Belgium’s strategic position at the heart of Europe has always influenced its approach to financial regulation and digital innovation. Many multinational banks and service providers operate in Brussels or nearby cities, making cybersecurity and operational resilience top priorities. With the advent of the Digital Operational Resilience Act (DORA), Belgian regulators and businesses alike are taking a closer look at how to align local rules with this EU-wide mandate. In this post, I’ll examine how Belgium is implementing DORA, consider whether the process differs from other EU countries, and explore how Belgian regulations already echo DORA’s principles. I’ll also outline a few auditors that can guide Belgian organizations through DORA compliance.
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The Belgian context and DORA’s significance
The financial sector in Belgium falls primarily under the National Bank of Belgium (NBB) and the Financial Services and Markets Authority (FSMA). Both agencies have a history of enforcing rigorous standards around risk management, consumer protection, and ICT oversight. This strong regulatory culture means DORA’s principles—covering ICT risk management, incident reporting, and third-party control—are not entirely new to Belgian financial institutions. What’s novel is how DORA unifies these expectations across all EU member states, creating a harmonized benchmark for digital resilience.
Beyond conventional finance, DORA’s demands for robust risk assessments and prompt incident reporting extend to any business handling sensitive financial data or providing critical IT services. Belgium has a vibrant ecosystem of startups, payment processors, and financial technology firms, so the effects of DORA will likely spill over into other industries, encouraging stronger cyber defenses and more structured governance models.
How Belgium’s approach compares to other EU member states
While every country must adhere to DORA’s common framework, local supervisory practices can differ. In Belgium, the NBB and FSMA have a track record of close collaboration with industry stakeholders, often issuing guidance that clarifies how EU regulations should be applied within the Belgian market. This consultative approach helps businesses adapt more smoothly, yet it may also result in Belgium-specific requirements layered on top of DORA.
In contrast, countries with more decentralized oversight could face steeper challenges integrating DORA into their frameworks. Belgium’s relatively straightforward regulatory structure—together with strong expertise in implementing previous EU directives such as PSD2 and the NIS Directive—provides a helpful foundation for rolling out DORA. However, Belgian companies operating across multiple EU jurisdictions should remain aware of any local nuances in how DORA is interpreted elsewhere.
PRO TIP
Keep an eye on circulars or updates from NBB and FSMA, as they frequently issue clarifying notes on how EU regulations apply locally. These may include Belgium-specific procedures or recommended templates for DORA compliance.
Existing Belgian regulations aligning with DORA
Belgium already has several laws and guidelines that resonate with DORA’s calls for digital operational resilience. The table below summarizes key regulations and how they support or complement DORA’s objectives:
| Regulation or measure | Focus area | How it aligns with DORA |
| Belgian National Cybersecurity Strategy | Coordinated approach to combating cyber threats | Encourages a standardized approach to risk management and incident reporting, reinforcing DORA’s resilience aims |
| Implementation of the NIS Directive in Belgian law | Rules for essential service providers and digital service providers | Aligns with DORA’s emphasis on consistent security measures and mandatory cyber incident reporting |
| NBB Circulars on IT and Security Risk Management | Sets requirements for banks and payment institutions on internal controls and risk management | Overlaps with DORA’s demands for ICT governance, third-party oversight, and robust operational resilience |
While Belgian organizations won’t need to rebuild their compliance programs from scratch, DORA’s uniform reporting timelines and cross-border scope mean companies must closely review existing policies. Ensuring these procedures meet DORA’s standardized expectations for third-party risk and incident disclosure is vital to achieving full compliance.
PRO TIP
If you’re already complying with the Belgian NIS implementation or NBB circulars, use those controls as your DORA compliance baseline—then layer in additional documentation or controls where DORA introduces new standardizations.
List of DORA auditors in Belgium
There is no single, official registry of DORA auditors, but several well-known firms in Belgium specialize in cybersecurity, ICT risk management, and regulatory compliance. Below is a concise overview of some options to consider:
| Firm | Primary expertise | Additional notes |
| Deloitte Belgium | Cyber risk, IT governance, regulatory audits | Global capabilities with strong local presence |
| KPMG Belgium | ICT risk management, compliance reviews, operational audits | Experienced in Belgian financial sector |
| PwC Belgium | Cybersecurity, data privacy, business continuity planning | Offers tailored solutions for diverse industries |
| EY Belgium | Technology consulting, digital transformation, IT audits | Deep knowledge of cross-border regulations |
| BDO Belgium | Internal controls, risk assurance, mid-market advisory | Known for pragmatic and cost-effective approaches |
| NRB Group | Specialized IT consulting, cybersecurity, and infrastructure | Belgian-based firm with a focus on local clients |
Organizations seeking to comply with DORA should assess each firm’s track record and industry expertise. An auditor’s familiarity with Belgian financial regulations, combined with its understanding of EU directives, can streamline the path to alignment.
PRO TIP
When selecting an audit partner, ask if the firm has supported organizations with prior NIS Directive or PSD2 audits in Belgium. Their ability to navigate overlapping frameworks will save time and prevent redundant documentation.
How CyberUpgrade supports Belgian firms on their DORA journey
With Belgium’s strong regulatory foundations and EU-focused outlook, many organizations already have a head start on DORA—but navigating its detailed demands still takes time, expertise, and coordination. CyberUpgrade simplifies the process by automating compliance workflows, aligning with NBB circulars, and guiding your teams through the exact requirements of DORA without adding operational burden. Whether you’re a fintech in Brussels or a service provider supporting the financial sector, our platform accelerates your path to resilience.
From risk assessments and evidence gathering to third-party reviews and incident planning, our platform handles 80% of the compliance work—allowing your team to focus on what matters most. Our Slack and Teams-integrated chatbot ensures real-time engagement across departments, while our CISO-led approach keeps you aligned with both Belgian standards and EU directives. No spreadsheets, no confusion—just guided compliance, built for your pace.
Belgian organizations using CyberUpgrade report cutting their compliance workload dramatically while staying regulator-ready and saving up to €60,000 annually. With audit-tested workflows, localized support, and a track record of seamless implementation, we make DORA compliance a strategic asset—not a burden.
Looking beyond compliance
DORA arrives in Belgium at a time when businesses are accelerating digital services and facing a rising tide of cyber threats. While the Act raises the bar for operational resilience, it also offers a roadmap for creating secure and trusted digital infrastructures. Belgian firms that proactively address DORA’s requirements can enhance their credibility in the eyes of clients, regulators, and international partners. By embracing a robust risk culture, companies position themselves for sustainable growth in an increasingly interconnected market—proving that resilience isn’t just a regulatory demand, but a strategic advantage.
Assess your DORA readiness for free!
Evaluate your organization’s compliance gaps and find areas for improvement—no prior DORA knowledge needed.
