Financial organizations must create a complete DORA compliance checklist. Recent data shows 74% of respondents consider cyberattacks the highest risk to the financial sector. The situation becomes more concerning as a 2022 survey of 130 global financial institutions revealed 74% faced at least one ransomware attack last year.
DORA (Digital Operational Resilience Act) came into force on January 16, 2023. Organizations need to achieve full compliance by January 17, 2025. The regulation provides a complete framework that strengthens cybersecurity, standardizes compliance and improves incident response. DORA encourages collaboration and tightens third-party risk management. The regulation’s scope extends to banks, insurance companies, investment firms, payment service providers, electronic money institutions, crypto-asset service providers, and financial market infrastructures.
This piece outlines a step-by-step DORA compliance process with practical approaches to meet requirements. Our CTO2B.io DevOps outsourcing services help maintain DORA-compliant infrastructure while implementing reliable security measures. The regulation requires regular testing of operational resilience, which we manage through proper planning and execution.
Key Takeaways
DORA compliance is critical for financial organizations, with the January 17, 2025 deadline fast approaching and 74% of financial institutions identifying cyberattacks as their highest risk.
• Start your DORA gap analysis immediately – 94% of financial institutions have already begun assessing their compliance readiness against the regulation’s requirements.
• Implement the 8-step compliance checklist systematically – From determining applicability to establishing governance structures, each step builds toward comprehensive digital resilience.
• Establish robust incident reporting within strict timelines – Initial notification must occur within 4 hours of classification, with intermediate reports due within 72 hours.
• Conduct mandatory resilience testing every three years – Threat-Led Penetration Testing (TLPT) following the TIBER-EU framework is required for all critical functions.
• Monitor third-party ICT providers continuously – Maintain detailed registers and ensure contractual arrangements meet DORA requirements for all critical service providers.
• Track key metrics for ongoing compliance – Elite performers restore services in under one hour, while continuous monitoring ensures sustained resilience beyond initial implementation.
DORA represents more than regulatory compliance—it’s an opportunity to strengthen your organization’s digital operational resilience. With proper planning, cross-functional collaboration, and the right technical infrastructure, financial entities can transform this regulatory requirement into a competitive advantage while protecting against the growing threat of cyberattacks.
What is DORA Regulation and Why It Matters
The Digital Operational Resilience Act marks a major change in EU financial regulation. It came into force on January 16, 2023, and organizations must fully implement it by January 17, 2025 [1]. Earlier regulations we focused on financial stability through capital allocation. DORA takes a different approach by tackling the growing digital vulnerabilities in the financial ecosystem [2].
DORA vs Other EU Regulations (e.g., GDPR)
DORA and GDPR work together but serve different purposes in the EU regulatory framework. GDPR protects data privacy for all organizations that process EU citizens’ data. DORA focuses on making the financial sector more resilient [1]. The regulation moves away from GDPR’s principle-based approach and provides detailed requirements to boost operational and security capabilities [1]. DORA builds on the NIS2 directive to create a specialized framework for financial entities [1].
Key Objectives: Cyber Resilience and Standardization
DORA’s main goal establishes strong digital resilience standards across the financial sector. The regulation lines up previously scattered approaches to operational resilience [1]. This ensures financial institutions can handle, respond to, and bounce back from ICT-related incidents [2]. DORA also introduces standard frameworks for ICT risk management, incident reporting, operational resilience testing, and third-party risk oversight [3].
Who Must Comply: Financial Entities and ICT Providers
The regulation’s scope covers 20 different types of financial entities operating in the EU [4]. Banks, insurance companies, investment firms, payment processors, crypto-asset service providers, credit institutions, and financial market infrastructures must comply [1]. DORA’s reach extends beyond financial institutions to include ICT third-party service providers. Cloud computing services, data centers, and software vendors supporting financial operations fall under its rules [5].
CTO2B.io helps organizations build DORA-compliant infrastructure through specialized DevOps outsourcing services that meet all requirements. Our core team implements resilient ICT risk management frameworks, incident reporting systems, and testing procedures—exactly what financial entities need to comply with DORA fully.
Step-by-Step DORA Compliance Checklist
Image Source: Cymulate
The financial entities must prepare for the January 17, 2025 deadline. This well-laid-out checklist provides guidance through each step to achieve DORA compliance.
