Navigating DORA: Essential Insights for Financial and Payment Institutions

The European Union’s Digital Operational Resilience Act (DORA) is a landmark regulatory initiative aimed at enhancing the digital operational resilience of entities within financial sector or those relating to it. DORA focuses on strengthening the digital operational resilience of these entities through robust ICT risk management, comprehensive testing, incident reporting, third-party risk management, and proactive information sharing.

This blog is a broad overview into the key aspects of DORA, highlighting its significance and offering practical steps for organisations to align with its stringent requirements and bolster their operational resilience.

Understanding DORA.

The Digital Operational Resilience Act, known as DORA, is an EU regulatory framework designed to ensure that financial institutions and related entities can effectively manage and recover from ICT-related incidents. Although the UK has left the EU, DORA remains crucial for UK-based firms engaged in cross-border financial activities or providing payment services to EU customers.

Who is impacted by DORA?

Below is a concise overview of the types of organisations impacted by DORA and their relationship with this regulatory framework.

Financial Institutions.

Banks play a central role in the financial system, handling extensive transactions and sensitive data. DORA ensures banks implement robust ICT risk management and regular system testing to maintain operational stability and protect public confidence.

Investment firms manage client funds and investments, making their digital systems critical for market operations. Under DORA, they must enhance cyber resilience, conduct regular stress testing, and effectively manage third-party risks.

Insurance companies and reinsurance companies rely heavily on digital platforms for their services. DORA requires these companies to adopt comprehensive ICT risk management practices to protect their operations and customer interactions.

Credit institutions, which provide various credit services, are crucial to the economy. DORA mandates these institutions maintain resilient ICT systems to safeguard the integrity of the credit market and their customer data.

Financial market infrastructures, such as exchanges and clearing houses, facilitate financial transactions. Their inclusion under DORA ensures they maintain operational continuity and manage systemic risks effectively.

Payment Service Providers.

Payment institutions and e-money institutions are essential for secure and efficient electronic payments. DORA mandates that these providers maintain resilient ICT systems to handle cyber threats and operational disruptions effectively.

Payment processors and digital wallet providers facilitate secure transaction processing and digital asset management. DORA requires them to conduct rigorous testing and manage ICT risks, ensuring continuous and secure operations.

Retailers and E-Commerce Platforms.

While online retailers and e-commerce platforms heavily depend on secure transactions, DORA primarily targets entities within the financial sector. These retailers might be indirectly impacted if they provide financial-like services or if their operations are tightly integrated with financial systems, but they are not the primary focus of DORA.

Point of Sale (POS) systems providers are vital for processing payments in retail. Under DORA, they must ensure their systems are resilient and capable of handling disruptions, safeguarding the transaction process.

Infrastructure Providers.

Telecommunications providers and data centres support critical functions for financial operations and can be considered relevant under DORA when they provide services to financial entities. Their direct regulation under DORA would typically be through their role as third-party service providers to financial institutions.

Data centres offer crucial data storage and processing services. DORA includes these facilities to ensure they maintain high standards of security and resilience, protecting the data and operations they support.

Financial Market Participants.

Securities trading venues and asset management companies are integral to market operations. DORA requires these entities to implement strong ICT risk management and resilience practices to ensure market stability and protect client investments.

Financial advisors handle sensitive client information and facilitate financial transactions. DORA mandates they maintain secure and resilient ICT systems to continue providing services without disruption.

Financial Intermediaries.

Broker-dealers, custodians, and transfer agents are crucial for securities transactions and asset management. DORA requires these intermediaries to ensure their systems support uninterrupted trading and comply with resilience standards.

Regulatory and Supervisory Bodies.

Financial supervisory authorities oversee market compliance and respond to ICT incidents. DORA includes these authorities to coordinate resilience practices and incident responses across the sector.

Central banks provide financial stability oversight and manage national monetary policies. Their inclusion in DORA ensures they maintain high operational resilience and ICT security standards, supporting the broader financial system’s stability.

These entities are integral to the financial and payment ecosystem and are included under DORA to ensure their ICT systems are resilient and capable of managing disruptions, thereby enhancing the overall security and stability of the sector

Key Components of DORA.

