DORA compliance: A checklist

DORA represents the European Union's most comprehensive approach to digital operational resilience in financial services. As a directly applicable regulation that took effect on January 17, 2025, DORA creates uniform ICT risk management requirements across all EU member states, replacing a patchwork of national approaches. The regulation establishes five core pillars: ICT risk management frameworks, incident classification and reporting, digital operational resilience testing, third-party risk management, and information sharing arrangements.

Successfully navigating DORA compliance requires understanding both the regulation's broad scope and its detailed technical requirements. Financial entities must now operate under harmonized standards for everything from vulnerability management to vendor oversight, while managing new reporting obligations that can trigger within hours of an incident. The regulation's technology-agnostic approach means you'll need to translate capability requirements into your specific technology stack, whether that involves cloud services, legacy systems, or hybrid environments.

The key to success lies in treating DORA as an operational transformation rather than a compliance checkbox exercise. Organizations that integrate DORA requirements into existing risk management processes, leverage automation for reporting and monitoring, and build sustainable vendor management practices will find themselves better positioned for long-term resilience rather than just regulatory adherence.

Planning your compliance strategy

Your organization's size and risk profile directly determine the depth and complexity of your DORA implementation. The regulation explicitly requires proportionality, meaning smaller entities face streamlined requirements compared to systemically important institutions. However, this proportionality principle doesn't eliminate core obligations—it scales the sophistication of your controls, documentation, and testing programs. Start by mapping your entity type against DORA's scope to understand whether you're subject to advanced requirements like Threat-Led Penetration Testing (TLPT) or whether you can implement simplified incident classification procedures.

The interconnected nature of DORA's five pillars means you cannot address them in isolation. Your ICT risk management framework must support incident detection and classification, which feeds into your reporting obligations, while your third-party risk management directly impacts your testing scope and information sharing capabilities. Plan your implementation with these dependencies in mind, ensuring that governance structures, data flows, and control activities work together rather than creating conflicting requirements or duplicated efforts.

Understanding your competent authority's specific expectations and reporting channels proves critical for practical implementation. While DORA creates harmonized requirements, national supervisors retain discretion in examination approaches, penalty frameworks, and guidance interpretation. Connect with your regulator early to understand their DORA implementation priorities, preferred reporting formats, and any national circulars that supplement the core regulation. This engagement helps you avoid costly misalignments between your compliance approach and supervisory expectations.

Timeline management becomes particularly important given DORA's immediate applicability and the ongoing publication of technical standards. The regulation's core requirements took effect in January 2025, but detailed implementing standards for incident reporting and testing procedures have continued rolling out through 2025. Build flexibility into your compliance program to accommodate these evolving standards while maintaining momentum on foundational elements like governance structures and vendor inventories.

Resource allocation decisions should account for both initial implementation costs and ongoing operational requirements. DORA compliance isn't a one-time project—it creates permanent obligations for incident monitoring, vendor oversight, regular testing, and continuous risk assessment. Factor in the need for specialized skills in areas like threat intelligence, penetration testing, and regulatory reporting when planning your resource strategy.

Navigating technical implementation challenges

The register of information requirement represents one of DORA's most operationally complex obligations. You must maintain comprehensive records of all ICT third-party arrangements using standardized templates, covering everything from basic contractor information to detailed subcontracting chains and exit planning. The challenge lies not just in initial data collection, but in maintaining accuracy across dynamic vendor relationships. Consider how contract amendments, service changes, and vendor acquisitions will trigger register updates, and build processes that capture these changes systematically rather than through periodic manual reviews.

Incident classification and reporting demands both technical precision and operational speed. DORA's materiality thresholds for "major" incidents include specific metrics for client impact, duration, geographical spread, and economic consequences. Your incident response procedures must incorporate these classification criteria from the moment an incident is detected, not as an afterthought during reporting preparation. This requires training your operations teams on DORA-specific classification logic and potentially automating threshold calculations where your monitoring systems can provide relevant data points in real-time.

Integration with existing technology stacks often creates unexpected complexity. DORA doesn't mandate specific tools, but it does require specific capabilities that may not map neatly onto your current systems. For example, your existing GRC platform might handle policy management and control testing, but lack the vendor relationship mapping needed for subcontracting chain analysis. Your SIEM might detect security events effectively, but require additional logic to calculate DORA incident materiality thresholds. Plan for these gaps early and consider whether integration, replacement, or supplementary tooling best serves your long-term compliance and operational needs.

Third-party contract negotiations present both legal and operational hurdles under DORA's enhanced requirements. The regulation mandates specific contractual provisions for audit rights, data access, exit planning, and subcontracting disclosure. However, many established vendors—particularly large cloud providers—operate on standardized terms that may not accommodate these requirements directly. Develop a pragmatic approach that combines direct contractual provisions where possible with alternative assurance mechanisms like third-party certifications, transparency reports, and industry-standard audit programs where direct contract modifications aren't feasible.

Testing program design must balance regulatory requirements with operational realities. DORA's TLPT requirements align with the TIBER-EU framework, providing clearer guidance than previous national approaches. However, the specialized skills needed for advanced testing remain limited, and the operational impact of comprehensive resilience testing can be significant. Plan your testing cycles to align with business calendars, ensure adequate preparation time for systems and personnel, and coordinate with other regulatory testing obligations to avoid overwhelming your operational capacity.

