DORA Compliance Services
Build Digital Systems That Don't Break Easily
Operational disruptions aren't just setbacks—they can disrupt entire financial systems. In an increasingly interconnected digital economy, financial institutions must be prepared to withstand ICT disruptions and recover fast. The Digital Operational Resilience Act (DORA) brings mandatory rules for financial entities across the European Union, establishing a comprehensive framework for digital operational resilience. The aim is simple but urgent: build digital systems that don't break easily, and if they do, can recover fast. DORA applies to over 22,000 financial entities across the EU including banks, investment firms, insurance companies, payment service providers, crypto-asset service providers, and critical ICT third-party service providers. With full application from January 17, 2025, and significant penalties for non-compliance, financial organizations must act now to achieve DORA compliance. At Glocert International, we offer comprehensive DORA compliance assessment services to help financial institutions meet EU requirements, strengthen digital infrastructure, manage ICT risks, enhance incident response capabilities, and build trust by proving your systems can handle pressure. Partner with Glocert International to navigate DORA requirements, implement robust operational resilience frameworks, and ensure your organization is prepared for the digital challenges of modern financial services.
What is EU DORA?
DORA is a regulatory framework from the European Union that ensures financial organizations can handle ICT (Information and Communication Technology) disruptions such as cyber threats, system failures, and third-party breakdowns. Adopted by the European Parliament and Council in November 2022 (Regulation (EU) 2022/2554), DORA establishes uniform requirements for the security of network and information systems of financial entities and critical ICT third-party service providers.
DORA looks at everything: risk controls, how incidents are reported, how systems are tested, and how outsourced technology is managed. Resilience is no longer optional—it's the standard. The regulation aims to consolidate and upgrade ICT risk requirements scattered across various EU financial services legislation, creating a comprehensive and consistent framework for digital operational resilience.
Why Was DORA Created?
The financial sector's increasing reliance on digital technologies and third-party ICT service providers has created new vulnerabilities and systemic risks. Recent years have seen numerous cyberattacks, system outages, and third-party failures affecting financial institutions, highlighting gaps in operational resilience. DORA addresses these challenges by:
- Creating harmonized ICT risk management requirements across all EU financial sectors
- Establishing mandatory incident reporting frameworks for cyber and ICT-related events
- Requiring regular resilience testing including advanced threat-led penetration testing
- Bringing critical ICT third-party service providers under direct regulatory oversight
- Ensuring financial entities can continue operations during and after severe ICT disruptions
Who Must Comply with DORA?
DORA applies to a broad range of financial entities and ICT service providers:
- Credit Institutions: Banks and lending institutions
- Investment Firms: Brokerage firms and investment banks
- Payment Institutions and E-Money Institutions: Payment service providers
- Crypto-Asset Service Providers: Organizations offering crypto services
- Central Securities Depositories: Organizations maintaining securities accounts
- Trading Venues: Stock exchanges and multilateral trading facilities
- Trade Repositories: Data repositories for derivatives
- Insurance and Reinsurance Undertakings: Insurance companies
- Insurance Intermediaries: Insurance brokers and agents
- Institutions for Occupational Retirement Provision: Pension funds
- Credit Rating Agencies: Organizations rating creditworthiness
- Administrators of Critical Benchmarks: Organizations administering financial benchmarks
- Crowdfunding Service Providers: Platforms facilitating crowdfunding
- Securitisation Repositories: Repositories for securitization data
- Critical ICT Third-Party Service Providers: Cloud providers, data centers, and other ICT suppliers designated as critical
The regulation covers over 22,000 financial entities across the EU. Small financial entities with fewer than 10 employees and limited balance sheets may benefit from simplified requirements under the principle of proportionality.