ICT Risk Management.

Under DORA, organisations must develop and maintain comprehensive ICT risk management frameworks. These frameworks should include detailed policies and procedures designed to identify, assess, and mitigate ICT risks continuously. This ensures that potential threats are monitored and managed proactively, rather than reactively addressing issues as they arise.

Operational Resilience Testing.

Regular and rigorous testing of ICT systems is a cornerstone of DORA. Entities are required to conduct thorough assessments and tests, including advanced methods like threat-led penetration testing (TLPT). This rigorous testing ensures that systems can withstand and quickly recover from disruptions, simulating real-world attack scenarios to validate the effectiveness of their security measures.

Incident Reporting.

DORA mandates that significant ICT-related incidents must be promptly reported to national competent authorities. This facilitates a timely and coordinated response to mitigate the impact of disruptions. Having clear and effective reporting protocols helps organisations to manage and contain incidents swiftly, reducing the potential for prolonged operational downtime or data breaches.

Third-Party Risk Management.

Given the increasing reliance on external ICT providers, DORA emphasises the importance of managing third-party risks. Organisations must conduct thorough due diligence to assess the resilience capabilities of their third-party providers. Continuous monitoring and management of these relationships are crucial to ensure that external dependencies do not compromise the organisation’s operational resilience.

Information Sharing.

DORA encourages the sharing of cyber threat intelligence among entities to foster a collaborative approach to cyber security. By sharing information about emerging threats and vulnerabilities, organisations can collectively enhance their security posture and improve their incident response capabilities. This collaborative effort is vital in combating sophisticated cyber threats that can affect multiple entities within the financial ecosystem.

Steps to Achieve DORA Compliance.

Assess Current Capabilities.

The first step towards DORA compliance involves conducting a thorough assessment of your current ICT risk management and operational resilience capabilities. This assessment should identify any gaps and vulnerabilities compared to DORA’s requirements, providing a clear understanding of the areas that need enhancement.

Develop a Compliance Plan.

Once the assessment is complete, organisations should develop a detailed compliance plan. This plan should set out clear objectives and timelines for achieving DORA compliance. It should also assign specific roles and responsibilities to ensure that all aspects of the compliance process are effectively managed and implemented.

Engage Stakeholders.

Achieving DORA compliance requires the active involvement of all relevant stakeholders. This includes senior management, IT teams, and third-party providers. Ensuring that everyone understands DORA’s requirements and their role in the compliance process is crucial. Regular communication and training can help keep stakeholders informed and engaged throughout the implementation process.

Invest in Training, Tools and Resources.

Organisations must invest in the necessary training, tools and resources to meet DORA’s stringent requirements. This involves equipping IT and security teams with the expertise needed to implement robust ICT risk management practices and advanced testing regimes. Additionally, investing in tools and technologies for continuous monitoring and improvement of ICT systems is essential for maintaining compliance.

Continuous Review and Improvement.

DORA compliance is not a one-time effort but an ongoing process. Regular reviews and updates of your policies, procedures, and systems are necessary to ensure they remain aligned with DORA’s standards and evolving best practices. Conducting periodic audits and staying informed about regulatory changes will help maintain and improve your organisation’s compliance status.

Benefits of DORA Compliance.

Complying with DORA brings numerous benefits beyond mere regulatory adherence. It enhances your organisation’s operational resilience, reducing the risk of disruptions and improving your ability to recover from incidents. Compliance with DORA also boosts customer trust and confidence by demonstrating a commitment to high standards of security and resilience. Furthermore, aligning with DORA’s requirements can provide a competitive advantage, positioning your organisation as a leader in operational robustness and risk management.


DORA is a transformative regulatory framework that is critical for financial institutions, payment service providers, and retailers. By understanding and implementing DORA’s requirements, organisations can significantly enhance their digital operational resilience, ensuring they are well-prepared to handle ICT-related incidents and threats.

For expert guidance on achieving DORA compliance and strengthening your organisation’s operational resilience, contact Secon . Our team of specialists is ready to provide tailored cyber security solutions to meet your needs. Reach out to our team to explore how we can help you navigate the complexities of DORA.