EU DORA Compliance (Digital Operational Resilience Act)

Implement DORA Regulation (2022/2554) digital operational resilience for financial entities — ICT risk management, incident reporting, resilience testing, third-party risk.

EU DORA Compliance (Digital Operational Resilience Act)

DISCLAIMER: This skill provides guidance only. It does not constitute legal or financial advice. Always verify with qualified professionals.

When to Use

  • Building software for financial institutions in the EU
  • Assessing ICT risk management for fintech
  • Setting up ICT incident reporting for financial entities
  • Designing resilience testing programs
  • Managing third-party ICT service provider relationships

Scope — Who Is Affected?

DORA applies to virtually all EU financial entities:

CategoryEntities
BankingCredit institutions, payment institutions, e-money institutions
InvestmentInvestment firms, trading venues, central securities depositories
InsuranceInsurance/reinsurance undertakings, intermediaries
PensionIORPs (Institutions for Occupational Retirement Provision)
CryptoCrypto-asset service providers (MiCA-regulated)
InfrastructureCCPs, trade repositories, securitization repositories
OtherCredit rating agencies, crowdfunding providers, data reporting services
ICT providersThird-party ICT service providers to the above (critical designation)

5 Pillars of DORA

Pillar 1: ICT Risk Management (Articles 5-16)

Establish an ICT risk management framework:

  • Identify all ICT assets, risks, dependencies
  • Protect through security policies, access controls, encryption
  • Detect anomalies and incidents via continuous monitoring
  • Respond with incident response and crisis communication plans
  • Recover with backup policies, restoration procedures, lessons learned

Pillar 2: ICT Incident Reporting (Articles 17-23)

Classify and report major ICT-related incidents:

CriterionThreshold for Major
Clients affected> 10% of clients or significant clients
Duration> 2 hours for critical services
Geographic spread> 2 member states
Data lossIntegrity, confidentiality, or availability compromised
Economic impactMaterial financial loss
Criticality of servicesCore banking, payment processing, trading

Reporting timeline:

  • Initial notification: within 4 hours of classification as major
  • Intermediate report: within 72 hours
  • Final report: within 1 month

Pillar 3: Digital Operational Resilience Testing (Articles 24-27)

Test TypeFrequencyWho
Vulnerability assessmentsAt least annuallyAll entities
Network security testingAt least annuallyAll entities
Scenario-based testingAt least annuallyAll entities
Threat-Led Penetration Testing (TLPT)At least every 3 yearsSignificant entities only

TLPT must be conducted by qualified external testers following the TIBER-EU framework.

Pillar 4: Third-Party ICT Risk (Articles 28-44)

For all ICT third-party service providers:

  • Maintain a register of all ICT service agreements
  • Conduct pre-contract due diligence
  • Include mandatory contractual clauses (audit rights, exit strategies, data location)
  • Monitor ongoing compliance
  • Have exit plans for critical providers

Critical ICT third-party providers (designated by ESAs) face direct EU oversight.

Pillar 5: Information Sharing (Article 45)

Financial entities may participate in voluntary information-sharing arrangements on:

  • Cyber threat intelligence
  • Indicators of compromise
  • Tactics, techniques, and procedures (TTPs)
  • Security alerts and configuration tools

Key Date

  • 17 January 2025: DORA fully applicable

What This Skill Does NOT Do

  • Does not conduct penetration testing or TLPT
  • Does not configure ICT security tools
  • Does not manage third-party provider contracts
  • Does not replace compliance officer or legal counsel

Last updated: October 13, 2026

Files (2)

Jurisdiction
🇪🇺 European Union
Practice area
Finance
License
MIT
Author
BuilderCed
Source
eu/finance/skills/eu-dora-compliance-builderced

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