DORA Timeline and Application
Key dates for DORA compliance:
- January 16, 2023: DORA entered into force
- January 17, 2025: DORA becomes fully applicable (all requirements must be met)
- January 17, 2025: First submission deadline for registry of contractual arrangements
- Ongoing: Continuous compliance including incident reporting, testing, risk management, and oversight
Why DORA Compliance Matters
DORA compliance is essential for financial institutions operating in or serving the European Union:
1. Regulatory Mandate and Legal Compliance
DORA is a directly applicable EU Regulation, meaning it has the force of law across all EU member states without requiring national implementation legislation. Non-compliance can result in administrative penalties and fines determined by national competent authorities, potential restrictions on business activities or operations, reputational damage with regulators and customers, loss of licenses or authorizations to operate, and increased supervisory scrutiny and oversight. Competent authorities have extensive powers to investigate and sanction non-compliance, making adherence to DORA mandatory, not optional.
2. Systemic Risk Reduction
The financial sector is highly interconnected, and ICT failures at one institution can create cascading effects across the system. DORA compliance helps reduce systemic risk by ensuring all financial entities maintain minimum standards for digital operational resilience, implementing robust ICT risk management frameworks, establishing effective incident response and recovery capabilities, managing third-party ICT dependencies proactively, and conducting regular testing to identify and address vulnerabilities. By raising the baseline resilience of the entire financial sector, DORA protects the stability of European financial markets.
3. Protection Against Cyber Threats
Cyberattacks on financial institutions have increased in frequency, sophistication, and impact. Recent incidents include ransomware attacks disrupting operations, data breaches exposing customer information, distributed denial-of-service (DDoS) attacks preventing access to services, supply chain attacks compromising third-party providers, and advanced persistent threats (APTs) stealing sensitive financial data. DORA's comprehensive approach to ICT risk management, mandatory resilience testing including threat-led penetration testing (TLPT), and incident reporting requirements significantly strengthen defenses against cyber threats and improve detection and response capabilities.
4. Third-Party Risk Management
Financial institutions increasingly rely on external ICT service providers for critical functions including cloud computing, data storage, payment processing, and software services. This creates concentration risk and potential single points of failure. DORA addresses third-party risk through mandatory contractual provisions for ICT service agreements, requirements to maintain registers of third-party arrangements, direct oversight framework for critical ICT third-party providers, and obligations to assess and monitor third-party risk continuously. These requirements help financial entities manage dependencies and maintain control over outsourced critical functions.
5. Business Continuity and Operational Stability
ICT disruptions can cause immediate operational impacts including inability to process transactions, loss of access to critical systems and data, customer service interruptions, regulatory reporting failures, and financial losses from downtime. DORA compliance ensures organizations develop comprehensive business continuity and disaster recovery plans, establish recovery time objectives (RTOs) and recovery point objectives (RPOs) for critical functions, conduct regular testing of continuity and recovery capabilities, and maintain communication plans for stakeholders during disruptions. This preparation minimizes operational disruption and enables faster recovery when incidents occur.
6. Customer Trust and Competitive Advantage
Customers increasingly evaluate financial institutions based on their cybersecurity and operational resilience. DORA compliance demonstrates commitment to protecting customer data and services, ability to maintain operations during disruptions, investment in robust ICT infrastructure and security, transparency in risk management and incident handling, and readiness to meet evolving digital challenges. In a competitive market, demonstrated operational resilience becomes a differentiator, supporting customer acquisition and retention.
7. Alignment with International Standards
DORA aligns with and complements international frameworks and standards including ISO 27001 for information security management, NIST Cybersecurity Framework, TIBER-EU (Threat Intelligence-Based Ethical Red Teaming), and Bank for International Settlements (BIS) principles for operational resilience. Organizations that achieve DORA compliance build capabilities applicable to global operations and other regulatory requirements, creating efficiency in multi-jurisdictional compliance programs.
Our DORA Compliance Services
Glocert International provides comprehensive DORA compliance assessment services to help financial institutions achieve and maintain compliance with EU Digital Operational Resilience Act requirements.
Pre-Assessment
Conduct an initial assessment to determine whether the current process meets the requirements of DORA standards and frameworks.