1. Determine if DORA Applies to Your Organization
Your organization needs to verify its status under DORA’s scope. Article 2 lists 20 different types of financial entities. Banks, insurance companies, investment firms, payment institutions, crypto-asset service providers, and financial market infrastructures operating within the EU fall under these regulations.
2. Conduct a DORA Gap Analysis
Your current digital resilience needs assessment against DORA requirements before making changes. This structured assessment helps you spot compliance gaps and create action plans. 94% of financial institutions already participate in understanding DORA requirements and perform gap analyzes.
3. Build an ICT Risk Management Framework
Your organization needs strategies, policies, procedures, and tools to protect information assets through a resilient ICT risk management framework. This framework should map all ICT-supported business functions and identify sources of ICT risks, including cybersecurity threats and vulnerabilities.
4. Set Up ICT Incident Reporting Procedures
Clear protocols help report major ICT-related incidents within specific timelines. You must send the original notification within 4 hours after classification (24 hours after detection). The intermediate report should reach within 72 hours, and the final report within one month. These protocols need standardized templates and procedures specified in the Implementing Technical Standards.
5. Plan and Execute Resilience Testing (TLPT)
Your detailed digital operational resilience testing should include Threat-Led Penetration Testing (TLPT) every three years. TLPT must follow the TIBER-EU framework and focus on your organization’s critical or important functions.
6. Review and Monitor Third-Party ICT Providers
Your organization needs a detailed register of all contractual arrangements with ICT third-party service providers. This register should distinguish providers supporting critical functions from others. The contractual provisions must meet DORA requirements, especially when providers support critical or important functions.
7. Establish Information Sharing Mechanisms
Trusted communities help exchange cyberthreat information and intelligence. These arrangements need clear governance rules that protect business confidentiality and data protection. Your competent authorities should know about your participation in these arrangements.
8. Define Governance and Accountability Structures
Your management body should approve the ICT risk management framework and related policies. Clear roles and responsibilities for ICT risk management ensure appropriate independence of control functions and avoid conflicts of interest.
CTO2B.io‘s DevOps outsourcing services help implement DORA-compliant infrastructure. These services address everything from establishing ICT frameworks to resilience testing procedures.
How to Implement Your DORA Compliance Plan
DORA implementation needs cross-functional collaboration and a step-by-step approach. Board members and management must take direct responsibility since DORA holds executives accountable [6].
Assign Roles and Responsibilities Across Teams
DORA requires “clear roles and responsibilities for all ICT-related functions” [6]. A senior executive should take charge to meet regulatory requirements. Board members must set up and monitor the ICT risk management framework and work closely with the CIO to create risk management processes [7]. ICT managers should get specific tasks with clear reporting systems to speed up decision-making.
Create a Timeline for Compliance Milestones
Companies should create a realistic implementation schedule before January 17, 2025. A typical DORA roadmap takes 12+ months. Assessment takes 1-3 months, training needs 4-6 months, pilot implementation runs 7-9 months, and company-wide rollout spans 10-12 months [4]. Companies can start with simple tasks like preparing board minutes and updating incident response plans [8].
Integrate DORA into Existing Risk Frameworks
DORA adds to frameworks like ISO 27001 instead of replacing them [4]. Companies should compare their security frameworks with DORA requirements to avoid doing work twice. The focus should be on better immediate monitoring, quick incident reporting, and constant vendor security checks.
Use CTO2B.io DevOps Services for DORA-Aligned Infrastructure
CTO2B.io makes DORA compliance easier with automated disaster recovery tools and backup systems across regions [2]. Their DevOPS automation gives complete tracking and audit capabilities for system changes [9]. This helps meet DORA’s documentation needs.
Monitoring, Metrics, and Continuous Improvement
DORA compliance needs continuous monitoring and adaptation to emerging ICT risks. Setting up the right metrics creates a strong foundation for maintaining compliance beyond the original implementation.
Track Incident Response Time and System Downtime
DORA compliance relies heavily on incident response metrics. Elite performers can restore service in less than one hour [10], while low performers might take up to six months [11]. Your system’s resilience against deployment failures becomes clear when you track Failed Deployment Recovery Time (FDRT) [11]. MTTR measurement should be part of your monitoring framework to spot potential vulnerabilities early.
Review Third-Party Performance Metrics
Your DORA compliance checklist must include third-party monitoring. Financial entities need to review their ICT service providers’ performance against agreed service levels [12]. Set up metrics to systematically assess third-party performance through contracts that require regular reports.
