Under the Digital Operational Resilience Act (DORA), incident classification isn’t just another box to check—it’s a cornerstone of operational resilience. Proper classification is foundational to DORA compliance, acting as a safeguard against regulatory scrutiny. But here’s the reality: getting it wrong isn’t a small mistake. A misstep in classification can quickly spiral into a regulatory nightmare, with delayed responses, penalties, and reputational damage.
Having worked closely with clients trying to navigate DORA’s complexities, I’ve seen how often organizations falter without expert guidance. One key takeaway stands out: understanding and implementing DORA’s classification framework isn’t optional. It’s a non-negotiable pillar of resilience, enabling organizations to respond swiftly and stay compliant.
Let’s dive into what DORA incident classification entails, why it’s critical, and how you can adopt it to protect your organization from ICT disruptions.
Why incident classification is the first line of defense
When ICT disruptions hit, the stakes are high. Systems are down, customers are irate, and regulators are watching. DORA’s incident classification framework ensures that organizations categorize disruptions based on their impact, enabling a streamlined response and reporting process.
In my work with clients, I often ask this critical question during audits: “Do you know how your team would classify an incident involving a sudden payment processing failure?” Most of the time, I’m met with vague responses. One client—a mid-sized bank—had suffered such an outage due to a cybersecurity vulnerability. They lacked clear criteria for classifying the disruption, delaying their response. Regulatory bodies later flagged them for failure to notify in a timely manner. This experience underscored a harsh reality: without clear classification, organizations risk non-compliance and reputational damage.
The DORA framework establishes specific thresholds to evaluate incidents based on criteria such as financial impact, number of customers affected, and potential for data breaches. Let’s take a closer look at the framework below.
Breaking down the DORA classification framework
Here’s a little-known truth: the key to fast and effective incident response lies in having tailored action plans for both major and non-major incidents. While DORA clearly distinguishes between the two severity levels—requiring only major incidents to be reported to regulators—non-major incidents still demand your attention. Ignoring them could leave vulnerabilities unchecked, potentially escalating into larger problems.
But how do you accurately determine the difference, and why is it so important to get this right? Let’s break it down.
What defines a major incident?
A major incident under DORA is one that significantly disrupts an organization’s operational continuity or impacts the broader financial ecosystem. Regulatory bodies expect these incidents to be reported promptly and require a more robust response.
- Financial impact
- Duration of downtime
- Client impact
- Market disruption
- Data breach risk
Example in practice: A major payment processor experienced a ransomware attack that took systems offline for 48 hours. Millions of transactions were delayed, impacting customers and financial institutions globally. This was classified as a major incident, triggering regulatory reporting and intensive remediation measures.
While the framework may seem complex at first, we’ve summarized the classifications and specific criteria in the table below to make it easier to understand:
Dora major incident classification
| Classification criteria | Explanation | Example |
| Impact on service availability | Disruption significantly affects critical services provided to clients or market participants. | A payment processing system outage affecting more than 50% of transactions during peak hours. |
| Impact on financial stability | The incident poses a risk to the stability of financial markets or systemic institutions. | A trading platform error causing market-wide mispricing of financial instruments. |
| Impact on customer data | Breach of sensitive customer data, especially if affecting a large number of individuals or high-risk information. | Unauthorized access to account information for 10,000+ customers. |
| Duration of the incident | Prolonged disruptions that exceed predefined thresholds for recovery time objectives (RTOs). | A ransomware attack rendering systems inoperable for 72 hours. |
| Cross-border implications | Incidents affecting operations across multiple jurisdictions or regulatory authorities. | A distributed denial-of-service (DDoS) attack on a multinational bank’s ICT infrastructure. |
| Operational or reputational risk | Incidents likely to harm the institution’s reputation or operational capabilities. | A phishing attack resulting in fraudulent payments worth millions being processed. |
What defines a non-major incident?
A non-major incident is a disruption that, while it requires attention, does not meet the thresholds set for major incidents. These incidents may involve localized issues, minimal financial impact, or brief interruptions that are quickly resolved.
Criteria for non-major incidents:
- Limited financial loss or negligible customer impact.
- Minimal disruption to services or short system downtime.
- No exposure of sensitive data or critical security breaches.
Example in practice: A financial institution experienced a temporary outage of an internal reporting tool that did not affect customer-facing systems. While inconvenient for employees, the incident was contained and resolved within two hours, making it a non-major incident that did not require external reporting.
The distinction between major and non-major incidents ensures that resources are allocated efficiently, and regulatory reporting is focused on disruptions with significant implications. Misclassifying a major incident as non-major—or vice versa—can lead to compliance failures, delayed responses, or unnecessary regulatory scrutiny.
To streamline this process, many organizations rely on automation tools, such as CyberUpgrade, to assess incidents against DORA’s thresholds. These tools help ensure consistent, accurate classification and prevent errors that could escalate into regulatory challenges. Let’s talk more about automation below.
The role of automation in incident classification
One of the most common barriers to effective incident classification is the manual effort involved. Teams are overwhelmed, data is scattered, and decisions are delayed. This is where automation tools like CyberUpgrade shine.
When we implement an automated classification system, our clients often see an immediate difference. The platform quickly flags incidents, calculates thresholds, and recommends responses based on DORA guidelines. For example, during a subsequent phishing attack that affected internal systems but didn’t compromise customer data, the system correctly classified it as non-material. The team was able to focus on remediation without the burden of unnecessary regulatory reporting.
To put it simply, automation ensures consistency and removes the guesswork from classification. It’s not about replacing human expertise but augmenting it with actionable insights and compliance-aligned workflows.
Building a resilient culture around incident classification
The success of DORA compliance doesn’t rest solely on automation—it requires a cultural shift. Teams need to view incident classification as a core part of operational resilience, not just another compliance requirement.
Training plays a pivotal role here. At CyberUpgrade, we encourage clients to conduct regular simulation exercises. One client simulated a scenario involving a ransomware attack on third-party vendors, testing their ability to classify and respond. The exercise revealed gaps in their communication and reporting protocols, which we helped them address.
Moreover, fostering collaboration across IT, compliance, and business units ensures a unified approach. DORA’s classification framework becomes more than a checklist—it becomes a shared language that bridges silos and strengthens organizational resilience.
Are you prepared to classify and conquer?
DORA incident classification is more than a regulatory mandate; it’s a strategic advantage. The ability to quickly and accurately classify disruptions reduces downtime, protects your reputation, and keeps regulators on your side.
As the financial client’s story demonstrates, adopting a clear framework, supported by automation and training, can transform your response to ICT disruptions. The question is: Is your organization ready to embrace the DORA framework and build a resilient future?
