What is DORA and How Does it Differ from Existing Risk Management Frameworks?
Well, DORA goes beyond traditional compliance frameworks by requiring organisations to embed ICT risk management into the core of their financial operations. Few frameworks focus on the importance of “integration” and this makes all the difference.
What do you need to integrate?
Easy, as the three European Supervisory Authorities (ESAs) developed specific Regulatory Technical Standards (RTS) to clarify expectations. Understanding these standards is essential — not just for ticking regulatory boxes but for building a resilient organisation that can thrive in an increasingly volatile environment. This article covers the RTS requirements, offering insights into how financial entities can navigate them efficiently and stay ahead of evolving risks.
DORA RTS Requirements
The RTS addresses operational resilience, ICT risk management and incident reporting functions:
ICT Risk Management
The foundation of this framework influences how incidents are classified and how ICT third-party contracts are evaluated. Planning should consider the development of technical standards, enabling firms to align their strategies with available resources while recognising dependencies across various compliance areas.
Firms must prioritise wisely, tackling time-intensive tasks early, especially in third-party risk management. Compliance levels vary across firms, influencing resource allocation and prioritisation. The 2024 timelines for requirements vary – you should have a clear distinction between immediate and January 2025 obligations.
Firms should integrate existing capabilities to avoid duplication, promote constructive collaboration in implementing the DORA framework and ensure efficient internal coordination across all related functions.
Requirements:
- Establish processes for risk identification, mitigation, and monitoring
- Ensure the ICT risk framework aligns with your business strategy
- Conduct regular audits to ensure ongoing effectiveness
Incident Reporting Frameworks
The second part of the framework deals with incident management and reporting, which is likely less challenging initially but necessitates new tools, staffing, and processes.
Requirements:
- Implement procedures to detect and report significant incidents
- Ensure incident reports are shared with both internal teams and regulators
- Establish protocols for communicating incidents to customers and stakeholders, when necessary
Below are the final Regulatory Technical Standards (RTS), outlining the deadlines for financial entities to classify incidents and submit notifications and reports to their national supervisory authority.
| Report | Timeframe | Requirement |
| Initial Report | – Incident Classification: ASAP after detection – Submission: Within 4 hours of classification as “major” | Classify the incident as “major” if it significantly impacts critical functions. Submit a report with general incident details to the national supervisory authority. |
| Intermediate Report | Within 72 hours of the initial report | Submit a notification detailing the incident cause, classification, and actual or estimated economic impact. |
| Final Report | Within 1 month of the intermediate notification | Provide a final notification with a root cause analysis, lessons learned, and any other relevant information. |
Vulnerability and Penetration Testing
The regulation mandates continuous security testing of ICT systems to evaluate their capacity to withstand operational stress and recover from disruptions. The RTS will outline guidelines for performing advanced penetration tests, requiring simulations of real-world scenarios to confirm the resilience of these systems.
Requirements:
- Conduct regular vulnerability assessments and penetration testing
- Simulate real-world scenarios to test incident response capabilities (Red Team Testing along with physical penetration testing)
- Document the results of all tests and implement improvements accordingly
Third-Party Risk Management
This requirement highlights the importance of thoroughly managing risks originating from external providers. Firms must ensure ICT service providers comply with DORA’s standards, including service-level agreements (SLAs) and risk monitoring mechanisms.
Requirements:
- Identify critical third-party providers and assess their resilience practices
- Ensure that contracts with providers include resilience obligations
- Monitor providers regularly to ensure compliance
Resilience Governance and Audits
This standard focuses on governance — establishing accountability and ensuring that senior leadership is actively involved in ICT risk management and resilience efforts. RTS will also require annual reviews and audits to ensure systems remain up to standard
Requirements:
- Involve executive leadership in compliance activities
- Appoint a designated owner to oversee compliance efforts
- Conduct stakeholder workshops to align business units with regulatory expectations
Conclusion: Preparing for DORA Compliance
Meeting DORA’s Regulatory Technical Standards is crucial for financial institutions aiming to build lasting operational resilience. These standards integrate ICT risk management, incident reporting, vulnerability testing and third-party oversight into core business practices.
Success requires developing a structured roadmap, leveraging existing compliance frameworks, and coordinating internal resources effectively. Firms that act early will not only meet regulatory deadlines, but will also gain a competitive edge by enhancing operational stability and strengthening partnerships.
Need Help Getting Started on Your Roadmap?
Risk Crew’s expert consultants are here to guide you. With the right strategy, you can turn compliance into an opportunity to strengthen your resilience and stay ahead of regulatory demands. Let us help. It’s what we do. Explore our DORA Compliance service today.