Compliance with the Digital Operational Resilience Act (DORA) is not just about meeting regulatory requirements—it’s about ensuring your organization can withstand and recover from digital disruptions. With financial institutions increasingly targeted by cyber threats, DORA establishes a unified framework to enhance the digital resilience of banks, insurers, and investment firms across the EU.
To help your organization align with these regulations, this DORA compliance checklist breaks down the key steps for seamless implementation. By following this structured approach, you’ll strengthen your ICT risk management, incident response, and business continuity strategies while ensuring compliance with regulatory mandates.
Key components of DORA compliance checklist
Achieving DORA compliance requires a structured approach that covers every aspect of digital operational resilience. The regulation is built around several core components that financial institutions and ICT service providers must integrate into their risk management and security frameworks.
Each of these components plays a critical role in ensuring organizations can anticipate, withstand, and recover from cyber incidents and operational disruptions. Below is a summary of key checklist areas and important actions to take for DORA compliance.
DORA compliance checklist summary
| Checklist area | Key actions |
| Governance and organizational structure | Ensure leadership oversight, clear roles, and formal policies |
| ICT risk management framework | Identify and mitigate risks, monitor systems, and assess third parties |
| ICT incident management | Develop an incident response plan, escalation procedures, and reporting mechanisms |
| Third-party risk management | Conduct vendor assessments, enforce security contracts, and ensure continuous monitoring |
| Business continuity and disaster recovery | Define recovery objectives, conduct BIA, and test business continuity plans |
| ICT security and resilience testing | Perform penetration tests, vulnerability scans, and stress simulations |
| Audits and continuous improvement | Maintain records, meet reporting obligations, and update policies regularly |
1. Governance and organizational structure
A resilient organization starts with strong governance. Without clear leadership and accountability, compliance efforts often fall apart due to a lack of direction. DORA requires financial firms to establish governance structures that promote operational resilience at all levels.
Senior management oversight
☐ Board/management commitment: Senior leadership must actively oversee DORA compliance efforts rather than delegating them entirely to IT or security teams. This ensures digital resilience becomes a core business priority.
☐ Clear responsibilities: Roles and responsibilities for ICT risk management should be well-documented to avoid confusion during critical situations.
Why this matters: When top management is engaged, the entire organization prioritizes resilience. Without their commitment, security and compliance efforts often stall due to lack of resources or urgency.
Organizational structure & culture
☐ Dedicated functions: Appointing a chief information security officer (CISO) or equivalent role ensures a dedicated leader is accountable for ICT risk management.
☐ Culture of resilience: Organizations must go beyond policy creation by fostering a proactive risk-aware culture where employees understand the importance of digital resilience.
Why this matters: Without a dedicated team and cultural commitment, ICT risk management often becomes a reactive effort rather than a proactive strategy.
Policies and procedures
☐ Formal policies: Organizations must develop written policies covering ICT risk management, incident handling, and business continuity.
☐ Review process: Policies should be reviewed and updated regularly to keep up with evolving cyber threats and regulatory changes.
Why this matters: Clear policies standardize security practices across the organization, ensuring consistency in how risks and incidents are managed.
Reporting & communication
☐ Internal reporting lines: Establishing structured reporting processes ensures cyber incidents are quickly escalated to the right decision-makers.
☐ Communication strategy: Organizations must define clear communication protocols for both internal stakeholders and external regulators in case of an ICT-related crisis.
Why this matters: Timely reporting ensures incidents are addressed before they escalate into full-scale disruptions.
2. ICT risk management framework
Risk management forms the backbone of DORA compliance. Organizations must systematically identify, assess, and mitigate risks before they threaten operations.
Risk identification & assessment
☐ Risk inventory: Maintain an updated list of critical ICT assets, data, and processes to identify high-risk areas.
☐ Risk assessment methodology: Implement structured risk assessment models to evaluate threats from cyberattacks, system failures, and third-party dependencies.
Why this matters: Without proper risk assessments, organizations cannot allocate security resources effectively, leaving key vulnerabilities unaddressed.
Risk mitigation & control measures
☐ Control implementation: Deploy a combination of technical (firewalls, encryption) and organizational (access controls, incident response teams) security measures.
☐ Third-party dependencies: Conduct risk assessments on all external ICT service providers, ensuring they meet compliance standards.
Why this matters: Many cyberattacks originate from third-party vulnerabilities. Ensuring vendor security minimizes these risks.
Monitoring and reporting
☐ Ongoing monitoring: Continuously track system performance, security events, and risk indicators.
