital operational resilience.

The framework encourages financial entities to share information related to cyber threats and vulnerabilities to enhance collective defense mechanisms and resilience across the financial sector.

DORA introduces a framework for the oversight of critical ICT third-party service providers to the financial sector, aiming to mitigate systemic risk and ensure the stability of the financial system.

DORA establishes mechanisms for supervisory oversight, compliance and enforcement, including the potential for sanctions in cases of non-compliance with the regulation’s requirements.

Another significant challenge lies in enhancing third-party risk management. Many large financial institutions rely on numerous third-party providers, making it crucial to priorities and focus on the most critical ones. While current practices may already integrate some requirements, DORA regulation demands a more comprehensive approach. Financial services must ensure that their suppliers comply with the regulation’s operational resilience requirements. This includes working on potential exit strategies and conducting joint testing when relevant. Embracing this shift in approach may redefine how businesses interact with their suppliers, demanding a proactive operational resilience risk management strategy from all involved parties.

Testing is a crucial aspect of DORA compliance. Organizations need to structure and regularly test their resilience strategies to assess risks and the effectiveness of their resilience measures. Developing a strategic vision for testing is essential, as current tests are often managed in silos, focusing on specific areas such as vulnerability, penetration, or business continuity. To meet DORA requirements, organizations must ensure proper coverage of critical functions over the years within their testing approach. Moreover, DORA regulation mandates conducting threat-led penetration tests in live production at least once every three years, including with ICT third-party providers.

One of the core pillars of DORA is the establishment of robust risk management frameworks. Financial institutions must identify, assess, and mitigate operational risks effectively. This includes integrating cybersecurity measures, developing incident response plans, and regularly testing resilience strategies. While some organizations may already have existing risk management frameworks in place, aligning them with DORA’s requirements and ensuring consistency across the organization may pose a challenge. It is crucial to review and enhance existing frameworks to meet the specific demands of DORA.

DORA mandates timely and transparent reporting of significant incidents to the relevant authorities. This reporting approach is vital for maintaining transparency, facilitating coordinated responses, and allowing for swift intervention in potential crises. Financial institutions must establish robust reporting mechanisms and processes to ensure compliance with the regulation’s requirements. This involves the development of clear incident reporting procedures and the implementation of systems that enable accurate and timely reporting.

DORA emphasizes the importance of collaboration and information sharing within the financial sector. Financial institutions are encouraged to collaborate with industry peers, industry associations, forums, and other relevant stakeholders. By sharing insights, best practices, and lessons learned, organizations can collectively navigate the challenges of DORA compliance. This collaboration also helps advocate for responsible and effective implementation of DORA, fostering a unified and resilient European financial landscape.

To ensure a smooth and successful DORA compliance journey, organizations must develop a detailed compliance roadmap. This roadmap should outline the necessary steps, timelines, responsibilities, and milestones for achieving compliance. By clearly defining these aspects, organizations can track progress effectively and mitigate any potential compliance gaps. The compliance roadmap serves as a guiding document for the entire organization, ensuring a systematic and structured approach to DORA compliance.

DORA compliance is not a one-time effort but an ongoing commitment. Organizations must implement a robust monitoring system to track ongoing compliance and performance. Regular assessments should be conducted to evaluate the effectiveness of DORA compliance efforts and identify areas for improvement. By continuously monitoring and improving compliance measures, organizations can ensure continued alignment with evolving regulatory requirements.