A few years ago, while working with a financial institution in Germany, I witnessed firsthand the aftermath of a third-party IT outage that crippled client-facing services for nearly two days. The disruption didn’t stem from negligence—in fact, the bank had several risk mitigation policies in place. But what was missing was a harmonized, enforceable framework that held all ICT providers, internal and external, to the same resilience standards. This is precisely the void the DORA EU regulation is now aiming to fill across the union.
Without further ado, let me highlight the key aspects of the DORA regulation, why it’s making waves across the continent, and why countries like Germany, France, Italy, and the UK are watching it closely.
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Setting the context: What DORA really aims to solve
The Digital Operational Resilience Act (DORA) is part of the broader Digital Finance Package introduced by the European Commission in 2020. Its core aim is simple but ambitious: ensure that all financial entities in the EU can withstand, respond to, and recover from ICT-related disruptions and threats. It applies not only to banks and insurers, but also to investment firms, crypto-asset service providers, and their critical third-party information and communication technology (ICT) partners.
This is particularly significant given the complex cross-border nature of the financial sector. Inconsistent national rules on digital resilience have long posed a risk. With the DORA legislation, the EU is now enforcing a unified framework to mitigate ICT risks.
PRO TIP
As early as possible, map your internal and external ICT assets and dependencies. This forms the foundation for all DORA-aligned resilience planning and will speed up later compliance assessments.
DORA across Europe: How countries are responding
Countries with advanced financial systems are embracing DORA in different ways, tailoring implementation to local needs while aligning with EU-wide requirements.
Germany: With a highly digitized financial sector and strong fintech presence, Germany has taken proactive steps. BaFin, the German financial regulator, is working closely with institutions to ensure early compliance. Many German banks are integrating DORA requirements into existing cyber and risk management protocols.
France: France’s ACPR (Prudential Supervision and Resolution Authority) has launched several consultations to support DORA alignment. French institutions are especially focused on enhancing their threat-led testing capabilities and formalizing third-party risk management structures.
Italy: Italy is leveraging DORA to accelerate IT modernization, particularly within public financial institutions. The country is also exploring AI-driven tools to perform continuous risk assessments, ensuring adaptability in a rapidly evolving digital environment.
United Kingdom: Although the UK is no longer an EU member, it has adopted a similar Operational Resilience Framework. The UK’s Financial Conduct Authority (FCA) and Prudential Regulation Authority (PRA) have issued guidelines that align closely with DORA’s principles, showing the regulation’s broader influence across Europe.
These national implementations reflect both the flexibility and the urgency of the EU DORA Act, with institutions racing to meet the January 2025 compliance deadline.
PRO TIP
Don’t wait for national regulators to finalize implementation guides. Align your readiness with the EU-level regulation directly, then adapt locally once country-specific nuances are introduced.
What is required: The DORA checklist
To understand the scope and impact of the DORA regulation, we need to look at the core compliance areas it mandates. The regulation outlines five key pillars that financial entities must adhere to:
| Compliance area | Description |
| ICT Risk Management | Establish governance and internal control systems to manage ICT risks across the entity. |
| Incident Reporting | Report major ICT-related incidents to regulators in a standardized, timely manner. |
| Digital Operational Resilience Testing | Regular scenario-based and threat-led testing of systems and controls. |
| Third-Party Risk Management | Contracts with ICT third parties must include resilience and security requirements. |
| Information Sharing | Encourage voluntary sharing of threat intelligence among financial entities. |
Each pillar underlines the comprehensive nature of DORA. It’s not just about protecting your own infrastructure but also about strengthening the ecosystem you’re part of.
PRO TIP
Draft an incident playbook template now—even before final classification. Include internal notification flows, assigned roles, the NCSC-CSIRT reporting timeline, and GDPR integration. You’ll refine it post-listing, but early versions reduce chaos during real or test events.
Bridging the knowledge gap: Training and awareness
One of the often-overlooked elements of DORA is the emphasis on education. DORA training programs are crucial to ensure staff across departments—from compliance to ICT—understand their roles in maintaining operational resilience.
Beyond internal training, third-party providers are offering DORA courses, helping organizations upskill teams quickly. If you’re looking to learn more about DORA, visit our resource hub for useful webinars and eBooks.
PRO TIP
Use role-specific DORA training modules. ICT, compliance, and risk teams face different expectations under DORA—tailored learning accelerates competence and helps meet audit-readiness faster.
The financial consequences: Fines and enforcement
DORA doesn’t just recommend best practices—it enforces them. The penalties for non-compliance are structured to be proportionate but significant enough to ensure accountability.
| Enforcement Area | Potential Consequences |
| Non-Compliance with ICT Governance | Administrative penalties, reprimands, or license suspension. |
| Inadequate Incident Reporting | Fines or public censure for failure to notify regulators within required timeframes. |
| Violations in Third-Party Oversight | Liability for service disruptions and regulatory sanctions. |
This enforcement model reflects a shift toward a stricter compliance culture in the EU. It also places additional pressure on board members, who must now demonstrate active involvement in ICT risk oversight.
PRO TIP
Ensure your board minutes reflect active oversight of ICT risk. Regulators may look for evidence that directors are engaged with resilience planning—not just approving budgets passively.
Risk management in the DORA era
Financial institutions have always practiced some form of ICT risk management, but DORA forces a much deeper, systemic approach. Institutions must perform risk assessments not just annually, but on an ongoing basis, adapting to new threats and digital dependencies.
The DORA European regulation also mandates a register of all ICT third-party service providers and critical subcontractors. This is a significant shift, especially for firms that rely heavily on cloud infrastructure, as it demands visibility down the chain.
Simplify your DORA compliance journey with CyberUpgrade
Achieving DORA compliance across ICT risk, incident reporting, and third-party management can feel overwhelming—but it doesn’t have to be. CyberUpgrade helps financial institutions across Europe streamline their resilience strategy with expert-led workflows, automated evidence collection, and real-time monitoring integrated directly into Slack or Teams. From your first gap analysis to threat-led penetration testing and board-level reporting, we handle the heavy lifting.
Our platform eliminates up to 80% of manual compliance work while ensuring your policies, contracts, and vendor oversight align with both EU-level and national DORA requirements. You get dedicated CISO guidance, easy collaboration across departments, and audit-ready documentation—all without disrupting your core operations.
Whether you’re based in Germany, France, Italy, or operating cross-border, CyberUpgrade is built to meet DORA where you are. Book a consultation with our experts today and turn resilience into your competitive advantage.
Building resilience one step at a time
The beauty of DORA is that it doesn’t demand perfection on day one. What it does require is a structured, transparent, and accountable approach to ICT resilience. It’s about demonstrating to regulators and customers that you’re not just hoping for the best but planning for the worst.
Countries like Germany, France, and Italy are setting the pace, and even in the UK, institutions are taking cues from DORA to bolster their own frameworks. Whether you’re a compliance officer, ICT manager, or executive board member, understanding this regulation is no longer optional.
The question isn’t whether DORA matters—it’s whether you’re ready for what comes next.
Assess your DORA readiness for free!
Evaluate your organization’s compliance gaps and find areas for improvement—no prior DORA knowledge needed.
