DORA Maturity Checklist

The Digital Operational Resilience Act (DORA) is an EU regulation aimed at enhancing the operational resilience of financial institutions by establishing standardized requirements for ICT risk management, incident reporting, third-party oversight, operational resilience testing, and governance.

It applies to a wide range of financial entities, including banks, insurance companies, and ICT service providers, ensuring they are prepared to withstand, recover from, and mitigate disruptions effectively. 

📚 Related: The Digital Operational Resilience Act (DORA) - Regulation (EU) 2022/2554

DORA Compliance Dates

The regulation was adopted on January 16, 2023, with a two-year implementation period. This means that all impacted organizations must comply by January 17, 2025.

During this period, institutions are expected to align their ICT frameworks, processes, and governance structures with DORA’s requirements to avoid penalties and operational risks.

📚 Related: Official DORA Journal of the EU

What Are the Penalties for DORA Non-Compliance?

Non-compliance with DORA can lead to significant financial and operational repercussions. Penalties include substantial fines, of up to 1% of the average daily worldwide turnover in the preceding business year. Regulators may also impose restrictions on operations, suspend certain activities, or require costly remediation measures.

Beyond legal penalties, non-compliance can damage an organization’s reputation, erode customer trust, and expose ICT systems to vulnerabilities, increasing the risk of cyberattacks or system failures. 

📚 Related: EBA Guidelines on ICT and Security Risk Management

DORA Compliance Checklist

This checklist provides practical steps for implementing DORA requirements effectively, including processes, tools, and organizational strategies.

1. Understand DORA Requirements

Before embarking on the compliance journey, it’s critical to gain a thorough understanding of DORA’s core requirements. This involves familiarizing yourself with the legislation’s articles and their implications for your organization’s ICT systems, processes, and governance structures.

Key Actions:

1. Review the full text of the DORA legislation, paying close attention to Articles 5–33.
2. Identify which sections of DORA apply directly to your organization based on its structure and activities.
3. Map out core requirements such as ICT risk management, incident reporting, third-party oversight, information sharing, and operational resilience testing.
4. Engage legal and compliance experts to interpret regulatory language and align it with your operations.
5. Host cross-departmental workshops to ensure all teams understand their roles in meeting DORA requirements.

2. Perform a DORA Gap Analysis

A DORA Gap Analysis identifies the differences between your organization’s current ICT systems, processes, and governance structures and DORA’s requirements. This foundational step helps pinpoint areas of non-compliance and provides a roadmap for addressing gaps.

Key Actions:

1. Assess current ICT risk management frameworks, incident reporting workflows, and resilience measures.
2. Use enterprise architecture tools to map existing IT systems and identify vulnerabilities.
3. Conduct interviews and surveys with key stakeholders to uncover operational gaps.
4. Develop a matrix comparing your current state to DORA’s requirements, highlighting areas that need improvement.
5. Prioritize gaps based on risk severity and compliance deadlines to allocate resources effectively.

3. Develop a Comprehensive ICT Risk Management Plan

A robust ICT risk management plan aligns with regulatory expectations. This involves identifying, assessing, and mitigating risks across your ICT infrastructure.

Developing this plan starts with identifying critical ICT systems and mapping their dependencies. Regular risk assessments help pinpoint vulnerabilities and prioritize mitigation strategies. For ongoing risk detection, integrate real-time monitoring systems, such as SIEM platforms, that alert teams to potential threats.

Incorporating resilience testing, including Threat-Led Penetration Testing (TLPT), is essential. Frameworks like TIBER-EU provide structured simulations of real-world cyber threats, enabling organizations to validate their recovery capabilities and refine their response strategies.

Key Actions:

1. Identify and map critical ICT systems and dependencies.
2. Conduct regular ICT risk assessments and document findings.
3. Implement SIEM systems for real-time threat detection.
4. Perform resilience testing using TLPT frameworks like TIBER-EU.
5. Develop and maintain recovery and mitigation plans.

4. Establish Clear Incident Reporting Protocols

DORA mandates a structured process for detecting, escalating, and reporting ICT-related incidents to regulators within tight timelines.

To meet this requirement, organizations should develop workflows that classify incidents by severity and urgency. Business process management tools can help automate these workflows, ensuring incidents are escalated promptly. Integration with monitoring systems ensures that detection and reporting are seamless, reducing delays in regulatory submissions.

TIBER-EU exercises can also test incident reporting workflows under simulated attack conditions, highlighting gaps and ensuring readiness for real-life scenarios.

Key Actions:

1. Develop workflows for incident classification, escalation, and reporting.
2. Automate reporting processes with tools like BPM tools.
3. Train staff on incident reporting protocols and DORA requirements.
4. Maintain comprehensive incident logs for audit purposes.
5. Test incident reporting workflows during TLPT exercises.

5. Implement Operational Resilience Measures

Operational resilience ensures that ICT systems can withstand disruptions and recover effectively, minimizing operational impact. DORA emphasizes regular resilience testing to validate these measures.

