DORA compliance for third-party vendors: How to demonstrate compatibility

DORA compliance basics

(DORA) is an EU regulation aimed at enhancing the digital operational resilience of financial entities. The Act establishes uniform requirements to ensure that financial institutions can withstand, respond to, and recover from ICT-related disruptions and threats. DORA applies to a broad range of financial entities, including banks, insurance companies, investment firms, and critical third-party ICT service providers.

DORA entered into force on Jan. 16, 2023, and is effective as of Jan. 17, 2025. This timeline gave financial entities a two-year period to align their operations with the regulation’s requirements. Over these past two years, the European Supervisory Authorities (ESAs) have developed regulatory technical standards to ensure an effective implementation.

For businesses in the financial sector, DORA mandates the establishment of comprehensive ICT risk management frameworks, regular digital operational resilience testing, and stringent oversight of third-party ICT service providers. Financial entities are required to implement robust internal controls and governance structures to manage ICT risks effectively. They must also report major ICT-related incidents to competent authorities and may voluntarily share information on significant cyber threats.

The implications of DORA extend beyond the financial sector, as the Act also affects ICT third-party service providers that offer services to financial entities. These providers, including cloud platforms and data analytics services, are subject to oversight to ensure they meet the necessary resilience standards.

DORA ensures that the entire supply chain supporting financial services adheres to robust resilience protocols, thereby enhancing the stability and integrity of the financial system as a whole.

The pillars of DORA

Now that we’ve covered a high-level overview of DORA, let’s dig deeper through some of the key areas. Your partners across the EU financial sector will expect you to regularly share information about your organization’s compliance with these regulations. 

You should be prepared to nimbly communicate your compliance with the following regulations:

ICT risk management and governance

Financial entities are required to implement robust frameworks to identify, assess, and mitigate ICT risks under DORA. This includes establishing governance structures, defining risk management policies, and ensuring continuous monitoring of ICT systems to address potential vulnerabilities.

For example, a bank could develop an ICT risk management policy that outlines procedures for regular vulnerability assessments and assigns roles for incident response.

To prepare, organizations should conduct comprehensive assessments of their current ICT risk management practices, document policies aligned with DORA, and deploy monitoring tools to detect and mitigate threats proactively.

Incident response and reporting

Organizations must establish systems to monitor, manage, log, classify, and report ICT-related incidents. If an incident is serious, they may need to report it to regulators, clients, and partners. For critical incidents, they must submit three types of reports:

• an initial report to notify authorities,
• a progress report on resolving the issue,
• and a final report that explains the root causes.

For example, if an investment firm experiences a cyber-attack compromising client data, it must notify the appropriate regulatory body promptly.

To comply, organizations should develop detailed incident response plans, train staff on detection and reporting protocols, and establish clear communication channels with regulators to ensure timely reporting.

Digital operational resilience testing

Regular resilience testing of ICT systems is a cornerstone of DORA compliance. Basic tests like vulnerability assessments are expected at least once a year. More advanced testing, such as threat-led penetration testing (TLPT), to identify and address vulnerabilities are required every three years.

As an example, a payment institution might conduct annual penetration tests to ensure the security of its transaction processing systems.

Financial entities should schedule regular resilience testing, document identified weaknesses, address them promptly, and engage qualified professionals for advanced testing. Under DORA, FinServ vendors are also required to strengthen cybersecurity, follow strict incident reporting rules, and regularly test their resilience. Vendors face the same higher standards for risk management, detailed incident response plans, and increased due diligence.

Third-party risk management

DORA emphasizes the importance of managing risks associated with third-party ICT service providers. Financial entities must assess these risks before contracting, ensure agreements include specific provisions, and maintain oversight of third-party performance.

For example, an insurance company might evaluate the cybersecurity measures of a cloud service provider before signing an agreement.

Actionable steps include conducting due diligence assessments, updating contracts to include DORA-mandated clauses, and regularly monitoring provider adherence to agreed-upon standards.

As we noted above, FinServ vendors are also required to comply with DORA regulations, which inevitably means vendors will be required to handle more security questionnaires.