Scope Identification
Identify the scope to understand inclusions and exclusions, which establishes boundaries, supports goal achievement, and provides a clear path to success.
Policy and Procedure Development
Ensures a streamlined workflow, aligning processes to achieve goals while maintaining efficiency and quality in accordance with DORA requirements.
Technical Solutions Improvement and Implementation
Identify, develop, and implement solutions to meet DORA requirements, improving and optimizing them to remain effective and aligned with regulatory standards.
Training and Awareness
Provide training to boost skills, awareness, and understanding of handling tasks, managing ICT risks, and applying best methods to improve processes and meet DORA framework requirements.
Audit and Assessment
Conduct an audit to examine compliance with DORA requirements and provide an assessment report that includes compliance evaluation and improvement areas.
Continuous Improvement
Ensure constant process improvement to enhance outcomes, drive efficiency, and maintain overall performance in digital operational resilience.
The Five Pillars of DORA
DORA is structured around five main pillars that establish comprehensive requirements for digital operational resilience:
Pillar 1: ICT Risk Management (Chapter II)
Financial entities must establish and maintain a comprehensive ICT risk management framework covering:
- ICT risk identification, classification, and assessment
- Implementation of protection and prevention measures
- Detection mechanisms for ICT-related incidents
- Response and recovery procedures including business continuity plans
- Learning and evolving capabilities based on incidents and testing
- Communication and information sharing on cyber threats
Pillar 2: Incident Reporting (Chapter III)
Financial entities must report ICT-related incidents to competent authorities using a standardized framework:
- Initial notification: Within 4 hours of classification as major incident
- Intermediate report: Not later than 72 hours after initial notification, with updates if status changes significantly
- Final report: Within one month of intermediate report, providing detailed root cause analysis and impact assessment
- Voluntary reporting of significant cyber threats
Pillar 3: Digital Operational Resilience Testing (Chapter IV)
Financial entities must conduct regular testing to assess operational resilience:
- Comprehensive program of testing including vulnerability assessments, scenario-based testing, and penetration testing
- Advanced testing: Threat-Led Penetration Testing (TLPT) for entities identified by authorities (at least every 3 years)
- Testing of ICT business continuity plans and response and recovery procedures
- Testing frequency based on risk profile and criticality
- Remediation plans for identified weaknesses
Pillar 4: ICT Third-Party Risk Management (Chapter V, Section I)
Financial entities must manage risks from ICT third-party service providers:
- Maintain register of all ICT third-party service provider arrangements
- Due diligence and risk assessment before entering contracts
- Mandatory contractual provisions including audit rights, security requirements, notification obligations, and exit strategies
- Continuous monitoring of third-party performance and risk
- Management of concentration risk and critical dependencies
- Notification to competent authorities of significant arrangements
Pillar 5: Information Sharing and Cooperation (Chapter V, Section II)
DORA establishes frameworks for information sharing on cyber threats and vulnerabilities:
- Financial entities may exchange information on cyber threats, vulnerabilities, and incidents
- Information sharing arrangements must have governance frameworks and protection of data confidentiality
- Cooperation between financial entities and competent authorities
- Cross-border cooperation among supervisory authorities
Benefits of EU DORA Compliance:
Better IT Disruption Handling
Handle IT disruptions better with smart risk management and regular testing to identify and address vulnerabilities proactively.
Structured ICT Risk Management
Manage ICT risks through structured risk management frameworks and comprehensive resilience testing programs.
Enhanced Incident Response
Enhance the capabilities to respond to incidents and effectively manage ICT disruptions with standardized reporting and recovery procedures.
Build Customer Trust
Build trust by proving your systems can handle pressure and maintain operations during severe disruptions.
How to Achieve DORA Compliance
Here is a general overview of the key steps your organization should follow to achieve DORA compliance:
Pre-Assessment
Conduct an initial assessment to determine whether the current process meets the requirements of standards or frameworks.
Scope Identification
Identify the scope to understand inclusions and exclusions, which establishes boundaries, supports goal achievement, and a clear path to success.