Using EA tools, organizations can map critical systems and dependencies, identifying single points of failure that require redundancy. Regular TLPT exercises, such as those guided by TIBER-EU, are essential for testing the robustness of resilience plans. These exercises simulate high-pressure attack scenarios, such as cyberattacks on payment systems, to assess recovery capabilities and refine disaster recovery strategies.

Defining clear recovery time objectives (RTOs) and recovery point objectives (RPOs) is also critical. These metrics guide the design of failover mechanisms and influence decisions about resource allocation for disaster recovery efforts.

Key Actions:

1. Map critical systems and identify points of failure.
2. Define RTOs and RPOs for critical systems.
3. Conduct regular resilience tests, including TLPT exercises.
4. Validate disaster recovery plans and refine as needed.
5. Monitor and document testing outcomes for continuous improvement.

6. Strengthen Third-Party Risk Management

Third-party ICT providers pose significant risks that must be managed effectively to meet DORA standards. Organizations should maintain a comprehensive inventory of third-party vendors, documenting their roles and access to ICT systems.

Regular due diligence, including vendor risk assessments, ensures compliance with DORA’s standards. Vendor management tools can track SLA performance and send alerts for potential non-compliance.

The TIBER-EU framework may extend to include critical third-party providers in resilience tests. For example, testing a vendor’s ability to recover from simulated attacks can help organizations evaluate their preparedness and address any gaps before disruptions occur.

Key Actions:

1. Maintain an up-to-date inventory of all third-party vendors.
2. Conduct due diligence and regular vendor risk assessments.
3. Include compliance obligations in vendor contracts.
4. Monitor SLA adherence with automated tools.
5. Evaluate vendor resilience through simulated TLPT exercises.

7. Optimize Governance and Compliance Processes

Strong governance structures are required to ensure ongoing compliance with DORA. Governance encompasses defining policies, automating audit trails, and fostering collaboration across teams.

Organizations can deploy governance dashboards to monitor compliance metrics in real time. BPM tools enable the automation of workflows, streamlining activities like audit preparation and compliance reporting.

Cross-department collaboration between IT, risk, and compliance teams ensures that governance structures remain aligned with regulatory changes and organizational priorities.

Key Actions:

1. Establish governance policies aligned with DORA requirements.Automate audit trails and compliance monitoring processes.
2. Use dashboards to track compliance metrics in real time.
3. Schedule regular governance reviews and update policies as needed.
4. Foster collaboration between IT, risk, and compliance teams.

8. Facilitate Organizational Change and Awareness

DORA compliance requires organizational commitment and cultural alignment to adopt new workflows, technologies, and processes effectively.

Building awareness across teams begins with educating employees on DORA’s requirements and their roles in compliance. Continuous training programs ensure that staff remain up-to-date on best practices in ICT risk management, incident reporting, and resilience testing.

Using TLPT exercises, such as those under TIBER-EU, can further reinforce practical learning by exposing teams to realistic, high-pressure scenarios.

Leadership engagement is equally critical. Securing executive sponsorship ensures resources and priorities align with compliance goals, while regular updates on compliance progress foster accountability and organizational buy-in.

Key Actions:

1. Educate employees on DORA requirements and their roles.
2. Provide continuous training on ICT risk management and resilience testing.
3. Integrate compliance practices into daily operations and company culture.
4. Engage leadership to align priorities with compliance goals.
5. Evaluate and adapt change initiatives to improve adoption and effectiveness.

9. Leverage Technology for Compliance

Investing in the right tools is crucial for efficiently meeting DORA requirements and ensuring long-term compliance.

1. Enterprise Architecture Platforms (e.g., SAP LeanIX): Enables architects to map ICT dependencies, identify risks, and design resilient systems. For example, LeanIX Enterprise Architecture can help identify high-risk legacy systems requiring updates to meet DORA standards.
2. Process Optimization Tools (e.g., SAP Signavio): Automates workflows for incident reporting, resilience testing, and compliance tracking. For instance, SAP Signavio streamlines escalation workflows, ensuring incidents are reported within DORA’s timelines.
3. Monitoring and Incident Management Tools: Integrates SIEM systems with incident management platforms to detect threats and automate response processes. These tools help IT teams respond faster to detected anomalies.
4. Vendor Management Systems: Tracks third-party performance and compliance with SLAs, ensuring vendors meet resilience standards. For example, automated alerts flag SLA breaches, prompting timely remediation.
5. Resilience Testing Platforms (e.g., TIBER-EU frameworks): Facilitates realistic simulations to evaluate system recovery and validate operational resilience measures. For example, a TLPT exercise may simulate a ransomware attack to test how effectively failover mechanisms activate.
6. Governance Dashboards: Automates compliance audits, tracks metrics, and provides real-time insights into governance performance. These dashboards help compliance teams maintain visibility across all operational areas.

📚 Related: The Role of Enterprise Architecture in DORA Compliance