Guide to DORA Compliance & Requirements (+ Free Checklist)

What Is DORA Compliance?

The Digital Operational Resilience Act (DORA) Compliance is an EU regulation designed to strengthen cybersecurity and operational resilience in the financial sector. Before DORA, financial institutions relied heavily on capital reserves to manage operational risks, but this approach didn’t fully address digital threats.

DORA shifts the focus to proactive ICT (Information and Communications Technology) risk management, ensuring that financial entities and their critical third-party service providers can withstand and recover from cyber incidents and have business continuity. It standardizes cybersecurity reporting, resilience testing, and third-party risk management across the EU financial sector.

With a compliance deadline of January 17, 2025, financial institutions and designated ICT providers working under the EU must be ready to meet these new requirements.

DORA Regulation Summary 

DORA strengthens the financial sector’s ability to handle digital disruptions, ensuring banks, insurers, and stock exchanges stay operational despite cyber threats, IT failures, or other risks.

Instead of dealing with digital threats in silos, DORA creates a unified approach across the European financial sector and European Banking Authority, making resilience a top priority. As Ciancimino of IS Partners explains, “The largest risk the regulation aims to counteract is the level to which the European financial system is interconnected, with an availability issue causing large-scale financial systems to be unavailable due to the interconnected webs that the European financial ecosystem relies upon.” 

By enforcing standardized risk management and operational resilience requirements, DORA helps mitigate these systemic vulnerabilities, ensuring that disruptions in one entity do not create cascading failures across the financial ecosystem..

At its core, the regulation focuses on three main areas:

Risk Management

Financial institutions are required to put a structured ICT risk management regulatory framework in place. This means having clear processes to identify, address, and mitigate digital risks effectively. 

The framework should be regularly tested to ensure that firms can respond swiftly and efficiently to cyber threats and operational disruptions.

Incident Management

DORA mandates that organizations establish a systematic process for handling ICT-related incidents. Financial entities must have procedures to detect issues early, manage them effectively, and report significant incidents to the relevant authorities. 

This ensures that threats are not just contained but are also properly monitored and analyzed for long-term resilience.

Supply Chain Security

Since financial institutions rely on multiple third-party ICT service providers, DORA requires firms to treat supplier risks as part of their overall digital risk strategy. This includes:

• Ensuring contracts with vendors address potential cybersecurity risks
• Keeping an updated register of all ICT service providers
• Reporting third-party risk assessments annually to the relevant regulatory body

Where DORA Stands Today

The European Commission first introduced DORA in September 2020 as part of a broader push to modernize digital finance and regulate emerging risks like cyber threats and crypto-assets. By November 2022, the regulation was officially adopted by the European Parliament and the Council of the EU.

Now, financial firms and third-party tech providers that support them have a deadline of January 17, 2025. That’s when DORA compliance becomes mandatory, and enforcement begins.

Who Must Comply with DORA? 

DORA applies to a broad range of financial institutions and their technology providers. Any organization that plays a role in the EU’s financial ecosystem must comply, including those that provide ICT services to these entities, regardless of where they are based.

Here’s a look at the financial institutions covered under DORA:

Banking & Payment Services

• Credit institutions (banks)
• Payment institutions
• Electronic money institutions
• Account information security service providers

Investment & Trading

• Investment firms
• Trading venues (stock exchanges, multilateral and organized trading facilities)
• Central counterparties
• Central securities depositories
• Alternative investment fund managers (AIFMs)
• Management companies of UCITS (Undertakings for Collective Investment in Transferable Securities)
• Trade repositories
• Crowdfunding service providers

Crypto & Digital Assets

• Crypto-asset service providers
• Issuers of asset-referenced tokens

Insurance & Pensions

• Insurance and reinsurance companies
• Insurance intermediaries, reinsurance intermediaries, and ancillary European insurance intermediaries
• Institutions for Occupational Retirement Provision

Financial Data & Ratings

• Credit rating agencies
• Administrators of critical benchmarks
• Securitization repositories
• Data reporting service providers

Third-Party ICT Service Providers

Beyond financial entities, DORA directly impacts technology providers that support the financial sector. This includes cloud service providers, data analytics firms, cybersecurity companies, and other ICT vendors offering critical digital services.

11 Steps to Get DORA Compliance 

This guide breaks down the essential steps to achieve full DORA compliance, from risk management and incident reporting to resilience testing and third-party oversight. Take a look at the steps in detail.

1. Determine Your Scope

If you’re in the financial sector working under the jurisdiction of the EU, DORA applies to you. It doesn’t matter if you’re a bank, an investment firm, a crypto platform, or a crowdfunding service—if your business plays a role in the EU’s financial system, like European securities, you’re within its scope.

