General Counsel

Jun 10, 2025

7 min. read

DORA regulations in Poland and impact for all industries

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DORA regulations in Poland and impact for all industries

When I visited Warsaw’s bustling business district a while ago, I was struck by just how quickly the city was evolving—sleek fintech startups, mobile payment apps, and state-of-the-art office buildings seemed to reflect a broader digital renaissance. As more industries rely on data-driven services, there’s a mounting need for robust cyber regulations that can safeguard customers and companies alike. 

Enter the Digital Operational Resilience Act (DORA), a Europe-wide framework designed to raise the bar on how organizations protect their digital infrastructure. In this post, we’ll explore how Poland is putting DORA into practice, whether the process differs from other EU countries, and how existing Polish regulations pave the way for DORA’s core principles. We’ll also highlight some local auditors you can turn to for compliance support.

Poland’s perspective on DORA

Poland’s financial sector, under the guidance of the Polish Financial Supervision Authority (KNF), has gradually strengthened its oversight of cyber and operational risks in recent years. KNF directives and recommendations already push banks, insurers, and other regulated entities to maintain high levels of digital resilience. This familiarity with stringent requirements means that the fundamentals of DORA—such as ICT risk management, incident reporting, and third-party oversight—fit naturally into Poland’s ongoing strategy.

However, DORA is not just for financial giants. Polish technology vendors, cloud providers, and consulting firms that partner with financial institutions must also meet higher standards under the new regulation. The good news is that many Polish businesses are primed for this alignment, thanks to KNF’s emphasis on IT security audits and operational continuity in the financial sector over the past decade.

Comparing Poland with the broader EU approach

All European Union member states have to adapt their local frameworks to DORA’s requirements. The level of effort typically depends on how developed a country’s existing regulations are. For instance, some member states might have fragmented guidance on cyber risk, making DORA a bigger shake-up. In Poland, while there’s still work to be done, the KNF already sets rigorous expectations on ICT risk and business continuity. This relatively high baseline can smooth the path to compliance compared with countries where oversight is more decentralized or less established.

That said, local nuances remain. Polish regulators often issue clarifications and additional guidelines to harmonize EU directives with national law. We’re likely to see similar advisories interpreting DORA in the Polish context, ensuring a common framework without losing sight of local risk factors, such as the cybersecurity challenges specific to Poland’s banking sector or the emerging fintech scene.

How Poland’s existing regulations align with DORA

Before DORA, Poland had already introduced regulations and guidelines that align neatly with the Act’s principles. Many stem from EU-wide mandates, while others are homegrown rules reflecting Poland’s commitment to building a resilient financial environment. Below is a simplified overview:

Polish regulation or measureFocus areaConnection to DORA
KNF Recommendations (e.g., D-SK1)Operational risk management and internal controlsOverlaps with DORA’s emphasis on robust ICT governance and resilience
National Cybersecurity System ActImplementation of the NIS Directive, covering critical servicesSets a precedent for incident reporting and threat monitoring, key in DORA
Personal Data Protection ActGDPR-aligned rules for data privacyReinforces data security obligations, mirroring DORA’s focus on secure handling of sensitive information

These frameworks make DORA feel more like a natural progression than a radical departure for many Polish firms. Even so, DORA’s uniform, EU-wide standards will likely require additional changes, such as standardized reporting mechanisms across borders and more thorough third-party risk assessments.

List of DORA auditors in Poland

Although DORA does not mandate a specific roster of auditing firms, Poland has a notable contingent of consultancies and auditing companies well-versed in cyber risk and compliance. Here’s a snapshot of a few options:

FirmPrimary expertiseAdditional notes
Deloitte PolandOperational resilience audits, cybersecurity reviewsGlobal reach with strong local presence
KPMG PolandIT governance, compliance, regulatory riskKnown for working closely with financial institutions
PwC PolandCybersecurity, GRC solutions, cloud risk assessmentsOffers tailored approaches for mid- to large-scale clients
EY PolandData protection, IT audits, digital transformationDeep experience in regulated industries
BDO PolandInternal audit, business continuity planningFocuses on small to mid-size companies and financial firms
ITMAGINATIONSpecialized cybersecurity consulting, system auditsPolish-based firm with fintech and banking expertise

When choosing an auditor, it’s essential to evaluate their familiarity with both EU directives and the local regulatory landscape. A strong track record with Polish financial institutions, as well as a thorough understanding of KNF guidelines, can streamline your path to DORA compliance.

How CyberUpgrade helps Polish fintechs thrive under DORA

For Polish companies already familiar with KNF guidance and the National Cybersecurity System Act, DORA might feel like an evolution—but the work involved is real. CyberUpgrade accelerates this journey by doing 80% of the compliance heavy lifting for you, using intelligent automation and step-by-step workflows tailored to both EU and local Polish expectations. You stay focused on building your product, while we ensure your digital resilience is regulator-ready.

Our chatbot integrates directly with Slack or Teams, guiding teams through real-time evidence collection and compliance tasks—no need to chase spreadsheets or coordinate audits manually. Backed by expert CISOs, we ensure full alignment with KNF recommendations like D-SK1 and provide end-to-end support across third-party risk management, data security, and continuous monitoring. We even adapt your existing GDPR or NCSA documentation into DORA-ready formats.

Polish fintechs and financial service providers using CyberUpgrade report saving over 60K EUR per year while boosting their audit-readiness and risk posture. Whether you’re scaling fast in Warsaw or just starting out in Kraków, we make DORA compliance faster, simpler, and far more cost-effective.

Securing a digital future

Poland’s embrace of DORA reflects a broader momentum toward elevated cybersecurity standards. As banks, insurers, fintechs, and service providers knit themselves more deeply into a digital economy, resilient infrastructure becomes more than a regulatory checkbox—it’s a strategic necessity. 

By weaving DORA requirements into Poland’s existing regulations, KNF and other stakeholders are setting the stage for a market that’s both forward-looking and robust in the face of evolving cyber risks. The journey might require new processes and deeper diligence, but it also paves the way for greater trust, stability, and innovative growth in Poland’s expanding digital marketplace.

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General Counsel

He is regulatory compliance strategist with over a decade of experience guiding fintech and financial services firms through complex EU legislation. He specializes in operational resilience, cybersecurity frameworks, and third-party risk management. Nojus writes about emerging compliance trends and helps companies turn regulatory challenges into strategic advantages.
  • DORA compliance
  • EU regulations
  • Cybersecurity risk management
  • Non-compliance penalties
  • Third-party risk oversight
  • Incident reporting requirements
  • Financial services compliance

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