☐ Risk reporting: Define clear metrics (KPIs) to assess digital resilience and report risks to management regularly.
Why this matters: Proactive monitoring helps organizations detect potential security threats before they cause operational disruptions.
3. ICT incident management
A well-structured incident response plan ensures your organization can detect, contain, and recover from cybersecurity incidents efficiently.
Incident detection and response
☐ Incident detection capabilities: Use automated monitoring tools to identify anomalies and potential cyberattacks in real-time.
☐ Incident response plan (IRP): Define detailed procedures outlining responsibilities and communication protocols during security incidents.
Why this matters: Organizations without an IRP often experience longer recovery times and increased financial losses during cyber incidents.
Incident classification and escalation
☐ Classification criteria: Establish standardized methods to categorize incidents based on severity.
☐ Escalation procedures: Define clear paths for escalating high-priority incidents to senior management and regulators.
Why this matters: Proper classification ensures critical threats are handled with urgency, while minor issues don’t consume unnecessary resources.
Post-incident analysis and reporting
☐ Root cause analysis: Conduct thorough reviews of incidents to identify patterns and weaknesses.
☐ Regulatory reporting: Meet DORA’s strict deadlines for reporting significant cyber incidents to regulators.
Why this matters: Learning from past incidents helps organizations continuously improve security practices.
4. Third-party risk management
Third-party vendors often introduce security risks. DORA mandates stronger oversight of outsourced ICT services to ensure compliance.
Due diligence and contractual arrangements
☐ Vendor risk assessments: Conduct background checks before engaging ICT service providers.
☐ Contractual obligations: Ensure contracts include DORA-aligned security expectations and service level agreements (SLAs).
Why this matters: A weak vendor contract can expose organizations to non-compliance risks and security vulnerabilities.
Ongoing oversight
☐ Monitoring provider performance: Conduct regular performance reviews and security audits of third-party services.
☐ Audit rights: Retain the right to inspect vendor security practices as part of contractual agreements.
Why this matters: Continuous oversight ensures that third-party partners do not become weak links in the security chain.
5. Business continuity and disaster recovery
DORA requires financial entities to prepare for and recover from ICT disruptions efficiently.
Business impact analysis (BIA)
☐ Identify critical processes: Assess which business functions rely most heavily on ICT systems.
☐ Define recovery objectives: Establish acceptable downtime limits (RTOs) and data loss thresholds (RPOs).
Why this matters: A well-defined BIA helps organizations prioritize recovery efforts effectively.
Testing and maintenance
☐ Regular testing: Conduct frequent disaster recovery drills to validate BCP effectiveness.
☐ Plan updates: Revise recovery strategies based on test results and emerging threats.
Why this matters: Frequent testing ensures that business continuity plans remain relevant and effective.
Final steps: Audits, documentation, reporting, and continuous improvement
DORA requires organizations to maintain detailed records of risk assessments, incidents, and compliance activities as well as perform regular audits.
Conduct a gap analysis
☐ Compare current practices: Identify discrepancies between current resilience measures and DORA requirements.
☐ Develop a remediation plan: Assign clear timelines and responsible parties for addressing compliance gaps.
Internal and external audits
☐ Schedule regular audits: Conduct periodic assessments to verify compliance and identify weaknesses.
☐ Management review: Ensure senior management reviews audit findings and implements corrective actions.
Why this matters: Regular audits ensure that compliance efforts remain effective and aligned with evolving threats.
Record keeping
☐ Documentation repository: Store records of risk assessments, incident reports, and business continuity plans.
☐ Version control: Ensure all documentation is up to date.
Reporting to authorities
☐ Timely notifications: Submit required reports within regulatory deadlines.
☐ Data retention: Comply with DORA’s data storage requirements.
Continuous improvement
☐ Feedback loop: Use lessons learned from past incidents to update policies and security controls.
☐ Regular reviews: Conduct periodic evaluations of resilience measures.
Are you ready for DORA compliance?
Achieving DORA compliance is not just about meeting regulatory requirements—it’s about building a strong, adaptable, and secure digital infrastructure. By following this DORA checklist, organizations can proactively identify risks, respond to incidents, and ensure operational continuity, even in the face of cyber threats and disruptions.
With enforcement deadlines approaching, now is the time to assess your current resilience strategy, conduct a gap analysis, and implement necessary improvements. A well-prepared organization doesn’t just comply with DORA—it thrives in an increasingly digital and interconnected financial landscape.