It also applies to businesses that are not usually regulated in finance. If you provide tech services to financial firms like cloud hosting, cybersecurity, or data analytics, you are also on the hook.

As Joe Ciancimino, Senior Director of SOC Practice at IS Partners, explains, one of the primary challenges financial institutions face when implementing DORA is “how financial institutions define the scope of their ICT ecosystem, and from there, how the specific directives of the regulation impact their ICT scope.” Establishing clear boundaries around what systems, vendors, and data flows fall under DORA’s oversight is crucial for compliance and risk management.

2. Conduct an ICT Gap Analysis Risk Assessment

DORA makes it clear that financial institutions need to identify, document, and manage every risk tied to their ICT systems and services.

So, what does that mean for you? You need to conduct a proper risk assessment, and it involves:

• Mapping out system dependencies. Know how your systems interact and where potential vulnerabilities lie.
• Setting clear recovery objectives. How quickly should your systems bounce back from a disruption? Define recovery time goals that align with business needs.
• Assigning ownership. Every system component needs a responsible party. Who’s in charge when something goes wrong? Make it clear.
• Vulnerability assessments. Continuously scan for security gaps, misconfigurations, and outdated systems
• Continuous monitoring. Use real-time threat detection tools to track anomalies and potential breaches. Also, establish automated alerts to respond to risks before they become cybersecurity incidents.

Trust IS Partners to help you identify gaps in your operations and security management according to the DORA requirements. 

Our team offers comprehensive audits and informational walkthroughs, helping you understand the complexities of the law while achieving compliance. 

3. Build Your DORA Remediation Roadmap

Once you’ve assessed your ICT risks and compliance gaps, it’s time to map out a clear action plan to get everything in order.

Here’s how to do it effectively:

• Review your risk assessment results
• Identify areas where you fall short of DORA’s requirements
• Prioritize fixes based on urgency and feasibility

• Break down tasks into quarterly milestones to keep progress on track
• Assign responsibilities to relevant teams
• Ensure leadership is involved in accountability

• Update policies, enhance monitoring, and improve reporting workflows
• Verify updates

At IS Partners, we produce the most efficient compliance roadmap for your organization. If you are an existing SOC 2 client, we can help you map an effective compliance process that combines the efficiencies and effectiveness of SOC 2 and DORA. 

Contact us today!

4. Create an Effective Incident Response Plan

No financial institution is immune to cyber threats or system failures, which is why having a solid incident response plan is non-negotiable under DORA. Here’s how to make sure your plan is airtight:

• Define what qualifies as an incident. Not every system glitch is a crisis—set clear criteria for what needs urgent action. Categorize incidents by severity (minor, major, critical).
• Establish a response workflow.

• Detection. How will you spot security breaches and IT failures?
• Containment. What’s the immediate action to prevent further damage?
• Resolution. Who’s responsible for fixing it, and how fast should it happen?
• Recovery. How will you get systems back to normal with minimal downtime?

• Assign clear roles and responsibilities. See who leads the response team,  who handles internal and external communication, and a person who ensures compliance with reporting requirements.
• Test and update the plan regularly. Run simulated attack drills to ensure your team is prepared. Adjust based on lessons learned and evolving threats.

5. Get Threat-Led Penetration Testing (TLPT)

Under Article 26 of DORA, financial institutions must stress-test their cybersecurity defenses using Threat-Led Penetration Testing. This is a deep dive into how well your systems can withstand real-world cyberattacks.

Here’s what you need to do:

• Use an approved TLPT framework. IS Partners can help you with penetration testing as it is conducted by our highly skilled cybersecurity team. The test must cover multiple or all critical functions of your organization.
• Get scope approval from authorities. Define what’s in and out of scope for your TLPT. Get approval from competent authorities as required under Article 46 of DORA.
• Include third-party providers if needed. If your ICT vendors are considered critical, ensure they participate in TLPT testing. Work with them to establish safeguards that prevent unnecessary disruption.
• Test in live environments. The testing must happen in live production systems to reflect real-world threats.
• Stick to the testing frequency. TLPT must be performed at least every three years, but some organizations may need to test more frequently based on risk exposure.

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6. Keep Third-Party Risks Under Control

If your business depends on third-party tech providers, you can’t just assume they’re secure, you need to prove it. DORA makes ICT third-party risk management a priority, meaning you’re responsible for ensuring that your vendors don’t become your weakest link.