Use Testing Results to Improve Resilience
Critical ICT systems need testing at least once a year [3]. Teams should have procedures to prioritize, classify and fix identified issues after completing tests [3]. CTO2B.io’s DevOps services excel at implementing automated testing frameworks that generate useful metrics and improve your resilience posture through evidence-based decisions.
Update Documentation and Training Regularly
DORA compliance requires constant monitoring and adaptation [1]. A continuous monitoring system helps track compliance status, incidents, and recovery efforts [1]. CTO2B.io makes this easier with customized dashboards that show key performance indicators and help keep documentation current as systems change.
Conclusion
DORA compliance marks a radical alteration in how financial organizations need to handle digital operational resilience. A significant deadline looms on January 17, 2025, when full implementation becomes mandatory. Your compliance trip should start today to avoid last-minute rushes and potential regulatory fines.
This piece breaks down DORA requirements into simple steps with a detailed checklist. Financial entities can tackle all five pillars: ICT risk management, incident reporting, resilience testing, third-party risk management, and information sharing. Clear accountability at the executive level must back these technical measures through proper governance structures.
The implementation needs teamwork across departments and careful planning. A well-developed timeline and integration with current frameworks will help your organization achieve compliance with minimal disruption to daily operations.
CTO2B.io’s DevOps outsourcing services tackle these DORA requirements with purpose-built infrastructure solutions. Our teams set up automated disaster recovery, cross-region redundancy, and continuous monitoring systems that match DORA’s resilience needs perfectly. Our DevOps services come with DORA compliance built into their core, giving financial organizations both technical solutions and compliance expertise.
DORA compliance needs constant watchfulness after the original setup. Tracking response times, evaluating vendor performance, and improving based on test results become vital to retain compliance. CTO2B.io helps this improvement cycle with custom monitoring dashboards and automated testing frameworks.
Financial organizations that see DORA compliance as a chance to grow will without doubt boost their overall resilience. The January 2025 deadline might seem far away, but starting now allows for systematic implementation and thorough testing. CTO2B.io will support your organization through this vital transformation. Your digital infrastructure will stay resilient and compliant with all DORA requirements.
FAQs
What are the key components of DORA compliance?
DORA compliance is built on five pillars: ICT risk management, incident reporting, digital operational resilience testing, third-party risk management, and information sharing. These components form the foundation for enhancing cybersecurity and operational resilience in financial institutions.
When is the deadline for DORA compliance?
Financial entities must achieve full DORA compliance by January 17, 2025. The regulation officially came into force on January 16, 2023, giving organizations a two-year window to implement necessary changes and meet all requirements.
How often should digital operational resilience testing be conducted under DORA?
DORA mandates that comprehensive digital operational resilience testing, particularly Threat-Led Penetration Testing (TLPT), must be conducted at least once every three years. This testing should target critical or important functions of the organization and follow the TIBER-EU framework.
What are the incident reporting timelines under DORA?
DORA requires strict incident reporting timelines. Financial entities must provide an initial notification within 4 hours after classifying an incident (or 24 hours after detection), followed by an intermediate report within 72 hours, and a final report within one month of the incident.
How can organizations ensure continuous DORA compliance?
Continuous DORA compliance involves ongoing monitoring, regular updates to documentation and training, and continuous improvement based on testing results. Organizations should track key metrics like incident response time and system downtime, evaluate third-party performance, and use a continuous monitoring system to track compliance status and adapt to emerging ICT risks.
References
[1] – https://www.skillcast.com/blog/dora-compliance-staff-training
[2] – https://cto2b.io/
[3] – https://www.dora-info.eu/dora/article-24/
[4] – https://www.cerrix.com/en/insights/blog/implementing-dora-from-compliance-to-long-term-resilience
[5] – https://www.cm-alliance.com/cybersecurity-blog/eu-dora-requirements-for-ict-service-providers-all-you-need-to-know
[6] – https://www.itgovernance.eu/blog/en/dora-roles-responsibilities-and-competences
[7] – https://www.houseofcontrol.com/blog/what-dora-requires-from-5-different-stakeholders
[8] – https://www.skadden.com/insights/publications/2025/01/countdown-to-dora-four-takeaway-points
[9] – https://dora.dev/capabilities/flexible-infrastructure/
[10] – https://newrelic.com/blog/best-practices/dora-metrics
[11] – https://www.cortex.io/post/understanding-dora-metrics
[12] – https://www.bitsight.com/learn/dora-compliance-checklist
