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Jan 0001 by
In a financial world increasingly dependent on digital infrastructure, resilience is no longer optional. It’s a regulatory expectation. The Digital Operational Resilience Act (DORA), now in force across the EU, represents a major shift in how financial institutions must approach their digital risk - not as an IT concern, but as an organization-wide responsibility.
For many leaders, the regulation can seem complex or abstract at first glance. But DORA offers a helpful structure by defining five distinct areas - or pillars - that together form the foundation of a compliant and resilient organization.
Understanding and aligning with these five pillars is critical not only for meeting compliance requirements but also for building long-term digital strength in a rapidly evolving threat landscape.
The Digital Operational Resilience Act (DORA) is a regulation introduced by the European Union to ensure that financial entities can maintain stable and secure operations in the face of digital disruptions. Officially adopted as part of the EU’s Digital Finance Package, DORA came into effect in January 2025 and applies uniformly across all EU member states.
At its core, DORA recognizes that digital systems are now essential to the functioning of the financial sector. Cyberattacks, system failures, third-party breaches, and data loss are no longer isolated IT incidents. They pose direct threats to the integrity, stability, and trustworthiness of financial markets.
Unlike previous frameworks, which left much of the implementation to national authorities or sector-specific interpretations, DORA establishes a centralized, legally binding set of rules for managing ICT (Information and Communication Technology) risks. It defines what institutions must do to prevent, respond to, and recover from ICT-related incidents. And it requires demonstrable, ongoing compliance - not just policies on paper.
DORA applies broadly across the financial sector. This includes banks, insurance and reinsurance companies, investment firms, credit rating agencies, payment service providers, pension funds, and crypto-asset service providers. Importantly, it also extends to third-party ICT service providers who deliver critical digital functions to these organizations. In doing so, the regulation acknowledges that operational resilience must include the entire digital supply chain.
Instead of a vague checklist of technical controls, DORA presents a clear, structured approach to operational resilience. The five pillars outlined in the regulation don’t exist in isolation. They are designed to reinforce one another and build a system where financial institutions can continue operating even under digital stress, disruption, or attack.
For many organizations, thinking in terms of these pillars offers clarity. Each one targets a specific type of risk - and together, they form a continuous cycle of preparation, prevention, detection, response, and improvement.
Let’s explore each pillar in depth.
Every financial institution - from global banks to fintech startups - relies on a growing ecosystem of digital systems. These systems also bring risk. That’s why ICT (information and communication technology) risk management sits at the heart of DORA.
The regulation requires institutions to identify, assess, and manage ICT risks in a way that is embedded across the entire organization. This means more than having an IT team respond to incidents. It means ensuring that the board, risk managers, and compliance officers understand digital risks and how they affect business continuity.
To align with this pillar, your organization should start by mapping its digital assets. What systems do you use? Where are your dependencies? What happens if one of them fails?
From there, the next step is assigning responsibility. DORA emphasizes governance, which means senior leadership must be involved in approving and reviewing ICT risk strategies. The risk landscape must also be regularly reviewed, with updates based on changes to technology, operations, or threat intelligence.
DORA mandates that financial institutions report major ICT-related incidents to the relevant authorities within specific timeframes. These reports must be detailed, timely, and structured.
But meeting these obligations isn’t just about filling out forms after the fact. Effective incident reporting begins long before anything goes wrong. It starts with defining what counts as a reportable incident in your organization, and then creating clear internal processes to escalate, investigate, and document what happens.
To comply with this pillar, organizations must establish internal playbooks. These should outline roles and responsibilities during a digital incident, including who communicates with regulators, who coordinates IT remediation, and who documents the technical timeline. Importantly, these responsibilities should be rehearsed, not improvised during a crisis.
By building this internal capacity, organizations can avoid panic when disruption strikes and demonstrate professionalism and preparedness to regulators.
Good intentions aren’t enough when it comes to resilience. DORA requires financial institutions to regularly test their digital systems to ensure they can withstand real-world threats. This isn’t about checkbox exercises. It’s about uncovering weaknesses before adversaries do.