Here’s how to stay ahead:

• Do your homework before signing contracts. Vet every provider thoroughly and check security practices, past incidents, and compliance history.
• Lock in strong contractual protections. Clearly define data protection, incident reporting, and audit rights in all agreements. Set expectations on resilience testing and compliance monitoring.
• Monitor. Regularly assess vendor security measures and track their performance. Require periodic compliance reports and proof of risk mitigation.
• Have a backup plan. If a critical vendor fails, your business shouldn’t collapse with them. Develop contingency strategies to transition to an alternative provider if needed.

7. Implement Governance and Oversight

Staying compliant with DORA is a leadership responsibility. Strong governance ensures that everyone knows their role in managing ICT risks and that accountability starts at the top.

Here’s what you need to focus on:

• Define clear roles & responsibilities. Set up a structured governance framework that outlines who’s in charge of what. Ensure risk management, compliance, and IT teams are aligned.
• Get senior management actively involved. Leaders can’t afford to be bystanders, they must oversee digital resilience efforts. They should regularly review risk reports, incident logs, and compliance updates.
• Report progress regularly. Provide senior management with detailed reports on risk management, incident trends, and DORA compliance status. Use data-driven insights to help them make informed decisions.

8. Continuously Monitor Your ICT

Cyber threats don’t take breaks, and neither should your ICT risk management. Article 8 of DORA makes it clear that financial institutions must constantly track and manage risks to stay resilient. It’s an ongoing process to detect, assess, and mitigate vulnerabilities before they turn into major disruptions.

Here’s what you need to do:

• Map out your ICT system. Identify and document all critical business functions, assets, and dependencies.
• Keep a close eye on cyber threats. Regularly assess vulnerabilities that could impact your ICT operations.
• Reassess after major system changes. If you update networks, shift to new infrastructure, or integrate new tech, reevaluate your risks.
• Maintain inventories of all ICT assets. Keep detailed records of all third-party dependencies, legacy systems, and technologies.
• Regularly test legacy systems for weaknesses. Older systems can be security liabilities, and audit them frequently for risks.

9. Encourage Intelligence Sharing

DORA encourages financial institutions to collaborate because sharing intelligence can mean the difference between preventing an attack and dealing with its aftermath.

Here’s how to make intelligence sharing work for you:

• Engage with industry peers & regulators. Join financial services sector threat intelligence groups to stay ahead of emerging risks. Share insights with regulatory bodies and trusted industry networks.
• Exchange real-time threat intelligence. If you detect a cyber threat, don’t keep it to yourself, sharing early warnings helps others prepare. Learn from others’ incidents to strengthen your defenses. Some of the threat intelligence sharing channels include FI-ISAC (Financial Services Information Sharing and Analysis Center), ENISA Threat Intelligence Sharing Platforms, TIBER-EU (Threat Intelligence-Based Ethical Red Teaming and EU-CERT (European Computer Emergency Response Team).
• Adopt best practices for cyber resilience. Tap into lessons learned from major security breaches across the industry. Implement proven risk mitigation strategies used by top-performing organizations.

10. Reporting and Auditing

With DORA, you get regular reporting, audits, and detailed records to show regulators you’re on top of your digital resilience.

Here’s what you have to do:

• Set up efficient reporting mechanisms. Automate data collection for ICT risk management, incident reports, and audit findings.
• Be audit-ready at all times. Regulators and independent auditors will check for compliance, and make sure you have all documentation and evidence easily accessible. Conduct internal compliance reviews before an audit to identify and fix potential gaps.

11. Train Employees & Build Awareness

Your employees are your first line of defense against cyber threats. To stay compliant with DORA and keep your business secure, they need ongoing training on:

• Cybersecurity best practices. How to spot phishing attempts, prevent breaches, and follow secure protocols.
• Incident reporting. What to do if they detect a security issue and how to report it properly.
• Operational resilience. Understanding their role in keeping information systems secure and minimizing disruptions.

Regular training ensures that everyone knows how to respond to risks, reducing human error and strengthening your company’s digital defenses.

What Are the 5 Pillars of DORA Regulation?

DORA sets guidelines for financial institutions to build resilience against cyber threats and operational disruptions. Here’s how the regulation breaks down into five essential pillars:

ICT Risk Management

Financial institutions must develop and maintain a robust ICT risk management framework that covers every stage of an ICT system’s lifecycle. This includes:

• Identifying cyber threats early
• Implementing strong protection and detection measures
• Establishing rapid response and recovery strategies
• Conducting continuous testing and monitoring to ensure ongoing security

ICT Incident Reporting

Under DORA, firms must report major ICT-related incidents to regulators promptly. As soon as a major ICT-related incident is detected, firms must send a preliminary report to their national competent authority (NCA) or the relevant European Supervisory Authority (ESA) (EBA, ESMA, or EIOPA). This ensures:

• A better understanding of cyber threats across the financial sector
• A coordinated response to major incidents
• Stronger regulatory oversight and guidance

If something goes wrong, regulators need to know, and they expect a detailed, structured report to track trends and strengthen sector-wide resilience.