Responsive’s automated security questionnaire software can help vendors prepare and ensure compliance and risk mitigation by using industry-leading AI to respond quickly with confidence, scalability, efficiency, and accountability in every response.

Information sharing

Under DORA, financial entities are encouraged to share information on cyber threats and vulnerabilities to foster collective resilience across the sector.

For instance, a financial consortium might create a secure platform for member institutions to exchange anonymized threat intelligence, ultimately leading to a more safe and secure platform.

To comply, entities should join industry information-sharing networks, develop internal policies for sharing cyber threat data responsibly, and collaborate with other financial organizations to strengthen sector-wide defenses. Responsive’s Profile Center makes it easy to create and proactively share secure profiles loaded with pre-filled questionnaires and documents to address common requests for security, privacy, and compliance information.

Mandatory contract provisions

DORA requires that contracts with ICT third-party service providers include specific provisions addressing risk management, security measures, and regulatory compliance. For critical or important functions, even greater service level descriptions and full access rights must be provided.

For example, a management company might revise its contract with an IT services provider to incorporate clauses on data protection and incident reporting.

To meet these requirements, organizations should review all existing contracts for compliance gaps, update them with DORA-mandated clauses, and ensure future contracts are aligned with the regulation from the outset. This also applies to third-party FinServ vendors.

Responsive can help third-party vendors handle the inevitable increase in security questionnaires with secure, accurate, and automated security questionnaire software to complete up to 80% of a security questionnaire with a few keystrokes, rather than manually addressing the same lengthy questions over and over.

How DORA affects financial businesses

DORA makes compliance mandatory for financial institutions across the EU, reshaping how businesses address operational and digital risks. If you’re a vendor contracting with these institutions, maintaining compliance with DORA is crucial to sustaining your partnerships.

Financial organizations must ensure that their third-party providers meet these regulatory requirements, making DORA not just a framework for internal resilience but also a standard for evaluating external collaborators.

For financial institutions in the EU, DORA gives the European Commission the power to create clear rules on how to follow its requirements. This helps financial companies and their service providers understand their responsibilities and avoid confusion about what they need to do to comply. DORA also improves how authorities manage digital risks, creating a consistent system for ensuring businesses are prepared for IT-related issues. Breaking these rules can lead to serious consequences, such as fines or even criminal charges, depending on the country.

For companies working across several EU countries, the different penalties in each nation make it important to have a strong compliance plan that works everywhere. Following DORA isn’t just about avoiding fines—it’s also about protecting your reputation and earning the trust of customers and regulators.

DORA allows for fines on ICT providers of up to 1% of the provider’s average daily worldwide turnover in the previous business year. Providers can be fined daily for up to six months until they achieve compliance.

Responsive’s Profile Center can help avoid these substantial fines by securely and proactively sharing pre-filled questionnaires and documents that address common requests for security, privacy, and compliance information. These pre-filled questionnaires also eliminate hours of repetitive work each week.

How DORA affects third-party vendors

DORA has brought third-party vendors squarely into the compliance spotlight, with oversight now enforced by European Supervisory Authorities (ESAs).

These include:

• European Banking Authority (EBA)
• European Securities and Markets Authority (ESMA)
• European Insurance and Occupational Pension Authority (EIOPA)

Each authority monitors vendors to ensure they meet the strict requirements of DORA, making it essential for businesses to align with its standards to continue working with EU-based financial institutions.

Vendors that fail to do so will face significant bottom-line consequences. If your business cannot meet DORA’s demands, your existing contracts with EU financial institutions could be at risk.

This means vendors must proactively assess and enhance their digital operational resilience. Whether it’s managing ICT risks, securing data, or demonstrating compliance, the stakes are high—not just for keeping your contracts but also for maintaining your reputation as a reliable partner, which will ultimately impact your revenue, too.

DORA requirements for third-party vendors

Under DORA, financial institutions are required to continuously monitor their third-party vendors to ensure compliance with the regulation. This means vendors must maintain transparency and readiness for ongoing scrutiny.

