Digital Operational Resilience Act (DORA) Requirements and Aspects

Executive Overview

Operational Resilience in the financial sector due to increasing cyber threats, technological disruptions and regulatory scrutiny has gained importance over time. The Digital Operational Resilience Act (DORA) was introduced by the European Union in 2020 as part of Digital Finance Package to improve the financial sector’s ability to withstand ICT (Information and Communication Technology) related risks. The regulation establishes a unified regulatory framework for financial institutions, ICT service providers, critical third parties ensuring they can manage, respond to, and recover from cyber incidents efficiently. The regulation entered into force on 17^th January 2023, requiring the enterprises to enhance their risk management, incident reporting, and test frameworks. The aim of this regulation is to create and implement the harmonized approach to digital resilience, reduce the fragmentation across European Union member states and improve financial stability.

Brickendon provides specialist DORA consulting services to help financial institutions design and implement sustainable operational resilience frameworks supported by trusted data architecture and governance. With extensive experience delivering large-scale data, risk, and regulatory transformation programmes across global banking organisations, our consultants support institutions in navigating complex regulatory change while strengthening enterprise resilience. Below we describe the main aspects of DORA operational resilience regulation.

1. ICT Risk Management Framework 

The main requirement is that financial entities must establish and maintain a robust ICT risk management framework as part of their overall risk management system. Key elements of this framework are:

• Identify, classify, and document ICT risks.
• Implement policies, procedures, and tools to mitigate ICT risks.
• Regularly update the framework to address emerging threats.
• Assign clear roles and responsibilities for ICT risk management.
• Integrate ICT risk management into the entity’s overall governance structure.

2. Incident Detection & Reporting

Incident reporting is about the obligation of the financial entities to have the mechanisms in place detecting, managing and reporting ICT-related incidents. Key elements:

• Establish incident classification criteria based on impact and severity.
• Report major ICT-related incidents to relevant authorities within strict timelines (e.g., initial report within 4 hours of classification).
• Maintain detailed records of incidents, including root cause analysis and remediation actions.
• Share incident reports with other financial entities and authorities to improve collective resilience.

3. Digital Operational Resilience Testing

The financial institution’s obligation is to conduct regular testing of its ICT systems and processes to ensure resilience. Key aspects of this are the following:

• Perform vulnerability assessments, scenario-based testing, and penetration testing.
• Conduct advanced threat-led penetration testing (TLPT) at least every three years for critical entities.
• Document test results and implement corrective actions to address identified weaknesses.
• Ensure testing covers all critical systems, third-party dependencies, and potential attack vectors.licated effort, accelerates remediation cycles, and improves regulatory confidence.

4. Third Party Risk Management

Third party Risk management is pointing out the requirement for financial entities must manage risks arising from dependencies on third-party ICT service providers. The key aspects of the Third-Party Risk management are as follows:

• Conduct due diligence before engaging third-party providers.
• Include specific contractual terms to ensure compliance with DORA requirements.
• Monitor and assess the performance and resilience of third-party providers.
• Develop exit strategies to ensure business continuity in case of third-party failure.
• Maintain a register of all third-party providers and their criticality to operations.

5. Information Sharing & Collaboration

Is the requirement for the Financial Entities to share cyber threat information and intelligence with peers and authorities. Key aspects of this point are the following:

6. Governance and Accountability

The financial entities must ensure strong governance and accountability for operational resilience. Key Elements include:

• Assign responsibility for ICT risk management to the board of directors or senior management.
• Regularly review and approve ICT risk management policies and strategies.
• Ensure adequate resources and expertise are allocated to operational resilience.
• Conduct periodic audits and independent reviews of ICT risk management practices.

7. Business continuity and disaster recovery

With this requirement the financial entities must have business continuity and disaster recovery plans in place to ensure continuity of critical functions. The following elements are included in this point:

• Develop and maintain Business Continuity Plans (BCPs) and Disaster Recovery Plans (DRPs).
• Regularly test and update BCPs and DRPs to reflect changes in the operating environment.
• Ensure backup systems and data are available and can be restored within defined recovery time objectives (RTOs).
• Establish alternative work arrangements and communication channels for crisis situations.

8. Training and Awareness

Is one of the key requirements to fulfill so the regulation is properly implemented in the organization.  Financial entities must provide regular training and awareness programs to staff on ICT risks and operational resilience. Key elements included in this are as follows: 

• Train employees on identifying and responding to ICT-related threats.
• Conduct simulated cyber-attack exercises to improve preparedness.
• Ensure senior management and board members are aware of their roles in operational resilience.
• Promote a culture of resilience across the organization.

