DORA regulations in Netherlands and impact for all industries

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Reviewed by: Nojus (Noah) Bendoraitis


On a recent visit to Amsterdam, I was struck by the seamless blend of tradition and modernity—canals and bicycles stood alongside bustling fintech hubs and digital startups. It felt like the perfect backdrop for understanding the Netherlands’ approach to cyber resilience. In this post, I’ll explore the Digital Operational Resilience Act (DORA) and how Dutch businesses are preparing to meet its demands. I’ll look at the main regulatory bodies, consider whether the Dutch implementation is noticeably different from other EU countries, and highlight existing rules that align with DORA’s objectives. Finally, I’ll include a brief list of auditing firms in the Netherlands that can guide organizations on their compliance journey.

Understanding DORA’s significance in the Netherlands

DORA sets out uniform requirements for operational resilience, ICT risk management, and incident reporting across the EU’s financial sector. But these requirements invariably affect a broad range of companies that partner with financial services. In the Netherlands, there’s already a strong focus on cybersecurity, data privacy, and risk management, partly driven by consumer expectations and partly by the proactive stance of financial regulators. Because the country’s fintech ecosystem is thriving, many companies find themselves needing to comply with DORA, even if they aren’t strictly financial institutions.

Dutch regulators, notably De Nederlandsche Bank (DNB) and the Netherlands Authority for the Financial Markets (AFM), have historically enforced robust policies around risk governance and customer protection. This creates a smoother transition into DORA, as these existing rules on operational continuity, third-party oversight, and data security often mirror DORA’s core themes.

Is the Dutch approach different from other countries?

Every EU member state must implement DORA’s requirements, but each nation’s starting point varies based on prior regulations. The Dutch, known for their pragmatic and collaborative approach, often engage in thorough industry consultations when adopting new rules. This means Dutch guidelines or sector-specific add-ons could emerge to address local concerns, such as data sharing protocols between banks and fintech companies or the role of cloud providers in financial services.

Compared to countries with less centralized oversight, the Netherlands benefits from well-coordinated regulatory bodies. DNB, for instance, has established frameworks for assessing ICT risk in banks, payment institutions, and insurers, while the AFM manages oversight for investment firms and securities markets. Their collective experience in rolling out GDPR, PSD2, and the NIS Directive should help in interpreting and enforcing DORA efficiently.

Existing regulations that align with DORA

Although DORA introduces a fresh, unified standard across the EU, it doesn’t arrive in a vacuum. In the Netherlands, a range of regulations already touch on similar objectives:

Regulation or measureFocus areaHow it aligns with DORA
GDPR (AVG in Dutch)Emphasizes data privacy and securityComplements DORA’s incident reporting demands, particularly when customer data is involved
Dutch implementation of the NIS DirectiveSets requirements for critical service providersAligns with DORA’s focus on continuous risk monitoring and mandatory cyber incident reporting
DNB guidance on outsourcing and ICT riskOutlines how financial entities should manage risks tied to external service providersDovetails with DORA’s call for robust oversight of third-party vendors

These measures mean many Dutch organizations will likely view DORA as the next incremental step rather than an entirely new framework. Still, DORA’s uniform reporting mechanisms and cross-border scope could require additional coordination, especially for firms that operate across multiple EU jurisdictions.

List of DORA auditors in the Netherlands

While DORA does not mandate a specific set of “official” auditors, a handful of well-established firms in the Netherlands specialize in ICT, cybersecurity, and operational resilience. The table below offers examples of organizations that can help businesses align their practices with DORA requirements.

FirmPrimary expertiseAdditional notes
Deloitte NetherlandsCyber risk, operational resilience, regulatory auditsGlobal network with Dutch-based specialists
KPMG NetherlandsIT governance, compliance reviews, risk managementKnown for strong links to the banking and insurance sectors
PwC NetherlandsCybersecurity, data privacy, incident responseTailored approaches for large and mid-sized firms
EY NetherlandsTechnology consulting, IT audits, digital transformationIn-depth experience with regulated industries
BDO NetherlandsInternal controls, process optimization, risk assuranceFocus on SMEs and mid-market financial services
ProtivitiCybersecurity consulting, operational risk managementBoutique approach with local and international reach

Organizations in the Netherlands seeking an audit or advisory partner may want to consider the firm’s track record in regulated industries, its familiarity with Dutch legislation, and its understanding of broader EU directives.

Charting a resilient future

The Netherlands has long been a leader in digital innovation, and that leadership extends to the realm of cybersecurity and operational resilience. DORA’s arrival doesn’t upend existing practices but rather enhances them by creating a unified EU-wide standard. By harnessing the synergy between Dutch regulations and DORA’s framework, organizations can reinforce customer trust, shield themselves from reputational damage, and maintain a competitive edge. As the lines between financial services and other sectors continue to blur, the Dutch spirit of collaboration could prove vital in shaping how effectively DORA safeguards the modern, interconnected marketplace.

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