A Complete Guide to the Digital Operational Resilience Act (DORA)

Trying to understand DORA? Think of it like this: The Digital Operational Resilience Act (DORA) sets a clear framework of regulatory technical standards to ensure that financial institutions and their ICT service providers remain resilient against cyber threats, technology failures and other operational risk oversights. With the growing dependence on technology, the ability to maintain operations through disruptions is a critical business capability.

However, DORA isn’t just about compliance—it’s about creating holistic, sustainable risk management strategies that empower organisations to thrive. At its core, it aligns with the modern enterprise’s need for critical infrastructure protection. This regulation will impact organisations across the EU—and beyond—including firms in the UK that operate or engage with the European market.

Whether you are a CISO, Compliance Manager, or Risk Officer, your role involves staying ahead of evolving regulations. The regulation provides both a challenge and an opportunity to protect your organisation and position it as a trusted industry leader. Early adoption of the framework offers a competitive advantage—enhancing resilience, reducing risk and ensuring business continuity.

The Benefits of Proactive Compliance:

• Strengthen operational resilience across the organisation
• Foster collaboration between departments to meet regulatory demands
• Build trust with stakeholders, customers and regulators
• Position the firm to navigate multiple regulatory environments effectively

Who Needs to Comply with DORA?

DORA harmonises the rules on digital operational resilience for the financial sector, applying to 21 different types of financial entities, of which 12 are in the remit of the European Securities and Markets Authority (ESMA). These entities include Account Information Service Providers, Data Reporting Service Providers, and Alternative Investment Fund Managers. Here are the main groups affected:

Financial Entities

The regulation primarily targets various types of financial institutions, including:

• Banks
• Insurance companies
• Investment firms
• Credit unions
• Payment and e-money institutions
• Cryptoasset firms

ICT Third-Party Service Providers

In addition to financial entities, the regulation extends its reach to critical third-party service providers that supply ICT systems and services to these financial institutions. This includes:

• Cloud service providers
• Data centres
• Credit rating agencies
• Data analytics firms

Notably, even non-EU based ICT providers that operate within the EU must comply, which may require them to establish a subsidiary in the EU for effective governance.

Need a further breakdown? All entities covered by the regulation include:

Components of DORA: The Five Pillars of the Regulation

The requirements are broken down across five pillars. EU firms can choose their starting point for resilience development, but this doesn’t imply independence among the five pillars. For instance, defining critical functions and mapping ICT systems are essential initial steps that influence other requirements.

Pillar 1: ICT Risk Management Framework:

Firms must implement robust ICT frameworks to manage risks. The focus is on identifying vulnerabilities, conducting regular threat assessments and mitigating operational disruptions.

Pillar 2: ICT Incident Reporting Framework:

Financial entities must adopt incident reporting procedures that meet DORA’s strict timelines and requirements. Regulatory Technical Standards (RTS) will specify what qualifies as a reportable ICT incident and how these incidents should be escalated and documented.

Entities should report incidents that are classified as ‘major’ no later than 24 hours from becoming aware of the occurrence.

Find a detailed breakdown of incident classification and requirements, read our blog post: Understanding DORA’s Regulatory Technical Standards.

Pillar 3: Operational Resilience Testing

This pillar (a Risk Crew personal favourite) emphasises ongoing advanced penetration testing to ensure that financial institutions and their ICT systems can withstand cyber threats and operational disruptions.

The scope of required testing will vary based on your risk profile. It may include security vulnerability assessment, secure application code testing, physical security evaluations, and Threat-Led Penetration Testing (TLPT). Red Team Testing, where applicable, must adhere to the TIBER-EU framework to simulate advanced cyber threats.

Pillar 4: Managing ICT Third-Party Risk

Continuous oversight of critical suppliers is essential to maintain operational resilience throughout the supply chain. Many financial institutions rely heavily on third-party ICT providers; therefore, institutions are required to evaluate and manage risks arising from outsourced services.

Read more about the third-party risk assessment requirements.

Pillar 5: Information and Intelligence Sharing

The final pillar of DORA encourages the sharing of cyber threat intelligence and vulnerability information across organisations. By fostering collaboration, entities can leverage collective knowledge and experience to strengthen their ability to anticipate and respond to digital threats.

How will the Regulation Impact the UK?

The regulation will have a big impact on UK companies, especially those in the financial sector and their ICT service providers.

Direct Impacts on UK Businesses:

• Applicability: Any UK financial institution that operates in the EU or serves EU customers will need to follow DORA’s rules. ICT providers working with these institutions must also meet the standards due to their contractual obligations.
• Increased Budgets: Compliance will incur expenses. UK businesses will likely face significant expenses to upgrade risk management frameworks, boost cyber security, and potentially renegotiate contracts to align with the new requirements.

For more details read the full article on the Essential Information | The DORA Regulation in the UK.

Key Deadlines: The Digital Operational Resilience Act Timeline

Staying on top of the timelines is critical to meet obligations without disruption. Firms operating in or interacting with the EU financial markets must prioritise compliance milestones to avoid penalties and operational risks. Below is a breakdown of the deadlines and phases for implementation.

