Denmark’s reputation as a digitally advanced society goes beyond its widespread use of mobile payment systems and electronic IDs. In the financial sector, Danish banks, payment institutions, and fintech startups have been early adopters of cutting-edge online services and automation. Against this backdrop, the European Union’s Digital Operational Resilience Act (DORA) sets a new standard for managing ICT risks and ensuring business continuity across the entire EU financial ecosystem.
In this post, I’ll examine how Denmark is integrating DORA into its regulatory landscape, compare this process to other European countries, and explore Denmark’s existing rules that already embody some of DORA’s core principles. I’ll also highlight several auditing firms in Denmark that can help businesses meet DORA’s requirements.
Why DORA matters in Denmark
DORA mandates strong ICT risk management, incident reporting, and third-party oversight, primarily targeting financial entities. Yet, because Denmark is highly digitalized, the regulation’s impact extends into other industries that provide critical IT services to financial institutions. For Danish organizations, meeting DORA’s provisions is not just a legal necessity—it’s a strategic opportunity to reinforce consumer trust and cyber resilience in an interconnected market.
Is Denmark’s approach different from other EU member states?
All EU member states must incorporate DORA’s uniform guidelines, but the path can vary based on a country’s supervisory structure. In Denmark, the primary regulator for the financial sector is the Danish Financial Supervisory Authority (Finanstilsynet). Known for a cooperative approach, Finanstilsynet typically consults closely with industry stakeholders when implementing new regulations. This open dialogue can result in local clarifications or practical guidelines that supplement DORA’s broader framework.
In countries with more fragmented oversight, reconciling multiple agencies’ views may take longer. Denmark’s relatively streamlined structure often allows for a more efficient adoption of EU directives. However, businesses operating across several EU markets should be attentive to differences in how local regulators interpret certain details, such as incident reporting timelines or scope.
Existing Danish regulations aligning with DORA
Denmark has been proactive in promoting cybersecurity and operational stability long before DORA. Several national measures already mirror parts of DORA’s objectives:
Danish regulation or measure | Focus area | How it aligns with DORA |
Finanstilsynet guidelines on outsourcing and IT security | Details requirements for banks, payment institutions, and insurers regarding internal controls and third-party governance | Reflects DORA’s emphasis on structured vendor due diligence and ongoing ICT risk management |
Danish implementation of the NIS Directive | Sets obligations for operators of essential services, including parts of the financial sector | Complements DORA’s focus on continuous monitoring and mandatory reporting of cyber incidents |
GDPR enforcement in Denmark (Databeskyttelsesloven) | Ensures data privacy and breach notification for personal information | Aligns with DORA’s requirement to secure sensitive data and promptly report incidents that affect clients |
Because these frameworks already guide Danish financial entities to prioritize security, adjusting to DORA often feels more like a consolidation of existing practices than a revolutionary change. Still, the Act’s uniform standards—particularly for cross-border operations—require updates to reporting processes and contractual arrangements with third parties to ensure consistency throughout the EU.
Impact beyond finance
Although DORA explicitly targets banks, insurers, investment firms, and similar institutions, any Danish business that hosts, processes, or safeguards critical financial data is indirectly affected. That includes cloud providers, payment service vendors, tech consultancies, and even certain B2B platforms. A single security lapse at a third-party provider could trigger DORA’s incident reporting obligations, meaning these companies must adopt rigorous protective measures and clear protocols for managing disruptions.
For Denmark’s thriving fintech scene, DORA introduces a common baseline of cybersecurity expectations throughout the EU. Newer startups that can demonstrate strong compliance could gain a competitive advantage and foster greater trust among clients wary of cyber threats.
List of DORA auditors in Denmark
DORA does not specify a roster of accredited auditors, but Denmark hosts several prominent consultancies and assurance firms experienced in ICT risk, regulatory compliance, and cybersecurity. Below is a concise list:
Firm | Primary expertise | Additional notes |
Deloitte Denmark | Cyber risk, operational resilience, internal audits | Combines global resources with Danish financial sector expertise |
KPMG Denmark | ICT governance, compliance reviews, risk management | Known for supporting large-scale Danish banking and insurance clients |
PwC Denmark | Cybersecurity, data privacy, incident response, GRC | Offers tailored approaches for both local and multinational entities |
EY Denmark | IT audits, digital transformation, cross-border compliance | Has a track record guiding cross-border financial firms |
BDO Denmark | Internal controls, mid-market risk advisory, business continuity | Focuses on smaller to mid-sized financial and tech organizations |
Devoteam | Denmark-based IT consultancy, cybersecurity services | Specializes in implementing technical frameworks for resilience |
When selecting an audit or advisory partner, Danish companies should seek firms that understand both local regulations (through Finanstilsynet guidance) and the larger EU context underpinning DORA.
Shaping a resilient future
Denmark’s digital leadership pairs naturally with DORA’s aim of raising the bar for operational and cyber resilience across Europe. By integrating DORA’s standardized approach to ICT risk and incident handling, Danish businesses can enhance their reputations for reliability and security. For those operating internationally, embracing DORA sets a firm foundation for consistent compliance in multiple jurisdictions. Ultimately, the Act aligns with Denmark’s broader ethos of forward-looking innovation—ensuring that the nation’s financial services remain robust and trusted in a fast-evolving digital landscape.