When the EU’s Digital Operational Resilience Act (DORA) came into force, it sent a clear message: operational resilience isn’t just about disaster recovery—it’s about cyber hygiene, continuity, and proactive defence. Among its many moving parts, one principle stands out for its sheer practicality and power: knowing your vulnerabilities before attackers do. That’s exactly where vulnerability scanning becomes a critical compliance ally.
DORA applies to a wide array of financial entities and ICT third-party providers, setting rigorous expectations for risk management, monitoring, and threat-led testing. While it doesn’t name specific tools, it lays down a framework that makes regular, intelligent vulnerability scanning not just helpful—but essential.
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Mapping scanning to DORA’s risk management obligations
DORA’s Title II focuses on ICT risk management, requiring entities to identify, protect, detect, respond to, and recover from ICT-related incidents. Vulnerability scanning aligns naturally with the first three of those pillars.
Let’s examine the alignment in clearer operational terms:
| DORA Requirement | Scanning’s Contribution |
| Identify ICT risks | Finds known software and configuration vulnerabilities in real-time |
| Protect against cyber threats | Supports prioritised patching and configuration hardening |
| Detect anomalies and weaknesses | Enables continuous monitoring of IT assets for emerging threats |
| Respond to vulnerabilities | Provides structured inputs for incident workflows and remediation timelines |
| Recover from incidents | Helps assess exposure and harden systems against repeat compromise |
Because DORA demands that financial entities maintain a “sound, comprehensive and well-documented ICT risk management framework,” vulnerability scanning provides not just operational support, but also documentary evidence. It helps organisations prove that they are proactively detecting and mitigating ICT risks—not simply reacting.
A cornerstone of continuous monitoring
One of the most emphasized tenets in DORA is the concept of continuous risk monitoring. This is a marked shift from point-in-time assessments to a more dynamic, ongoing evaluation of digital exposure. Vulnerability scanning—especially when scheduled regularly or integrated into CI/CD pipelines—meets this expectation head-on.
The relevant wording in Article 6.4(b) makes this link explicit. Entities must deploy tools that allow them to “identify all sources of ICT risk in a timely manner.” Scanners that are continuously updated with CVE feeds or threat intelligence platforms deliver on this need.
Let’s compare traditional vs DORA-aligned scanning approaches:
| Characteristic | Traditional Scanning | DORA-Aligned Scanning |
| Frequency | Monthly or quarterly | Continuous or high-frequency scheduling |
| Scope | Limited to perimeter | Includes cloud, endpoints, third-party systems |
| Prioritisation | Manual or static severity ratings | Integrated with asset criticality and threat data |
| Integration | Standalone reports | Feeds into risk management platforms or SIEM |
This evolution is not just a technical preference—it reflects regulatory momentum. As DORA raises the bar on what “resilience” means, outdated scanning practices quickly fall out of step.
Supporting DORA’s advanced testing framework
DORA also introduces Threat-Led Penetration Testing (TLPT) under Title V. While this form of red-teaming is distinct from vulnerability scanning, the two are complementary. Scanning helps organisations prepare for TLPT by preemptively identifying and addressing weaknesses that testers would otherwise exploit.
Scanning becomes a form of readiness assessment—ensuring that environments aren’t littered with low-hanging fruit. This not only improves security posture but can also streamline TLPT scoping and reduce exposure during the testing period.
Here’s how the two methods compare and collaborate:
| Feature | Vulnerability Scanning | TLPT (DORA-guided) |
| Purpose | Identify known weaknesses | Simulate realistic, adversary-driven attack paths |
| Frequency | Continuous or scheduled | Every 3–5 years (minimum, per DORA) |
| Scope | Entire infrastructure (based on IP/assets) | Pre-defined critical systems |
| Output | Technical findings with severity ratings | Tactical findings with recommendations |
| Relationship | Prepares the environment and reduces attack surface | Validates detection and response capabilities |
By removing known vulnerabilities in advance, scanning ensures that TLPT efforts focus on high-value insights rather than avoidable technical debt.
Evidence generation for compliance audits
A key aspect of DORA is auditability—the ability to demonstrate that controls are both implemented and effective. Vulnerability scan reports are ideally suited for this, offering a timestamped, repeatable snapshot of the entity’s exposure at any given point.
Scan data can support compliance with Article 6.9, which requires documentation of all “risk analysis and assessment procedures.” When fed into a risk register or GRC platform, scan outputs can show that vulnerabilities were:
- Detected in a timely fashion
- Classified by severity and business impact
- Assigned for remediation
- Tracked through closure
Because many scanning tools integrate with ITSM and SIEM platforms, the remediation workflow becomes traceable—just the kind of governance DORA auditors will look for.
Operationalise DORA compliance with CyberUpgrade vulnerability scanning
DORA doesn’t just raise the cybersecurity bar—it redefines how financial entities should approach risk. At CyberUpgrade, we help you turn regulatory expectations into real-time resilience. Our managed vulnerability scanning service aligns directly with DORA’s ICT risk management mandates, providing you with continuous visibility across your infrastructure—from cloud environments to third-party integrations. Our CISOs run the scan for you and map the scan findings to business-critical systems, prioritise by impact, and deliver audit-ready reports that feed straight into your risk register.
Whether you’re preparing for TLPT, building out your ICT risk framework, or proving control effectiveness to auditors, we provide the technical evidence and expert support you need—on schedule, in scope, and fully documented.
Stay ahead of DORA, not buried under it. Let CyberUpgrade help you transform scanning into a strategic asset. Talk to us today.
Beyond compliance: building resilience through visibility
DORA’s aim is not to increase paperwork. It’s to elevate operational resilience across the financial sector. Vulnerability scanning contributes by offering organisations clear, actionable visibility into their digital exposure. More importantly, it embeds that visibility into the day-to-day rhythm of ICT operations.
Scanning answers a deceptively simple question: What risks do we already have in the open? That clarity can be uncomfortable, but it’s what resilience is built on.
For entities subject to DORA, the question isn’t whether to scan—it’s how well those scans are integrated, prioritised, and acted upon. When done right, scanning becomes a quiet force multiplier: enabling early detection, supporting informed risk decisions, and turning compliance into capability.
Assess your DORA readiness for free!
Evaluate your organization’s compliance gaps and find areas for improvement—no prior DORA knowledge needed.