Testing activities may include vulnerability assessments, scenario-based stress testing, and - for more complex institutions - threat-led penetration testing (TLPT), where ethical hackers simulate advanced attacks in a controlled environment.
But before launching tests, organizations must define the scope. What systems are most critical? What failure scenarios are most damaging? Which controls should be tested?
Many institutions start with basic vulnerability scanning and gradually build toward more sophisticated simulations. The important part is to establish a regular cadence for testing and ensure that results are reviewed, acted upon, and logged.
Testing transforms resilience from a theory into a verified reality. And in the world of DORA, that verification is no longer optional.
In today’s outsourced world, few financial institutions operate their technology in isolation. Cloud providers, software platforms, managed service partners - all of these external players form part of your digital supply chain. DORA recognizes that the weakest link in that chain can compromise the entire system.
That’s why one of its core pillars is third-party risk management. The regulation requires institutions to assess, monitor, and control the ICT risks posed by external vendors throughout the full lifecycle of the relationship - from onboarding to termination.
To comply, your organization should maintain a comprehensive vendor inventory. You should know who provides what, what data they handle, what security measures they use, and what happens if their systems go down.
Contracts must be updated to include DORA-aligned clauses. These might include expectations for uptime, breach notification, testing cooperation, and audit rights.
This is not a one-time exercise. DORA requires continuous monitoring of third-party performance. You must also identify and classify “critical” ICT providers and apply stricter oversight accordingly.
No single organization can defend against every threat alone. DORA acknowledges this by encouraging, and in some cases requiring, financial entities to participate in threat intelligence sharing.
By exchanging timely, actionable information about cyber threats, financial institutions can detect attacks earlier, respond faster, and improve sector-wide awareness. This pillar of DORA promotes transparency, trust, and collaboration.
Organizations should start by identifying the right forums or information-sharing groups in their region or industry. Many national authorities and industry associations run secure platforms for this purpose. Once connected, companies must create internal processes to review shared intelligence, apply relevant insights, and circulate warnings to the right teams.
DORA compliance isn’t about chasing five separate goals. It’s about building a connected framework where each pillar supports the others. For example, good ICT risk management helps inform what systems need testing. Incident reporting procedures highlight gaps that testing can address. Vendor risk assessments ensure external partners meet the same standards your internal teams do.
Taken together, the five pillars create a cycle of resilience: a dynamic system that allows your organization to not only survive disruption but recover quickly and evolve.
Achieving this maturity doesn’t happen overnight. It requires leadership commitment, cross-functional cooperation, and practical training that speaks the language of both regulation and real-world operations.
With DORA now in effect, financial institutions must be prepared to show regulators how they meet each of the regulation’s requirements. This isn’t a “soft” framework, but rather it’s enforceable law. That means institutions that fail to demonstrate compliance risk regulatory sanctions, reputational damage, and even business continuity issues if critical weaknesses are exposed.
Beyond formal enforcement, the real cost of non-compliance often comes in the form of operational risk. A delayed incident response, poor vendor oversight, or an outdated risk register can quickly escalate into financial losses or customer fallout.
Furthermore, clients and partners - particularly in B2B and institutional contexts - are increasingly asking for proof of alignment with different security standards. Being unable to demonstrate readiness may affect competitiveness, procurement eligibility, and long-term trust.
Compliance is not just about avoiding fines. It’s about proving your organization is prepared, responsible, and ready for the digital demands of today’s financial system.
As regulators begin assessing DORA compliance in practice, institutions must be able to demonstrate that their systems are not only compliant but functional, tested, and sustainable. That takes planning, expertise, and a cross-functional commitment to resilience.
If your organization is ready to strengthen its DORA alignment or begin the journey in earnest, a focused and practical course can make all the difference.
The Readynez DORA Essentials course, led by regulatory expert Anette Pedersen, gives your team a one-day deep dive into the regulation and how to apply it. It’s not just theory. You’ll work through real exercises, evaluate your current state, and leave with tools you can use the next day.
The financial world is only getting more complex, but with the right structure, your resilience doesn’t have to be.