Financial institutions must also evaluate their ICT providers’ risk strategies regularly and ensure they have clear, written, accessible, and auditable policies that cover all third-party services and functions. This level of oversight is designed to mitigate risks and ensure that vendors are reliable partners in maintaining operational resilience.

One unique requirement of DORA is substitutability. Financial institutions must be able to replace any third-party vendor without jeopardizing their operations. If a vendor is deemed not substitutable, the institution must justify this exception and ensure alternative measures exist.

It’s important for vendors to demonstrate flexibility, transparency, and compliance, as their relationships with financial institutions hinge on meeting these standards. To comply with DORA, third-party vendors must focus on three key areas:

1. information security controls
2. robust risk strategies
3. adequate resilience

Vendors must have strong safeguards to protect sensitive data, strategies to manage and mitigate ICT risks, and the capacity to withstand and recover from disruptions. These requirements are not just regulatory checkboxes—they represent a commitment to supporting the operational stability and trustworthiness of the financial institutions they serve.

How does DORA impact RFPs and proposals?

DORA is set to reshape the way we think about compliance in RFPs and proposals. While the substance of compliance is changing, the methods for finding and contracting vendors will largely remain the same.

What’s different? The heightened focus on operational resilience and security across the board.

Security questionnaires, for example, are still a cornerstone of the sales process for third-party vendors. However, DORA ups the ante by requiring vendors to demonstrate a more comprehensive understanding of cybersecurity risks and operational safeguards. This means your questionnaires—and the responses you craft—will need to go beyond checkbox compliance to showcase your organization’s ability to maintain resilience against disruptions.

Third-party vendors must also ensure their proposals and responses address every angle of DORA’s mandates. This isn’t just about saying you’re compliant. You need to prove it with detailed explanations and documentation. If your proposal doesn’t explicitly speak to DORA concerns, it could be left out of the running.

For example, DORA places greater emphasis on file-sharing security and Digital Rights Management (DRM). Standards for encryption, access controls, and data tracking are no longer optional talking points—they’re mandatory proof points in your proposals. This shift means organizations must be prepared to demonstrate how their systems align with these new standards and how they can help clients maintain compliance in their operations.

In short, DORA isn’t rewriting how vendors are selected, but it’s certainly raising the bar for the content you deliver in RFPs and proposals. By addressing DORA’s concerns upfront and integrating its requirements into your proposal workflows, you can stay ahead of the curve and position your organization as a trusted, resilient partner in a complex regulatory landscape.

Responsive’s Profile Center includes a free 120 Q&A pair template companies can use to quickly, thoroughly, and proactively demonstrate DORA compliance.

Tips for creating competitive proposals under DORA

Crafting competitive proposals under DORA is about more than just ticking off compliance checkboxes—it’s about showcasing your business as a proactive, trusted partner. To do that effectively, you’ll need to adapt your proposal strategies to address DORA requirements head-on.

Here are some actionable tips to help you stand out.

Assign a DORA expert to review requirements

Start by designating an expert (or team of experts) to review DORA’s requirements and map out how they relate to your business operations. This is no small task—it involves a detailed examination of both the legislation and your existing policies. But it’s essential. Understanding how DORA applies to your industry is the foundation of a strong, competitive proposal.

Be ready for the time-intensive documentation process

Creating thorough and compliant documentation takes time, but it’s worth every second. DORA requires detailed proof of your operational resilience measures, so don’t rush the process. By developing robust documentation now, you’ll have the resources ready to include in future proposals, saving time in the long run and ensuring your submissions meet the highest standards.

Organizations can make use of tools like Responsive’s Content Library to save and reuse past successful answers from previous responses in future responses, ensuring each response is timely and accurate. A content library also provides instant and secure access to all shared content that is current, complete, and compliant.

For global organizations, this means multiple departments can manage their data in a single, curated content repository, ensuring information is shared seamlessly and each department is always using the correct data for their responses.

Highlight recent compliance data

One of the easiest ways to make your proposals more persuasive is by including up-to-date compliance data. Clients need to know you’re not just meeting current protocols but actively monitoring and improving your systems. Include details about your latest audits, certifications, and security updates to demonstrate your dedication to staying ahead of regulatory requirements.

