DORA Maturity Assessment

A DORA maturity assessment evaluates an organization’s preparedness for the Digital Operational Resilience Act (DORA Regulation) by analyzing its existing ICT systems, processes, and governance structures.

It helps financial institutions determine their maturity level in core areas, such as risk management, resilience testing, and compliance monitoring, providing a roadmap for improvement.

Part of this assessment includes a DORA gap analysis, which identifies specific gaps between current capabilities and DORA requirements. This analysis highlights areas needing immediate attention and informs strategic planning for compliance. 

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

Why Conduct a DORA Maturity Assessment?

With the DORA coming into effect on January 17, 2025, conducting a maturity assessment is critical for financial institutions to ensure readiness. It helps organizations evaluate current capabilities, identify gaps, and prioritize improvements to meet regulatory requirements.

• Clarity on Compliance Status: It gives organizations a clear understanding of their strengths and weaknesses in ICT risk management, resilience, and compliance.
• Prioritization of Efforts: Helps allocate resources effectively by focusing on high-priority areas.
• Operational Resilience: Ensures systems are designed to withstand disruptions and recover swiftly.
• Proactive Risk Mitigation: Identifies vulnerabilities before they escalate into compliance or operational issues.
• Streamlined Audits: Simplifies regulatory audits by providing documented proof of compliance and a roadmap for continuous improvement. 

📚 Related: Official DORA Journal of the EU

Key Dimensions

Use these dimensions to understand all critical areas before conducting your DORA maturity assessment. Each dimension highlights what to check and address so you can identify and resolve any gaps.

1. ICT Risk Management

Confirm your risk inventory is complete, covering all IT systems, applications, and dependencies. Check for overlooked vulnerabilities in interconnected systems and ensure your continuity plans address all critical applications. Make sure your system inventory is regularly updated to capture emerging risks and align with DORA’s requirements.

2. Incident Reporting and Management

Ensure you have systems in place to detect incidents in real time and workflows that escalate and report incidents within DORA’s strict timelines. Look for any gaps in your detection mechanisms or inconsistencies in your regulatory reporting process. Align your incident response workflows with DORA’s standards to maintain compliance.

3. Operational Resilience Testing

Verify that your resilience testing covers all critical systems and includes scenarios like Threat-Led Penetration Testing (TLPT). Avoid skipping high-priority systems or leaving test results undocumented. Use resilience tests to identify weaknesses and validate recovery mechanisms to prepare your organization for real-world disruptions.

4. Third-Party Risk Management

Examine your third-party vendor relationships closely. Are you continuously assessing vendor compliance with DORA, monitoring SLA performance, and including disaster recovery requirements in your contracts? Make sure you’re tracking these dependencies and addressing any risks tied to external providers.

5. Governance and Compliance

Evaluate your governance framework to ensure it provides continuous monitoring and clear reporting of ICT risks. Confirm that you have automated compliance reports, detailed audit trails, and policies that align with DORA’s evolving standards. Look for any missing documentation or unclear processes that could undermine your compliance.

6. Critical Data Governance

Identify and secure all DORA-critical data objects within your IT systems. Check that data flows are mapped, encryption protocols are in place, and access controls are being monitored. Don’t overlook the importance of classifying data to focus your resources on securing the most critical assets.

7. Information Sharing

Ensure seamless and secure information sharing. You need frameworks that facilitate the exchange of cyber threat intelligence, both internally and with external stakeholders like regulators and industry peers. Focus on creating standardized sharing protocols to improve collaboration and collective defense. 

📚 Related: EBA Guidelines on ICT and Security Risk Management

How to Conduct a DORA Maturity Assessment?

Conducting a maturity assessment involves several stages, with cross-functional involvement ensuring a holistic approach:

Step 0: Understand DORA Requirements

Before beginning the assessment, it’s essential to understand DORA’s core requirements and their implications for your organization. This step involves reviewing the regulation in detail, breaking it down into manageable components, and mapping them to your current operations. A clear understanding of the requirements ensures that subsequent steps address the right areas effectively.

Who’s involved?

• Compliance officers and enterprise architects collaborate to interpret DORA’s requirements and identify which areas of the organization they apply to.

Practical steps:

• Break down DORA into its core elements (ICT risk management, incident reporting, resilience testing, third-party risk management, governance, and information sharing).
• Map these elements to existing processes, systems, and stakeholders.

Step 1: Establish Baseline Maturity Levels

Establishing baseline maturity levels helps you understand your starting point. This involves mapping your IT infrastructure, cataloging applications, and identifying existing controls and policies. This foundational step ensures that all stakeholders have a shared understanding of current capabilities and vulnerabilities.

Who’s Involved?

• Enterprise architects, compliance officers, and risk managers work together to document current processes, tools, and policies.

Practical steps:

• Use enterprise architecture tools to create a comprehensive map of IT systems and their dependencies.
• Analyze workflows to identify inefficiencies and areas where resilience measures are missing or inadequate.

Step 2: Perform a DORA Gap Analysis – Impact Assessment

The gap analysis compares your current state to DORA’s requirements. This process highlights areas needing immediate attention, such as operational resilience testing, vendor management, or ICT risk frameworks. It also identifies the potential impact of these gaps on your organization’s ability to comply and remain operational during disruptions.

Who’s involved?

• Compliance officers lead the analysis, supported by IT teams and risk managers.

