Digital Operational Resilience Act – DORA

The Digital Operational Resilience Act (DORA) addresses the need for financial institutions to enhance their ability to manage technology risks and ensure uninterrupted operations in an increasingly digital environment.

As reliance on digital infrastructure grows, DORA establishes a framework to help organizations safeguard their ICT systems from disruptions and cyber threats, ensuring long-term stability and resilience.

📚 Related: DORA Maturity Assessment

What is the Digital Operational Resilience Act - DORA?

The Digital Operational Resilience Act (DORA) is an EU regulation that ensures financial entities can withstand and recover from disruptions to their Information and Communication Technology (ICT) systems.

It establishes uniform guidelines across the European Union for managing ICT risks, incident reporting, operational resilience testing, information sharing, and third-party risk management. DORA is part of the EU’s broader Digital Finance Package, aimed at strengthening the operational resilience and cybersecurity of financial institutions.

The regulation applies to banks, insurance companies, investment firms, and payment service providers, as well as key third-party ICT service providers. By standardizing practices across all EU member states, DORA helps financial entities manage cyber risks and secure their operations.

📚 Related: Official DORA Journal of the EU

Key Drivers behind EU’s adoption of DORA

To address rising cyber risks, such as ransomware attacks on banks and data breaches in payment systems, which threaten financial stability. By creating a unified framework, DORA ensures financial institutions can manage ICT disruptions, recover quickly, and maintain consistent resilience across the EU.

• Increased Reliance on ICT: The financial sector’s growing dependence on technology heightens the need for a robust framework to manage ICT risks.
• Rising Cybersecurity Threats: With the rise in cyberattacks on financial institutions, DORA provides a unified approach to mitigate such risks.
• Harmonization of Standards: DORA addresses inconsistent risk management practices by introducing standardized resilience requirements across EU member states.

Scope and Applicability of DORA

DORA was established on January 16, 2023, as part of the EU’s Digital Finance Package to address pressing challenges in the financial sector. The regulation introduces a harmonized framework to manage ICT risks and enhance operational resilience across EU financial institutions.

The compliance due date is January 17, 2025, by which all affected entities and third-party ICT providers must fully implement DORA’s requirements.

Financial Entities Covered Under DORA

DORA applies to the following financial entities:

• Banks
• Insurance companies
• Investment firms
• Payment service providers
• Credit institutions
• Securities depositories
• Central counterparties
• Electronic money institutions
• Fund managers

These entities must implement comprehensive ICT risk management frameworks and ensure their operations can continue with minimal disruption in the event of cyberattacks or system failures.

Critical Third-Party ICT Service Providers

DORA also covers critical third-party providers of ICT services, such as:

• Cloud service providers
• Data center operators
• Payment processing companies
• Outsourced IT service providers

These providers play a vital role in the operations of financial institutions, and DORA imposes stringent requirements on them to ensure that any disruptions or risks originating from third parties are managed effectively.

Geographical and Sector-Specific Coverage

DORA applies across all EU member states and mandates a consistent approach to ICT risk management across the European financial sector.

While the regulation directly applies to entities operating within the EU, it also impacts third-party ICT providers located outside the EU, as long as they deliver services to EU financial entities. 

Core Requirements of DORA

DORA’s requirements are designed to create a unified framework for managing ICT risks, ensuring rapid recovery from disruptions, and enhancing the overall cybersecurity posture of financial institutions.

1. ICT Risk Management

DORA mandates that financial entities implement a robust ICT risk management framework that covers the following key components:

• Identification: Regular assessments to identify ICT risks and vulnerabilities across the organization.
• Protection: Security controls and strategies to protect systems, data, and networks from potential threats.
• Detection: Systems that monitor for anomalies and detect potential cybersecurity incidents.
• Response: Defined processes for responding to ICT incidents in real-time to minimize operational impact.
• Recovery: Comprehensive business continuity and disaster recovery plans to ensure swift restoration of services after a disruption.

What tools to use?

• Tools like SAP LeanIX provide visibility into IT components by building an inventory of applications, enhancing transparency, and identifying vulnerabilities.
• SAP Signavio Process Manager helps map regulatory requirements directly to business processes, enabling organizations to align their ICT risk management efforts seamlessly with DORA standards.

2. Incident Reporting

Financial entities must establish standardized processes for detecting, reporting, and responding to ICT-related incidents. DORA requires:

• Timely Detection: Monitoring systems must identify incidents as they happen.
• Standardized Reporting: Significant incidents must be reported to regulatory authorities promptly, using a standardized approach across the EU.
• Incident Response Framework: Organizations must develop incident response protocols that include clear communication channels for regulatory reporting.

3. Operational Resilience Testing

DORA requires regular testing of financial entities’ ICT systems to ensure they can withstand operational disruptions. This includes:

• Threat-Led Penetration Testing (TLPT): A key component of operational resilience testing, TLPT simulates real-world cyberattacks to test the strength of defenses.
• Routine Resilience Testing: Organizations must perform resilience assessments at regular intervals to validate the effectiveness of their ICT systems in mitigating risks.

What tools to use?

• These efforts can be documented efficiently using SAP Signavio Process Governance, where organizations can map testing scenarios and attach confirmation results.
• Additionally, SAP LeanIX helps assess the criticality of applications and processes, enabling targeted and impactful testing efforts.

