Several months ago, I worked with a client in the financial sector who was grappling with an increasingly complex regulatory landscape. They were drowning in spreadsheets and manual processes while trying to maintain compliance with the EU’s Digital Operational Resilience Act (DORA). Their biggest challenge? Managing vulnerabilities efficiently and meeting DORA’s stringent requirements for vulnerability management.
This experience underscored the critical importance of building a cohesive vulnerability management framework aligned with DORA. Here’s what I learned and how you can enhance your cybersecurity posture by focusing on disclosure, assessments, and scanning.
The art of vulnerability disclosure: A critical first step
When I first engaged with the client, one glaring issue became evident—they had no formal vulnerability disclosure process. Security flaws were occasionally flagged by their development team or external auditors, but there was no centralized system to track or prioritize them.
DORA vulnerability disclosure emphasizes creating clear, structured pathways for reporting and managing vulnerabilities, whether they originate internally or externally. Here are the key elements of it:
Key DORA requirements and implementation for vulnerability disclosure
Requirement | How to implement |
Establish a formal disclosure process | Create a documented policy and assign ownership for managing disclosures. |
Provide secure reporting mechanisms | Use encrypted email or online platforms to receive reports safely from stakeholders. |
Track and prioritize reported issues | Implement an automated workflow tool for managing and triaging vulnerabilities. |
For my client, we implemented a formal disclosure program supported by automated workflows. These workflows routed vulnerabilities to the appropriate teams while tracking timelines for remediation.
The result? A faster, more transparent resolution process and an improvement in their compliance audit scores. Beyond compliance, the program signaled to third-party partners and regulators that they were serious about operational resilience.
A key takeaway here is that vulnerability disclosure isn’t just about managing flaws—it’s about building a culture of accountability and resilience. Your systems should encourage reporting and provide clear guidance on how vulnerabilities are addressed.
Assessments: The backbone of Informed decision-making
With disclosure processes in place, the next hurdle was conducting comprehensive vulnerability assessments. While our client’s security team was skilled, their approach to assessments was inconsistent. Some vulnerabilities were analyzed thoroughly, while others were dismissed without adequate evaluation.
DORA vulnerability assessments require a risk-based approach. It’s not enough to simply identify vulnerabilities—you need to assess their potential impact on your organization. This ensures that resources are allocated to address the most critical threats first. Let’s take a look at key aspects in the table below:
Key DORA requirements and implementation for vulnerability assessments
Requirement | How to implement |
Conduct risk-based assessments | Use scoring systems like CVSS to prioritize vulnerabilities based on impact. |
Evaluate third-party and supply chain risks | Incorporate vendor assessments in the evaluation process. |
Maintain assessment documentation | Use centralized tools to document assessment results and decision-making. |
For my client, we introduced automated tools to standardize assessments, using scoring systems like the Common Vulnerability Scoring System (CVSS) to prioritize risks. One particular case stood out: a seemingly low-risk vulnerability in a third-party tool was flagged for deeper assessment. The tool was integrated into their payment processing system, making the vulnerability far more critical than it initially appeared. Addressing this issue proactively prevented a potential service disruption and avoided regulatory penalties.
What I learned from this process is that thorough assessments don’t just protect your business—they safeguard your reputation. DORA compliance isn’t just about ticking boxes; it’s about making informed decisions that align with your operational priorities.
Scanning: The engine of proactive defense
When discussing DORA vulnerability scanning, I often tell clients that this is where the rubber meets the road. Scanning tools are your first line of defense, continuously probing for weaknesses before malicious actors can exploit them. My client, however, had been relying on quarterly scans, a frequency that left them exposed to fast-evolving threats.
Under DORA, organizations are expected to implement continuous vulnerability scanning practices. This proactive approach not only identifies vulnerabilities as they emerge but also reduces the window of exposure. Below are the most important requirements you need to be aware of:
Key DORA Requirements and Implementation for Vulnerability Scanning
Requirement | How to Implement |
Implement continuous scanning | Deploy automated scanning tools that run in real-time. |
Integrate scanning into DevOps | Use tools compatible with CI/CD pipelines to detect vulnerabilities in real-time. |
Monitor and review scan results | Assign dedicated resources to analyze and act on scan findings promptly. |
One specific incident highlighted the value of this shift. A zero-day vulnerability surfaced in a widely used library. Thanks to real-time scanning, the client identified the affected systems within hours, prioritized patches, and updated their risk assessments before the issue could escalate. This not only reinforced their compliance posture but also boosted confidence among their regulators and customers.
The moral here is clear: investing in robust scanning capabilities isn’t just about compliance—it’s about staying ahead of threats and mitigating risks before they spiral out of control.
Turning compliance into a competitive edge
My experience working with this client transformed my perspective on DORA vulnerability management. By focusing on disclosure, assessments, and scanning, they didn’t just achieve compliance—they turned it into a competitive advantage. Regulators praised their resilience, customers felt reassured by their proactive approach, and internal teams reported higher morale and efficiency.
If you’re navigating the complexities of DORA compliance, don’t view these requirements as a burden. Instead, use them as an opportunity to enhance your cybersecurity maturity. Whether it’s implementing structured vulnerability disclosure, adopting a risk-based assessment framework, or investing in continuous scanning, every step you take strengthens your operational resilience.