Your DORA compliance roadmap

Foundation and governance

Establish management body oversight for DORA compliance, including clear accountability for each of the five pillars
Map your entity scope against DORA requirements and confirm proportionality provisions that apply to your organization
Designate control functions with specific DORA responsibilities and ensure appropriate skills and resources
Document your ICT risk management framework according to RTS 2024/1774 requirements, including governance, risk assessment, and control procedures
Align existing policies with DORA requirements for information security, business continuity, and vendor management

ICT risk management implementation

Complete comprehensive asset inventory covering all ICT systems, applications, and infrastructure components
Implement vulnerability management program with defined scanning, assessment, and remediation procedures
Establish business impact analysis methodology that supports both DORA compliance and broader resilience planning
Document recovery time and recovery point objectives for all critical and important functions
Create testing procedures for preventive, detective, and corrective controls across your ICT environment

Incident management and reporting

Implement incident classification logic based on RTS 2024/1772 materiality thresholds
Build reporting workflows that meet Delegated Regulation 2025/301 timeline requirements (initial, intermediate, and final reports)
Configure monitoring systems to capture data points needed for DORA classification and reporting
Establish authority reporting channels and confirm submission procedures with your competent supervisor
Train incident response teams on DORA-specific classification and escalation procedures

Third-party risk and vendor management

Develop comprehensive third-party policy covering the full arrangement lifecycle per RTS 2024/1773
Populate register of information using ITS 2024/2956 templates for all existing ICT arrangements
Review and update vendor contracts to include required audit rights, access provisions, and exit planning clauses
Map subcontracting chains for all critical and important function suppliers
Establish ongoing monitoring procedures for third-party performance and risk assessment

Testing and resilience validation

Assess TLPT applicability under Delegated Regulation 2025/1190 and coordinate with competent authority if required
Design comprehensive testing program that covers vulnerability assessments, scenario-based testing, and recovery procedures
Identify qualified testing providers and establish relationships for specialized resilience testing
Schedule testing cycles that balance regulatory requirements with operational capacity and business impact
Create testing documentation and evidence management procedures for supervisory review

Establish information sharing arrangements with relevant industry groups and authorities where beneficial
Coordinate with NIS2 obligations to ensure consistent incident reporting and threat intelligence sharing
Document threat intelligence procedures that support both preventive controls and incident response
Review data protection compliance for all DORA-related information sharing activities
Maintain relationships with supervisory authorities, industry groups, and peer institutions for ongoing coordination

FAQs

Q: How does DORA's ICT risk management framework work and what benefits does it provide?

A: DORA establishes a comprehensive ICT risk management framework built around five core pillars: ICT risk management, incident reporting, digital operational resilience testing, third-party risk management, and information sharing. The framework creates harmonized standards across all EU member states, replacing fragmented national approaches. This provides financial entities with clear, consistent requirements for everything from vulnerability management to vendor oversight, while enabling better coordination and information sharing across the financial sector.

Q: How does DORA help with automation and save time compared to previous approaches?

A: DORA enables significant automation opportunities, particularly in incident classification and reporting where standardized materiality thresholds can be built into monitoring systems for real-time assessment. Organizations can automate third-party register updates through integration with contract management systems, streamline TLPT testing through alignment with the TIBER-EU framework, and leverage standardized templates for regulatory reporting. By replacing multiple national requirements with a single harmonized framework, DORA eliminates duplicative compliance efforts across EU jurisdictions.

Q: How does DORA integrate with existing tools and handle data management requirements?

A: DORA is technology-agnostic and designed to work with existing technology stacks through capability requirements rather than mandating specific tools. Organizations can integrate DORA requirements through their existing GRC platforms for policy management, SIEM systems for incident monitoring, and contract management systems for third-party oversight. The regulation provides standardized templates for the register of information and incident reporting, enabling consistent data capture while allowing flexibility in how organizations implement these requirements within their current systems.

Q: What are DORA's limitations and where is human oversight still essential?

A: While DORA enables significant automation, human judgment remains critical for incident materiality assessment, especially for complex scenarios involving reputational impact or cross-system dependencies. Third-party risk assessment requires human expertise to evaluate subcontracting chains and exit planning effectiveness. TLPT testing demands specialized skills that remain scarce in the market, and strategic decisions about proportionality application and competent authority engagement require experienced compliance professionals who understand both regulatory requirements and business context.

Q: What should organizations consider when evaluating DORA compliance solutions?

A: Organizations should assess solutions based on their ability to handle all five DORA pillars in an integrated manner, since the requirements are interconnected. Key differentiators include support for standardized templates (particularly ITS 2024/2956 for third-party registers), automated incident classification aligned to RTS 2024/1772 thresholds, and flexibility to accommodate evolving technical standards. Consider the vendor's understanding of proportionality requirements for your entity size, integration capabilities with existing systems, and ability to support ongoing operational requirements rather than just initial implementation, since DORA creates permanent obligations for monitoring, testing, and reporting.