Policy Development
Ensures a streamlined workflow, aligning processes to achieve goals while maintaining efficiency and quality.
Technical Implementation
Identify, develop, and implement solutions to meet requirements, improving and optimizing them to remain effective and aligned.
Training & Awareness
Provide training to boost skills, awareness, and understanding of handling tasks, managing risks, and applying best methods.
Audit & Assessment
Conduct an audit to examine compliance with framework requirements and provide an assessment report with evaluation and improvements.
Continuous Improvement
Ensure constant process improvement to enhance outcomes and drive efficiency and overall performance.
General Audit and Assessment Process for DORA Compliance
Glocert International follows a comprehensive three-phase approach to DORA compliance assessment:
Phase 1: Audit Planning
Phase 2: Audit & Assessment
Phase 3: Audit Reporting & Attestation
DORA Compliance Pricing
Our DORA compliance assessment pricing is transparent and based on your organization's size, complexity, and current resilience maturity. We offer competitive rates with no hidden fees.
Request a Quote
Get a personalized estimate based on your organization's ICT environment, third-party dependencies, and compliance readiness.
Contact Us for PricingWhat's Included in DORA Assessment Pricing:
- Initial scoping and applicability determination
- Comprehensive assessment against all five DORA pillars
- ICT risk management framework evaluation
- Incident reporting process review
- Digital resilience testing program assessment
- Third-party ICT risk management evaluation
- Review of contractual arrangements with ICT providers
- Gap analysis and compliance roadmap
- Detailed assessment report with findings and recommendations
- Attestation by CISA certified auditor
- Post-assessment consultation and guidance
Note: DORA compliance pricing varies based on organization type and size, complexity of ICT environment, number of critical ICT third-party providers, current operational resilience maturity, geographic scope across EU, and whether remediation support is needed. Contact us for a detailed, no-obligation quote tailored to your specific needs.
Frequently Asked Questions (FAQ)
Find answers to common questions about DORA compliance:
DORA (Digital Operational Resilience Act) is EU Regulation 2022/2554 establishing uniform requirements for the security of network and information systems of financial entities and critical ICT third-party service providers. It was created to address the financial sector's increasing reliance on digital technologies and third-party ICT providers, which has created new vulnerabilities and systemic risks. DORA consolidates and upgrades ICT risk requirements scattered across various EU financial legislation, creating a comprehensive framework for digital operational resilience. The regulation applies to over 22,000 financial entities and becomes fully applicable on January 17, 2025.
DORA applies to a broad range of financial entities operating in the EU including credit institutions (banks), investment firms, payment and e-money institutions, crypto-asset service providers, insurance and reinsurance companies, trading venues, central securities depositories, pension funds, credit rating agencies, crowdfunding platforms, and critical ICT third-party service providers. If your organization falls into any of these categories and operates in or serves the EU market, DORA likely applies. Small financial entities (fewer than 10 employees and limited balance sheets) may benefit from simplified requirements under proportionality principles. Glocert International can help assess DORA applicability to your specific organization.
DORA is structured around five main pillars: 1. ICT Risk Management: Comprehensive framework for identifying, assessing, and managing ICT risks. 2. Incident Reporting: Mandatory reporting of major ICT-related incidents to authorities within specific timeframes (4 hours initial, 72 hours intermediate, 1 month final). 3. Digital Operational Resilience Testing: Regular testing including vulnerability assessments, scenario-based testing, penetration testing, and Threat-Led Penetration Testing (TLPT) for designated entities. 4. ICT Third-Party Risk Management: Managing risks from ICT service providers including contractual requirements, registers of arrangements, and oversight of critical providers. 5. Information Sharing: Frameworks for sharing information on cyber threats and vulnerabilities among financial entities and with authorities.
