Say Hi to DORA without the regulatory maze

The Digital Operational Resilience Act (EU Regulation 2022/2554) became mandatory on 17 January 2025. It establishes EU-wide requirements for digital operational resilience in financial services, covering ICT risk management, incident reporting, resilience testing, third-party risk management, and information sharing.

DORA applies to 21 types of financial entities operating in the EU, including:

• Credit institutions and banks
• Payment institutions and e-money providers
• Investment firms and trading venues
• Insurance and reinsurance companies
• Crypto-asset service providers
• Alternative fund managers and pension providers
• Credit rating agencies
• Market infrastructure providers

Additionally, ICT third-party service providers deemed critical face direct EU oversight.

1. ICT Risk Management: Comprehensive frameworks to identify, assess, and mitigate ICT risks with senior management oversight
2. Incident Management, Classification, and Reporting: Standardised processes for identifying, classifying, and reporting ICT incidents
3. Digital Operational Resilience Testing: Regular testing including threat-led penetration testing for critical systems
4. ICT Third-Party Risk Management: Due diligence and ongoing oversight of ICT service providers
5. Information Sharing Arrangements: Optional but encouraged collaboration on threat intelligence and best practices

Financial entities are regulated firms (banks, insurers, investment firms) that must comply with all five DORA pillars.

‍Critical ICT third-party providers are service providers designated as systemically important by European Supervisory Authorities (ESAs). They face direct EU oversight including inspections, information requests, and potential penalties. Designation is based on systemic impact, criticality of supported functions, and degree of substitutability.

Financial entities and critical ICT providers face significant penalties for non-compliance, along with reputational damage and potential operational restrictions. Supervisory authorities have enforcement powers including fines, remediation orders, and public disclosures.

Financial entities must report major ICT-related incidents to competent authorities following standardised templates and timelines:

• Initial notification: As soon as possible after detection
• Intermediate reports: During incident response
• Final report: Upon incident resolution

Reports must include incident classification, impact assessment, root cause analysis, and remediation steps. Missing deadlines tends to attract regulatory attention.

TLPT simulates real-world attack scenarios on critical ICT systems. DORA mandates it for certain financial entities based on size and criticality. It involves:

• Red team exercises mimicking actual threat actors
• Testing across multiple attack vectors
• Blue team response validation
• External oversight and documentation

It's penetration testing that assumes you're already a target. Because you probably are.

DORA requires financial entities to:

• Conduct due diligence before engaging ICT providers
• Include specific contractual clauses in service agreements
• Monitor provider resilience and performance continuously
• Maintain exit strategies and contingency plans
• Report providers handling critical functions to authorities

Large cloud providers may be designated as critical ICT third-party providers, subjecting them to direct EU oversight. Their compliance affects yours.

Yes. DORA requires testing of your organisation's resilience, not just individual vendor certifications. This includes:

• End-to-end scenario testing across integrated systems
• Failover and recovery procedures
• Business continuity validation
• Third-party dependency testing

Vendor SOC 2 reports don't replace your resilience testing obligations. Regulators expect you to prove it works in your environment.

DORA became applicable 17 January 2025. Key milestones:

• April 2025: Submit ICT third-party provider registers to supervisory authorities
• Ongoing: Implement incident reporting procedures, conduct resilience testing, maintain documentation
• Continuous: Monitor compliance across all five pillars

Starting late means catching up under watchful supervisory eyes. Not ideal.

We automate coordination across all five pillars: ICT risk assessment templates, incident reporting workflows, resilience testing schedulers, third-party oversight tracking, and regulatory documentation exports. You focus on financial operations; we handle compliance coordination and evidence management. When supervisors request documentation, it exports in assessment-ready formats. No midnight evidence archaeology required.

Yes. DORA implementation often overlaps with ISO 27001, SOC 2, and other frameworks. Hicomply's unified control mapping means evidence collected for DORA supports multiple compliance requirements. One evidence collection process, multiple regulatory outputs. That satisfying moment when one control satisfies three frameworks.