Be specific about methodologies and policies

EU clients operating under DORA need to know exactly how you manage risk, maintain operational continuity, and ensure data security. The more specific you can be in describing your methodologies, policies, and systems, the more authoritative your proposals will feel.

Don’t just say you’re compliant—show how you’re compliant, with clear examples and metrics.

Customize proposals to address client concerns

Remember, not all companies interact with DORA in the same way. Each client has unique technical concerns and operational needs based on their role within the EU’s financial ecosystem. Tailor your proposals to address these specifics. Doing your homework on a client’s priorities will demonstrate your commitment to meeting their needs and set your submission apart from generic responses.

Responsive makes this process of pulling in validated company information even easier with Profile Center, a secure trust center with custom profiles loaded with pre-filled questionnaires and documents that address common requests for security, privacy, and compliance information. Profile Center even includes a free 120 Q&A pair template you can use to demonstrate DORA compliance.

Keep your DORA compliance information in a central knowledge base

Let’s face it—DORA compliance isn’t just another box to check. The requirements are intricate, and the stakes are high. Proposal professionals must manage a wealth of information, from cybersecurity protocols to operational resilience strategies. Creating documentation from scratch for every RFP or security questionnaire isn’t just time-intensive; it also increases the risk of errors and inconsistencies.

The solution? A central knowledge base for your DORA compliance information.

Centralize for a single source of truth

DORA’s complexity requires thorough analysis and precise documentation. Importing your compliance data into a central knowledge base ensures you always have a single, reliable source of truth.

Instead of scrambling to pull together details from scattered files, you’ll have everything you need in one place, ready to reference or share. This not only streamlines the process but also boosts confidence in your team’s ability to deliver accurate, well-documented responses.

Save time and increase efficiency

Manually writing DORA-related responses for each proposal is inefficient and leaves room for error. A central repository, like the Responsive Content Library, allows you to reuse and customize content easily, tailoring it to specific RFPs without starting from scratch. Used in tandem with Responsive’s AI Draft to create first drafts in minutes, your team will be saving hours of time each week previously spent doing repetitive tasks.

Need to update a policy or adapt to a new standard? A central knowledge base makes these updates seamless, so you can focus on crafting persuasive, client-focused proposals. This also ensures that, once a new update is made in the library, everyone across your organization will use that latest version.

Streamline cross-team collaboration

DORA compliance data often addresses core issues of data security and operational resilience, topics that touch multiple teams across your organization—IT, legal, operations, and more.

A Strategic Response Management (SRM) platform ensures everyone has access to the same, up-to-date information, fostering better collaboration and reducing the risk of miscommunication. It’s a tool that benefits the entire organization, not just your proposal team.

Be prepared for the long haul

DORA compliance isn’t static—it’s sure to constantly evolve with regulatory standards and industry practices. A knowledge base grows with your organization, allowing you to adapt quickly to changes and stay ahead of the curve. By investing in a single platform to power every response, you’ll ensure your team is equipped to handle not just today’s proposals, but tomorrow’s challenges as well.

By keeping your DORA compliance information in one place, you simplify a complex process, reduce errors, and increase efficiency. More importantly, you position your team to create proposals that stand out for their clarity, consistency, and professionalism—qualities that build trust.

Stay on top of DORA compliance mandates

With such sweeping changes affecting financial entities in the EU, DORA is set to dramatically alter digital operational resilience with uniform requirements to ensure that financial institutions can withstand, respond to, and recover from ICT-related disruptions and threats.

DORA has entities around the world asking how they can ensure compliance with the new requirements. Responsive customers are already set thanks to a free DORA compliance questionnaire in Profile Center to help customers demonstrate their compliance with DORA.

This DORA questionnaire includes 120 Q&A pairs companies can use to quickly and thoroughly demonstrate DORA compliance across six sections, including:

• IT Risk Management
• Incident Reporting and Management
• Digital Operational Resilience Testing
• Third-Party Management
• Information & Intelligence Sharing and Reporting
• Section for additional questions as needed.