DORA entered into force on January 16, 2023, and becomes fully applicable on January 17, 2025. This means all financial entities in scope must comply with DORA requirements by that date. Key compliance milestones include having ICT risk management frameworks in place, establishing incident reporting capabilities, implementing testing programs, maintaining registers of third-party ICT arrangements, and ensuring contractual agreements with ICT providers include mandatory DORA provisions. The first submission deadline for the registry of contractual arrangements is also January 17, 2025. Organizations should begin compliance efforts now, as achieving full DORA compliance typically requires 12-24 months depending on current maturity.
DORA grants competent authorities extensive investigation and enforcement powers. While DORA itself doesn't specify exact penalty amounts (leaving this to national implementation), authorities can impose administrative penalties proportionate to the breach, potentially restrictions on business activities or operations, orders to cease certain practices or activities, suspension or withdrawal of authorizations, public statements identifying responsible persons and nature of breach, and increased supervisory oversight and monitoring. National competent authorities will determine specific penalty regimes within their jurisdictions. Beyond regulatory penalties, non-compliance can result in operational disruption from unmanaged ICT risks, reputational damage with regulators and customers, loss of competitive position, and potential systemic consequences affecting the broader financial sector. The costs of non-compliance significantly exceed the investment in achieving compliance.
Threat-Led Penetration Testing (TLPT) is advanced testing simulating real-world cyber attacks on an organization's critical live production systems. TLPT is based on the TIBER-EU framework developed by the European Central Bank. Under DORA, competent authorities will identify financial entities required to conduct TLPT at least every three years. TLPT involves threat intelligence gathering on relevant threat actors and attack scenarios, red team testing by ethical hackers attempting to breach systems, blue team response (organization's security team responding to attacks without knowing it's a test), and comprehensive reporting on vulnerabilities and defensive capabilities. TLPT goes beyond traditional penetration testing by using intelligence-driven scenarios specific to the financial sector and testing entire attack chains from initial access to achieving objectives. Organizations designated for TLPT must use testers meeting DORA requirements and follow the European framework for testing, ensuring consistent high-quality assessments.
DORA mandates specific provisions in contractual arrangements with ICT third-party service providers: Service level agreements (SLAs) with performance targets, security requirements and controls the provider must implement, audit rights allowing financial entity and competent authorities to inspect provider, notification obligations for incidents affecting services, subcontracting conditions requiring approval for critical functions, data location and cross-border data transfer restrictions, exit strategies enabling orderly termination and transition, business continuity and disaster recovery requirements, liability provisions and indemnification clauses, and information security policies and access controls. Financial entities must maintain a register of all ICT third-party contractual arrangements and provide information on critical or important arrangements to competent authorities. Existing contracts should be reviewed and amended to include DORA-required provisions before January 17, 2025.
DORA complements but is distinct from other EU regulations: DORA vs. NIS2 Directive: DORA is lex specialis (sector-specific law) for financial entities, taking precedence over the general NIS2 Directive. Financial entities complying with DORA are deemed compliant with NIS2 cybersecurity requirements. However, NIS2 may apply to ICT third-party providers serving financial sector. DORA vs. GDPR: DORA focuses on operational resilience and ICT risk management; GDPR focuses on personal data protection and privacy. Both regulations apply simultaneously. DORA incident reporting doesn't replace GDPR breach notification—both may be required. DORA vs. PSD2: Payment service providers must comply with both DORA operational resilience requirements and PSD2 strong customer authentication and security requirements. Synergies: Many DORA requirements (risk management, incident response, third-party management, security testing) align with and support compliance with other frameworks including ISO 27001, NIST CSF, and SOC 2. Organizations can leverage integrated compliance programs to maximize efficiency.
DORA establishes a new Oversight Framework bringing critical ICT third-party service providers under direct regulatory supervision—a significant shift from previous indirect oversight through contractual requirements. The European Supervisory Authorities (ESAs) will designate ICT third-party service providers as critical based on systemic impact if a failure occurred, number of financial entities relying on the provider, global market share and alternatives, complexity of services, and dependencies within financial sector. Designated critical providers must register with Lead Overseer from ESAs, undergo general investigations and inspections by authorities, provide information and documentation on request, comply with recommendations and requests from overseers, and pay supervisory fees. This framework addresses concentration risk in cloud computing and other ICT services where few large providers serve many financial entities. Major cloud providers (AWS, Microsoft Azure, Google Cloud) and other significant ICT service providers are expected to be designated as critical, subjecting them to direct EU financial services regulation for the first time.
