Digital Operational Resilience Act Now in Force

This new regulatory framework aims to strengthen the digital resilience of financial institutions and their critical technology providers, setting rigorous requirements for managing ICT risks, testing operational resilience, and responding to disruptions that could affect financial stability. For businesses that have invested significant time and resources in preparation, today is an opportunity to showcase their compliance readiness, strengthen relationships with regulators, and build trust with stakeholders. For those still lagging behind, the urgency to act cannot be overstated—compliance is no longer optional. 

What DORA Means for Financial Services and their Third-Party ICT Providers 

DORA establishes a robust and comprehensive framework designed to ensure financial entities and their critical technology providers can withstand, respond to, and recover from ICT-related disruptions. It applies to a diverse range of organisations, including banks, insurance firms, investment companies, payment service providers, and third-party ICT vendors that deliver essential technology services. 

The regulation is structured around four core requirements that all impacted entities must meet: 

• ICT Risk Management: Businesses must implement robust frameworks to identify, assess, and mitigate ICT risks effectively. This includes creating detailed processes for monitoring vulnerabilities, managing updates, and ensuring systems are secure and up-to-date. 

• Operational Resilience Testing: Regular testing of operational resilience measures is mandatory under DORA. This includes penetration tests, red teaming exercises, and disaster recovery simulations designed to ensure that systems and processes can withstand real-world challenges. 

• Incident Reporting: Timely reporting of major ICT-related incidents to regulatory authorities is a key aspect of DORA. Organisations must have clear protocols for identifying, escalating, and disclosing incidents that impact their operations, customers, or critical infrastructure. 

• Third-Party Risk Management: Greater scrutiny of third-party ICT providers ensures that these external partners adhere to the same high standards of resilience. This involves conducting regular risk assessments, negotiating robust contractual terms, and establishing ongoing monitoring processes. 

 

What’s Next for Compliant Organisations? 

For organisations that are already compliant with DORA, this milestone is just the beginning of an ongoing journey to maintain resilience. Compliance is not a one-time achievement—it’s an ongoing process that requires vigilance, adaptation, and continuous improvement. 

Here’s how compliant businesses should proceed: 
 

• Monitor Continuously 

Implement real-time monitoring systems to detect and respond to ICT risks as they arise. Early detection is critical for minimising the impact of potential disruptions. 
 

• Document and Report 

Ensure you have well-documented protocols for incident reporting and are prepared to provide detailed evidence of compliance during regulatory reviews. Transparency and accountability will be essential in maintaining trust with regulators. 
 

• Review and Update Testing Schedules 

Operational resilience testing is an iterative process. Regularly schedule tests to adapt to emerging threats and refine your response capabilities. This includes updating scenarios to reflect changes in your business operations or technology landscape. 
 

• Engage with Third-Party Providers 

Keep open communication channels with your ICT providers to ensure they remain compliant. Regular reviews and audits of your third-party relationships will be necessary to address risks proactively. 

For Organisations Still Catching Up 

If your organisation is not yet fully compliant with DORA, the time for immediate action is now. Non-compliance could result in regulatory penalties, reputational damage, and operational vulnerabilities that place your business at risk. 

Here’s where to start: 

• Conduct a Gap Analysis 

Evaluate your current processes and identify critical gaps in your ICT risk management, resilience testing, incident reporting, and third-party oversight. 

• Strengthen Incident Response Plans 

Ensure you have a well-defined framework for identifying, managing, and reporting ICT incidents promptly. 

• Enhance Third-Party Risk Management 

Engage with your external ICT providers to align on compliance requirements. This may involve renegotiating contracts, implementing continuous monitoring, and conducting regular risk assessments. 

• Seek Expert Guidance 

If you’re facing challenges in meeting DORA’s requirements, don’t hesitate to seek external support. Expert advisors can help you streamline your compliance efforts and focus on high-priority areas. 
 

DORA’s Long-Term Impact 

While the implementation of DORA marks a significant milestone, it also signals a broader shift towards greater resilience and accountability across the financial sector. By embracing DORA’s principles, organisations can build stronger foundations for managing ICT risks, enhancing operational stability, and protecting against an increasingly complex threat landscape. 

This regulation is not just about meeting today’s requirements—it’s about future-proofing your business. Those who invest in continuous compliance and resilience stand to gain competitive advantages, including improved stakeholder confidence, stronger customer trust, and reduced risk exposure. 

As the regulatory environment continues to evolve, businesses must remain proactive. Compliance with DORA should be viewed as part of an ongoing commitment to digital resilience, rather than a one-time effort. 
 

Need Assistance with Ongoing Compliance? 

If you’re still working towards full compliance or looking to refine your resilience strategies further, our team is here to help. From conducting gap analyses to building robust testing frameworks, we provide tailored solutions to meet your unique needs under DORA. 

Contact us to learn how we can support your journey towards sustained compliance and operational excellence.