What Channel to Use?

Each EU member state has designated authorities (e.g., BaFin in Germany, ACPR in France, FCA in the UK) where reports must be submitted.

For critical incidents affecting multiple jurisdictions, reporting may also go to EBA (banking), ESMA (securities), or EIOPA (insurance & pensions).

Digital Operational Resilience Testing

To prove their ability to withstand cyberattacks and system failures, financial institutions must conduct regular testing, including:

• Threat-led penetration testing to simulate real cyberattacks.
• Routine resilience assessments for all critical ICT systems.

If you’re not testing your defenses, you’re leaving gaps open for attackers. DORA makes testing mandatory to ensure systems hold up under pressure.

ICT Third-Party Risk Management

DORA recognizes that financial institutions rely heavily on third-party ICT providers, so it sets strict regulatory requirements for managing vendor risks:

• Conduct due diligence before onboarding ICT service providers.
• Continuously monitor third-party regulatory compliance with security and operational resilience standards.
• Have strong contractual agreements that define security responsibilities and response protocols. IS Partners helps with high-quality vendor risk assessment tailored to your organization with a team of cyber experts. 

Your security is only as strong as your weakest vendor, DORA ensures that third-party potential risks are actively managed and not ignored.

Information & Intelligence Sharing

DORA encourages financial institutions to share cyber threat intelligence across the industry to:

• Detect emerging cyber risks faster.
• Learn from other organizations’ experiences.
• Improve overall sector-wide resilience.

You can share the threat intelligence through channels like Europol which which facilitates the exchange of intelligence between member states. Also, the Cyber Information and Intelligence Sharing Initiative (CIISI-EU), launched by the European Cyber Resilience Board (ECRB), allows public and private entities to share cyber intelligence.

Is DORA Mandatory?

Yes, DORA is mandatory, and it is a legal or key requirement if you’re a financial institution or an ICT service provider operating in the EU. This regulation applies to banks, insurance companies, investment firms, trading platforms, and any critical third-party ICT providers supporting the financial sector.

Non-compliance can lead to fines, enforcement actions, and reputational damage—not to mention leaving your business vulnerable to cyber threats.

If your organization falls under DORA’s scope, you need to take action now. Regulators are watching, and the penalties for falling short are serious.

DORA Penalties: What Happens If You Don’t Comply?

DORA enforces cybersecurity standards with serious financial penalties. If your organization fails to meet DORA’s requirements, the fines can be substantial, and they vary based on who is responsible and how severe the violation is.

Here’s what’s at stake:

• Financial institutions can be fined up to 2% of their total annual worldwide turnover or 1% of their average daily global turnover for non-compliance.
• For violations, individuals within financial firms (such as executives or compliance officers) can face fines of up to €1,000,000.
• Critical third-party ICT providers, those supplying essential digital services to financial institutions, face even higher penalties:

• Up to €5,000,000 for organizations
• Up to €500,000 for individuals

DORA’s penalties are stricter than some existing regulations, including GDPR, which imposes fines of up to €20,000,000 or 4% of global turnover in the most severe cases.

Additional Sanctions

• Public reprimands that can damage your reputation
• Operational restrictions that could limit your ability to do business
• In extreme cases, regulators can revoke your authorization to operate

IS Partners Is Ready to Help You Comply with the DORA Regulation

The Digital Operational Resilience Act (DORA) is not just another regulation—it’s a game-changer for financial institutions and service providers. Starting January 2025, organizations must prove they can withstand cyber threats and operational disruptions. Non-compliance isn’t an option—it can lead to penalties, reputational damage, and lost business.

IS Partners has been preparing for this shift and is ready to guide organizations through compliance with tailored solutions that simplify the process. Our DORA Compliance Assessment provides a comprehensive review of your security controls, documentation, and processes to identify gaps.

With IS Partners by your side, you’ll meet regulatory standards and build a more resilient, secure, and future-proof business.

IS Partners ensures you’re ready—without the hassle. Let’s strengthen your resilience together. Contact us today!

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About The Author

John DeCesare

John has over 22 years of experience working in the manufacturing, distribution, not-for-profit, governmental, insurance, public utilities and service industries. John has expertise in various aspects of the accounting, auditing and consulting disciplines. He has directed a full range of value-added services and has consulted to Senior Executives in middle market and Fortune 500 companies. His experience includes Sarbanes-Oxley compliance, SOC 1 audits, outsourcing and contract services, financial management, accounting and strategic planning, due diligence, business restructuring / re-engineering, process improvement and risk assessment.