Practical steps:

• Assess third-party vendor to evaluate the compliance and resilience of all third-party ICT providers. This includes SLA adherence, disaster recovery plans, and risk monitoring practices.
• Analyze business impact to quantify the potential impact of disruptions on your critical business functions, ensuring a clear understanding of priorities and vulnerabilities.
• Identify and map dependencies between applications, business capabilities, and processes. Use this mapping to pinpoint where gaps in operational resilience may exist.
• Assess the impact of identified gaps on your organization’s ability to meet DORA requirements. This assessment helps prioritize remediation efforts based on risk severity and regulatory importance.

Step 3: Leverage Tools for Tracking and Visualization

Visualization and tracking tools provide clarity and oversight during your maturity assessment. By configuring dashboards and mapping processes, you can monitor progress and ensure alignment with DORA’s requirements. These tools also help stakeholders understand gaps and make data-driven decisions.

Who’s involved?

• Enterprise architects and IT teams integrate tools to enhance visibility and tracking.

Practical steps:

• Configure SAP LeanIX dashboards to track compliance metrics.
• Use SAP Signavio to visualize process inefficiencies and map improvement plans.

Step 4: Set Priorities and Define Action Plans

The final step is to define a roadmap to close compliance gaps and strengthen your operational resilience. This roadmap should prioritize high-risk areas, outline long-term objectives, and allocate resources effectively. Collaboration among senior leadership, compliance officers, and enterprise architects is critical to ensure alignment and accountability.

Who’s involved?

• Senior leadership sets priorities, while architects and risk managers define specific steps.

Practical steps:

• Use risk analysis tools to quantify impacts and prioritize efforts.
• Develop a roadmap addressing both immediate and long-term compliance goals.

📚 Related: The Role of Enterprise Architecture in DORA Compliance

DORA Maturity Levels Explained

Organizations’ progress toward DORA compliance can be categorized into five maturity levels, each reflecting their readiness to meet the regulation’s core requirements.

These levels offer a framework for organizations to assess their position and outline the steps needed to advance.

Level 1: Initial

Organizations lack standardized processes for risk management, resilience testing, and compliance monitoring. ICT systems are typically fragmented, with limited visibility into vulnerabilities or dependencies.

To progress, organizations need to focus on establishing foundational frameworks for ICT risk management and incident reporting.

• Current state: Processes are ad hoc and poorly defined.
• Key Focus Areas: Establishing frameworks for ICT risk management and reporting.

Level 2: Developing

Level 2 indicates that basic processes have been introduced, but they remain inconsistent or incomplete. For instance, incident detection may rely on manual processes, and resilience testing might not be conducted regularly.

To reach the next level, organizations must begin automating key processes and ensuring that governance structures are standardized across departments.

• Current state: Basic processes exist but lack consistency.
• Key Focus Areas: Begin standardizing governance structures and resilience testing.

Level 3: Established

At Level 3, organizations have functional frameworks for compliance, but they require further optimization to align with DORA’s stringent standards. Resilience testing is conducted periodically, and third-party risks are monitored, though not in real-time.

Moving to Level 4 requires integrating enterprise architecture tools to automate compliance tracking and BPM tools to optimize workflows for efficiency.

• Current state: Frameworks are functional but require optimization.
• Key Focus Areas: Automate incident reporting and third-party monitoring.

Level 4: Advanced

Organizations demonstrate strong resilience, proactive risk management, and robust monitoring systems. Incident reporting workflows are fully automated, and third-party risk management is comprehensive

To achieve the highest maturity level, organizations need to continuously innovate resilience strategies and use advanced simulations to prepare for evolving threats.

• Current state: Systems are resilient, with robust monitoring and testing in place.
• Key Focus Areas: Focus on continuous improvement and enhanced automation.

Level 5: Optimized

At Level 5, full DORA compliance is achieved, supported by automated processes, real-time governance dashboards, and integrated resilience testing environments.

Continuous improvement is embedded in the organization’s culture, enabling rapid adaptation to regulatory changes and emerging risks.

• Current state: Full DORA compliance is achieved, supported by proactive risk management and real-time governance.
• Key Focus Areas: Innovate resilience strategies and perform continuous simulations.

Tools and Resources

Effective tools are necessary for assessing DORA maturity, as they enable organizations to visualize, track, and optimize their processes for compliance.

1. LeanIX Enterprise Architecture allows enterprise architects to map IT systems, visualize dependencies, and identify high-risk areas. For example, it enables architects to identify legacy systems that pose vulnerabilities and prioritize their replacement or upgrade, ensuring alignment with DORA’s ICT risk management requirements.
2. SAP Signavio supports process mining and workflow optimization, helping organizations identify inefficiencies in incident reporting or resilience strategies. For instance, it can highlight bottlenecks in reporting workflows, enabling compliance officers to redesign them for faster regulatory submissions.
3. Vendor Management Systems provide continuous oversight of third-party performance and SLA compliance. These systems allow risk managers to receive real-time alerts when a vendor falls below contractual obligations, enabling timely remediation and ensuring alignment with third-party risk management requirements.
4. Resilience Testing Platforms enable organizations to simulate disruptions, such as cyberattacks or system outages, and evaluate the effectiveness of their recovery strategies. These tools help IT teams validate disaster recovery plans and identify weaknesses before they impact operations.
5. Governance Dashboards provide real-time compliance metrics and automated audit trails, giving leadership a clear view of progress toward DORA compliance. These dashboards are instrumental for cross-departmental reviews and regulatory audits, simplifying the process of demonstrating compliance.

Maturity assessments provide organizations with a structured approach to evaluating their capabilities, identifying gaps, and prioritizing improvements in key operational and compliance areas.

Whether assessing readiness for regulatory requirements, such as DORA, or improving ICT risk management, these assessments are tailored to reflect the unique structure, goals, and challenges of each organization.