How to Build a DORA Compliance Roadmap

Creating a structured compliance roadmap is essential for achieving and maintaining operational resilience. Risk Crew recommends that your roadmap should be outlined as follows:

1. Conduct a Compliance Gap Assessment – Begin by identifying gaps between your current ICT risk management framework and the requirements
2. Define Milestones and Deadlines – Map out activities like incident reporting setup and security penetration testing schedules over a multi-year timeline
3. Assign Ownership and Responsibilities – Create a RACI matrix (Responsible, Accountable, Consulted, Informed) to ensure stakeholder accountability for each compliance task
4. Allocate Budget and Resources – Forecast the financial impact of compliance initiatives, including investments in ICT infrastructure and third-party vendor assessments.
5. Implement Processes for Continuous Monitoring – Build workflows for real-time monitoring of ICT systems aligned with DORA’s continuous oversight requirements. Include third-party vendor risk monitoring to maintain resilience across supply chains.
6. Conduct Stakeholder Training and Workshops – Organise workshops to educate key stakeholders on their roles and ensure everyone understands the roadmap.
7. Review and Refine the Roadmap – Continuously review and adjust the roadmap based on internal performance and regulatory changes.
8. Once you are ready to write your roadmap and strategy, head over to Risk Crew’s blog post for a detailed, step-by-step checklist with key activities, timelines and resources.

Overcoming Challenges in DORA Compliance

Achieving compliance is essential, but it comes with unique challenges that can create roadblocks for even the most prepared organisations. Below are some of the pain points that many are facing and actionable solutions to overcome them.

1. Staying Updated with Evolving Regulatory Compliance Standards

The Challenge: DORA’s regulatory landscape may shift as Regulatory Technical Standards (RTS) evolve over time, which could make it difficult for organisations to stay ahead. Ultimately leading to confusion and compliance gaps.

The Solution:

• Engage GRC compliance experts to ensure continuous alignment with emerging changes
• Follow regulatory updates and monitor RTS developments closely
  • Monitor the official websites of the European Supervisory Authorities (ESAs), such as:
    • European Banking Authority (EBA)
    • European Securities and Markets Authority (ESMA)
    • European Insurance and Occupational Pensions Authority (EIOPA)
  • Set Up Alerts and Track RTS Progress
    • Create Google Alerts for keywords like “DORA RTS updates” or “EBA regulatory standards” to stay notified of new publications

2. Securing Buy-In from Leadership and Stakeholders

The Challenge: CISOs and Compliance Managers often struggle to gain leadership approval for compliance budgets and initiatives, especially when non-technical executives don’t immediately see the benefits.

The Solution:

• Conduct workshops to align compliance goals with business growth and risk mitigation strategies
• Present compliance risks and penalties in business terms, demonstrating how non-compliance could impact reputation and operations
• Offer tangible milestones with budget forecasts to justify financial investment

3. Managing Vendor and Supply Chain Risks

The Challenge: Third-party vendors and service providers can introduce vulnerabilities, making it harder to meet the ICT risk management requirements.

The Solution:

• Implement vendor risk management programs that include third-party assessments and regular monitoring
• Use automated tools to assess vendor risks in real time and ensure alignment with your ICT framework
• Conduct regular penetration testing for critical vendors to confirm their security posture aligns with the regulation

3. Balancing Compliance and Budget Constraints

The Challenge: Many organisations have limited resources for implementing compliance initiatives, including technology investments and ongoing monitoring. Balancing compliance needs with budget realities can be overwhelming.

The Solution:

• Take a phased approach by prioritising high-impact compliance activities first
• Look for cost-effective ISMS solutions, which we specialise in through creative and pragmatic risk management strategies

5. Monitoring and Maintaining Long-Term Compliance

The Challenge: Achieving compliance is not a one and done effect — it requires continuous monitoring and updates to ICT systems, policies and controls.

The Solution:

• Establish automated compliance tracking systems to ensure ongoing monitoring without manual effort
• Create a compliance calendar with scheduled activities, such as audits and vendor assessments, to maintain operational resilience
• Partner with experts like Risk Crew for continuous compliance support — explore our services in more detail on the DORA Compliance page

A Roadmap to Overcoming Challenges

To help keep you focused, here’s a breakdown of the challenges, solutions and outcomes:

Conclusion: Achieving Holistic Operational Resilience

Achieving compliance is more than meeting regulatory requirements — it is about building a culture of continuous resilience. For businesses to thrive in today’s dynamic threat landscape, operational resilience must become a core element of their strategy, ensuring they are prepared to navigate disruptions while maintaining trust, efficiency and security.

DORA serves as a framework that pushes organisations beyond compliance, encouraging long-term ICT risk management that supports business growth.

However, true operational resilience requires a holistic approach that blends compliance with proactive risk management. Organisations that embrace this philosophy not only avoid fines but also gain a competitive advantage by safeguarding their reputation and ensuring operational continuity.k

Where Risk Crew Can Help

At Risk Crew, we believe operational resilience isn’t just about compliance—it’s about enabling businesses to grow without fear of unexpected disruptions. Our Compliance Roadmap ensures that every step of your compliance journey aligns with your broader business goals. Let us help. It’s what we do.

Explore our service:

• DORA Compliance Services: Step-by-step support from assessment to implementation.
• Our Promise & Guarantee: We stand behind every solution we offer with a 100% satisfaction guarantee.

Will You Take the Next Step Toward Resilience?

With compliance deadlines on the horizon, now is the time to take action. A strategically designed compliance roadmap will not only protect your business from regulatory penalties but also position you to adapt and thrive in an increasingly uncertain environment. Partner with Risk Crew, and let us help you turn compliance challenges into lasting operational strength.

“Resilience isn’t a destination — it’s a journey, one that requires a seasoned navigator.” Richard Hollis, CEO – Risk Crew