Glocert International provides comprehensive DORA compliance services including: Pre-assessment determining current compliance status against DORA requirements, Scope identification establishing boundaries and applicability, Policy and procedure development creating DORA-aligned ICT risk management frameworks, Technical solutions implementation identifying and deploying required controls and capabilities, Training and awareness programs for staff on DORA requirements and ICT resilience, Comprehensive audits and assessments evaluating compliance across all five DORA pillars, Attestation services providing formal compliance validation by CISA-certified auditors, and Continuous improvement support for ongoing compliance maintenance. Our team brings expertise in financial services regulation, ICT risk management, operational resilience frameworks, and EU regulatory requirements. We serve as your partner in achieving and maintaining DORA compliance, helping you build digital operational resilience, manage third-party risks effectively, and meet the January 2025 compliance deadline.
Why Choose Glocert for DORA Compliance?
Expert Financial Services Compliance
Glocert International specializes in compliance assessment services for financial institutions, helping organizations navigate complex regulatory requirements including DORA. Our team has deep expertise in EU financial services regulation, digital operational resilience frameworks, ICT risk management best practices, and regulatory technology implementation. We provide comprehensive DORA compliance assessments, gap analysis, remediation roadmaps, policy development, training programs, and attestation services certified by CISA auditors to ensure your organization meets all DORA requirements by the January 2025 deadline.
Operational Resilience Expertise
Our team includes certified professionals with expertise in operational resilience frameworks and standards, ICT risk management and business continuity, cybersecurity and threat intelligence, third-party risk management, incident response and recovery, resilience testing including penetration testing and TLPT, and financial sector technology and infrastructure. We've conducted resilience assessments for banks, investment firms, insurance companies, payment service providers, and other financial entities. Our financial services focus ensures we understand the unique challenges of implementing operational resilience in regulated financial environments while maintaining business operations.
Comprehensive Service Portfolio
Glocert International offers complete DORA compliance services including pre-assessment and gap analysis, scope identification and applicability determination, ICT risk management framework development, incident reporting process design, resilience testing program establishment, third-party ICT risk management implementation, policy and procedure development, technical solution identification and implementation, staff training and awareness programs, comprehensive compliance audits and assessments, attestation by CISA certified auditors, and continuous improvement and monitoring support. We also provide ISO 27001 certification, SOC 2 audits, and NIST 800-171 compliance, allowing integrated compliance programs that maximize efficiency.
Proven Methodology and Best Practices
We follow a proven three-phase approach to DORA compliance: audit planning with business context understanding and scope confirmation, comprehensive assessment with evidence collection and control testing, and detailed reporting with attestation by certified auditors. Our methodology aligns with international best practices and regulatory expectations, ensuring thorough evaluation of all DORA requirements across the five pillars. We provide actionable recommendations prioritized by risk and impact, realistic implementation roadmaps considering business constraints, and ongoing support for continuous compliance maintenance. Our pragmatic approach balances regulatory requirements with operational realities, helping you build sustainable operational resilience programs.
Related Services
Financial institutions subject to DORA often need additional compliance services. Glocert International also provides ISO 27001 certification for information security management, SOC 2 audits for security and availability controls, GDPR compliance for data protection, PCI DSS compliance for payment card security, and penetration testing and vulnerability assessment services. We can coordinate multiple engagements to maximize efficiency, leverage shared evidence and controls, and provide comprehensive risk management and compliance validation supporting both EU and global regulatory requirements.
Unlock the Full Potential of Your Organization
Contact us today to learn more about our DORA compliance services and how we can help you achieve digital operational resilience excellence and meet EU regulatory requirements.
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