9. Regulatory oversight and Compliance

Financial entities must comply with DORA requirements and cooperate with regulatory authorities. Key aspects within this requirement are:

• Submit regular reports and documentation to demonstrate compliance.
• Cooperate with regulatory inspections and audits.
• Address any deficiencies or recommendations identified by regulators.
• Ensure compliance with other relevant regulations. There are several regulations which DORA must also comply with. The most relevant ones are listed below:

Regulation	Description
GDPR (General Data Protection Regulation)	Ensure financial institutions protect personal data and handle breaches properly, which overlaps with DORA’s ICT risk management and incident reporting requirements.
NIS2 (Network and Information Security Directive 2)	Establishes stricter cybersecurity standards for critical infrastructure, complementing DORA’s focus on digital resilience and third-party risk management.
PSD2 & PSD3 (Payment Services Directive 2 & 3)	Regulates digital payments and cybersecurity measures for financial services, ensuring alignment with DORA’s ICT security requirements.
Solvency II & Solvency II Review	Governs the risk and capital requirements of insurance companies, integrating operational risk considerations that overlap with DORA’s resilience requirements.
Basel III / CRD VI (Capital Requirements Directive VI)	Provides financial risk management guidelines, requiring banks to integrate operational resilience into their risk frameworks, aligning with DORA’s principles.
EBA, EIOPA, and ESMA Guidelines	The European Supervisory Authorities (ESAs) issue technical standards and guidelines, ensuring financial entities align their ICT risk management and outsourcing practices with DORA’s framework.

10. Critical Third-Party Providers Oversight

DORA introduces a supervisory framework for critical third-party ICT service providers with the following key elements:

• Critical providers will be subject to direct oversight by EU authorities.
• Providers must comply with DORA’s resilience requirements and undergo regular assessments.
• Financial entities must ensure their critical providers are compliant with DORA.

DORA’s operational resilience requirements are comprehensive and aim to ensure that financial entities can maintain continuity of services in the face of ICT-related disruptions. By focusing on risk management, incident reporting, testing, third-party oversight, and governance, DORA enhances the resilience of the financial sector. Financial entities must adopt a proactive and holistic approach to meet these requirements and ensure compliance.

About Brickendon

Brickendon is a specialist consulting firm supporting financial institutions in navigating complex regulatory, operational, and data transformation challenges. With deep expertise across banking technology, risk, and regulatory frameworks, Brickendon helps organisations strengthen operational resilience and meet evolving supervisory expectations.

In the context of regulations such as the EU’s Digital Operational Resilience Act (DORA), Brickendon supports banks and financial services firms in designing and implementing robust ICT risk management frameworks, improving incident response capabilities, and establishing effective governance structures. Our consultants work closely with clients to build sustainable resilience programmes that integrate risk management, technology controls, and regulatory compliance.

Brickendon combines strong domain knowledge in banking operations with practical delivery experience across large-scale transformation programmes. We support organisations throughout the full lifecycle of change initiatives—from regulatory gap assessments and target operating model design to implementation, testing, and ongoing governance.

Trusted by leading financial institutions, Brickendon helps organisations move beyond reactive compliance towards a proactive, enterprise-wide approach to operational resilience—ensuring systems, processes, and third-party ecosystems remain secure, reliable, and resilient in an increasingly digital financial landscape.

Speak to Banking Data & Operational Resilience Experts

The Digital Operational Resilience Act (DORA) introduces a comprehensive regulatory framework designed to strengthen ICT risk management, operational resilience, and third-party oversight across financial institutions. For banks, asset managers, and financial market infrastructure providers, achieving DORA compliance requires robust governance, transparent data frameworks, and strong operational controls across technology and business functions.

Brickendon provides specialist DORA consulting services to help financial institutions design and implement sustainable operational resilience frameworks supported by trusted data architecture and governance. With extensive experience delivering large-scale data, risk, and regulatory transformation programmes across global banking organisations, our consultants support institutions in navigating complex regulatory change while strengthening enterprise resilience.

To learn how Brickendon can support your organisation’s DORA compliance and operational resilience transformation, please contact our specialists: [email protected]

Alternatively you can complete this contact form and we will be in touch: https://www.brickendon.com/contact-us/

Sources:

https://eur-lex.europa.eu/eli/reg/2022/2554/oj/eng

https://www.eiopa.europa.eu/digital-operational-resilience-act-dora_en#:~:text=The%20Digital%20Operational%20Resilience%20Act,as%20of%2017%20January%202025