DORA Compliance: Is Your Operational Resilience Test Programme Ready?

As the clock ticks closer to the deadline, organisations should ensure their resilience plans and frameworks are not only in place but also rigorously tested to withstand real-world disruptions. Under DORA, operational resilience testing requirements are detailed in Chapter IV. The European Supervisory Authorities' (ESA) technical standards provide further guidance. 

DORA places great importance on regular testing to assess an organisation’s preparedness to manage and recover from ICT incidents. These tests are not only a compliance requirement but also a critical step in strengthening your organisation’s ability to respond to threats and maintain continuity in an increasingly volatile digital landscape.
 

 

Why Operational Resilience Testing Matters

Operational resilience testing is about preparing your organisation for the unexpected. Whether it’s a cyberattack, a system failure, or a supplier disruption, your ability to recover quickly and minimise impact is essential for compliance, customer trust, and long-term stability. DORA requires firms to demonstrate that their systems, processes, and teams are capable of maintaining critical operations during adverse conditions. Without rigorous testing, potential vulnerabilities could remain hidden, leaving your organisation exposed to risks that could have been addressed proactively.

 

Types of Operational Resilience Testing

There are several types of tests that organisations should carry out to meet DORA’s requirements:
 

1. Penetration Testing

Simulating attacks on your ICT systems helps identify vulnerabilities before malicious actors can exploit them. Regular penetration tests are vital for uncovering weaknesses and strengthening your defences.

2. Disaster Recovery Simulations

Simulating large-scale disruptions, such as unexpected outages or cyberattacks, can help assess the effectiveness of your disaster recovery and business continuity plans. These simulations should test your ability to restore critical functions within acceptable timeframes.

3. Tabletop Exercises

These involve gathering key stakeholders to discuss and walk through a hypothetical incident scenario. Tabletop exercises are an effective way to align response plans with the principles outlined in DORA's ICT risk management framework, ensuring all stakeholders are aware of their roles during incidents.

4. Threat-Led Penetration Testing (TLPT)

TLPT frameworks outlined by ESAs are particularly applicable to critical entities. This advanced testing method involves cybersecurity experts emulating real-world attackers to evaluate how effectively your systems and personnel respond to unauthorized access attempts. TLPT is crucial for identifying both technical and human vulnerabilities, and aligns with DORA's focus on proactive risk management by ensuring that your ICT risk management framework is robust and responsive to potential threats.

 

Key Steps to Prepare for Testing

With the DORA deadline so close, it’s essential to approach resilience testing strategically. Here’s how you can get started:

1. Define Objectives

Determine the specific goals of each test. Are you focusing on uncovering system vulnerabilities, evaluating your incident response plan, or testing your communication protocols? Clear objectives will ensure your testing efforts are focused and effective.

2. Engage Key Stakeholders

Involve all relevant teams, including IT, compliance, risk management, and executive leadership. Cross-functional collaboration is crucial for testing scenarios that impact multiple areas of your organisation.

3. Simulate Realistic Scenarios

Design tests that reflect real-world threats your organisation is likely to face. Tailoring scenarios to your specific operational environment will provide more actionable insights.

4. Document Findings

Thoroughly document findings, including the methodologies used, vulnerabilities identified, and remedial actions. Ensure compliance with DORA’s requirement for ongoing improvement and reporting to management body.

5. Refine and Repeat

Testing isn’t a one-time exercise. Use the insights gained to refine your resilience plans and schedule regular tests to ensure ongoing readiness.

 

The Final Push: Why Action Now is Critical

As the DORA deadline approaches, operational resilience testing is a crtical step in ensuring your organisation is fully prepared. Testing your frameworks under realistic conditions will not only help you meet compliance requirements but also give you the confidence that your systems, teams, and processes are ready to handle challenges. Time is running out, but it’s not too late to act. By prioritising resilience testing now, you can identify and resolve weaknesses before they become critical issues. For guidance on conducting operational resilience testing or for support with your overall DORA compliance strategy, contact us today.

Is your organisation ready for DORA? Let us help you test and refine your resilience programme to meet the challenges of tomorrow.

Contact us