4. Third-Party Risk Management

Given the reliance on external service providers, DORA places a strong emphasis on managing risks from third-party ICT providers:

• Due Diligence: Financial entities must conduct thorough evaluations of third-party providers before entering into contracts.
• Ongoing Monitoring: Institutions must continuously monitor third-party services to ensure that they adhere to operational resilience standards.
• Contractual Safeguards: Contracts with third-party providers must include provisions that address ICT risk management and resilience.

What tools to use?

• With SAP LeanIX, organizations can consolidate information about third-party vendors, including contracts, lifecycles, and compliance details, in a centralized system. This approach ensures transparency and facilitates ongoing monitoring.
• Additionally, SAP Signavio Process Governance supports workflows to document resilience testing outcomes and integrate vendor-related risks directly into business process management."

5. Information Sharing

To enhance collective resilience, DORA encourages financial institutions and competent authorities to share information regarding cyber threats and vulnerabilities. This facilitates:

• Threat Intelligence Sharing: Entities must participate in networks to share information on emerging cyber threats.
• Collaborative Defense: By sharing intelligence, financial institutions can better prepare for and mitigate risks, helping to safeguard the entire sector.

What tools to use?

• With SAP Signavio Process Governance, organizations can create secure workflows for sharing data and documenting collaboration efforts.
• SAP LeanIX complements this by providing insights into critical application dependencies and processes, ensuring that shared information focuses on high-priority areas.

📚 Related: Architecture Review Board

Impact of DORA on Enterprise Architecture

DORA has a significant impact on enterprise architecture in financial institutions. Enterprise architects play a key role in ensuring that ICT systems are designed to meet DORA’s requirements and support ongoing operational resilience.

DORA drives changes in how systems are structured, monitored, and governed to ensure compliance and minimize risks.

At a high level, DORA pushes organizations to prioritize resilience by design, embedding redundancy, and recovery processes into their infrastructure. It also demands tighter integration of security architecture, incorporating tools for real-time threat monitoring and incident response.

Additionally, EA frameworks must support ongoing governance, enabling continuous compliance auditing and reporting to meet DORA’s standards.

EA tools, such as LeanIX Enterprise Architecture help architects map applications, capabilities, and dependencies, providing insights into critical areas during disruptions. Meanwhile, BPMN tools, such as SAP Signavio Process Manager link regulatory requirements to business processes, ensuring compliance is embedded into operational workflows. Together, these tools enable enterprise architects to design systems that prioritize resilience and regulatory alignment.

By adopting a resilience-first approach, enterprise architects ensure that ICT systems not only meet regulatory requirements but also provide a robust foundation for long-term stability and operational continuity.

📚 Related: EA Governance

DORA Compliance Checklist

To help enterprise architects and CIOs ensure their organizations are prepared for the Digital Operational Resilience Act (DORA), this short checklist provides a practical set of action items. You can use a detailed DORA checklist to evaluate your organization's readiness.

• Have you implemented a comprehensive ICT risk management framework?
  • Are the key components—identification, protection, detection, response, and recovery—well established and regularly updated?
• Are you conducting regular operational resilience testing?
  • Have you performed Threat-Led Penetration Testing (TLPT) or similar resilience tests to evaluate your systems’ defenses?
• Is your incident reporting process in place and compliant with DORA’s standards?
  • Can you detect, report, and respond to ICT-related incidents within the required timeframes?
• Are third-party ICT service providers continuously monitored?
  • Have you established due diligence processes for third-party providers and set up ongoing performance and compliance monitoring?
• Are your governance structures set up for continuous auditing and reporting?
  • Have you integrated governance tools that ensure ongoing compliance with DORA, including continuous audits and regulatory reporting?

Key Action Items for Ensuring Readiness for DORA

• Evaluate Your IT Landscape: Use enterprise architecture tools like SAP LeanIX to map out your ICT systems and identify areas that require improvement or further resilience measures.
• Regularly Update Risk Management Protocols: Ensure that ICT risk management frameworks are not static, but continuously adapt to emerging threats and vulnerabilities.
• Maintain Clear Communication Channels for Incident Reporting: Ensure your teams are trained to report incidents promptly and follow a clear escalation process.
• Strengthen Relationships with Third-Party Providers: Conduct frequent reviews of third-party providers, updating contracts as necessary to meet DORA’s compliance requirements.
• Track Compliance Progress: Use dashboards or compliance tools to track your organization’s ongoing adherence to DORA regulations

Conclusion

The Digital Operational Resilience Act (DORA) represents a significant step forward in ensuring that financial institutions within the EU are equipped to manage and recover from ICT disruptions and cyber threats. With its comprehensive requirements for ICT risk management, incident reporting, third-party oversight, and operational resilience, DORA sets a new standard for digital resilience in the financial sector.

For enterprise architects, DORA introduces new challenges and opportunities to redesign systems with resilience, security, and compliance at their core. By adopting best practices, leveraging enterprise architecture tools, and continuously monitoring compliance, organizations can not only meet DORA's requirements but also build a stronger, more resilient digital infrastructure.

As financial services continue to rely on digital operations, ensuring compliance with DORA will be crucial for maintaining operational continuity, safeguarding against threats, and building trust in the financial system.