Demystifying DORA Compliance on the culture of an Organization


Digital Operational Resilience refers to the ability of a financial entity to ensure the operational integrity of its technological systems. This encompasses the organization's capability, whether through its own resources or with the assistance of third-party ICT service providers, to maintain the full range of ICT-related capabilities necessary to secure the network and information systems supporting the provision of financial services. The term "security of network and information systems" is defined as the system's ability to withstand actions that compromise the availability, authenticity, integrity, or confidentiality of stored, transmitted, or processed data, as well as the associated services accessible through those systems.  

Within the context of digital operational resilience, a major ICT-related incident refers to an incident with the potential for significant adverse impact on the network and information systems critical to the functioning of the financial entity.  

ICT third-party service providers play a crucial role by offering digital and data services, which can include cloud computing, software solutions, data analytics, and data center services.  

ICT concentration risk refers to the exposure or dependency on specific critical ICT third-party service providers, either individually or in a related manner, that could create potential risks for the financial entity. Addressing these risks and ensuring digital operational resilience is a vital aspect of compliance with the DORA regulation.

Impact of DORA on the Cybersecurity Culture of an Organization

The implementation of DORA has a significant impact on the cybersecurity culture of an organization. It encourages three key areas of change that play a crucial role in strengthening cybersecurity resilience.

  1. Business process-led approach - DORA emphasizes a business process-led approach to cyber risk assessment. This means organizations are required to assess and evaluate their cybersecurity risks in the context of their overall business processes. By aligning cybersecurity with business objectives, organizations gain a holistic understanding of their risk landscape, enabling them to prioritize and allocate resources effectively.
  1. Proactive risk management: DORA promotes proactive cyber risk management. Instead of solely focusing on incident response and mitigation, organizations are encouraged to take a proactive stance in identifying and addressing potential risks. This proactive approach involves implementing preventive measures, threat intelligence analysis, and adopting security best practices to assess, prioritize and mitigate risks before they manifest into actual incidents.
  1. Continuous risk management: DORA emphasizes the importance of continuous risk assessment with an audit trail. Organizations are required to regularly assess and reassess their cybersecurity risks to ensure ongoing compliance and resilience. This involves maintaining a comprehensive audit trail that documents risk assessment processes, risk mitigation strategies, and any changes made to enhance cybersecurity measures.  

By encouraging these three key areas of change, DORA compels organizations to adopt a more robust and comprehensive approach to managing their cybersecurity posture. It necessitates the development and maintenance of resilient systems and controls that can withstand and recover from cyber incidents. Moreover, DORA promotes a proactive and continuous risk management mindset, enabling organizations to stay ahead of emerging threats and ensure the overall resilience of their operations.

Key Cybersecurity Controls for DORA Compliance

There are the following six areas of focus under DORA

  1. Cybersecurity Governance: DORA places a strong emphasis on cybersecurity governance, with senior management playing a critical role. This control requires organizations to establish a robust governance framework, define policies and procedures, and assign accountability for ICT risk management. It involves defining roles, conducting risk assessments, and implementing appropriate security controls to ensure effective cybersecurity governance.
  1. Risk Management: DORA mandates a comprehensive risk management approach for ICT-related risks. This control includes implementing the 3LOD (Three Lines of Defense model) for ICT risk management, developing a digital resilience strategy, and setting risk tolerance levels for ICT risks and disruptive events. It involves regular risk assessments, vulnerability management, threat intelligence analysis, and mitigation measures to address identified risks.
  1. ICT Incident Reporting: DORA requires organizations to establish processes for consistent detection and handling of ICT-related incidents. It outlines specific requirements for initial, intermediate, and final notification of incidents. Additionally, DORA establishes a single EU Hub for reporting major ICT-related incidents, ensuring effective communication and coordination in response to significant incidents.
  1. Testing and Monitoring: DORA emphasizes a risk-based approach to testing and monitoring. This control encompasses various aspects such as penetration testing, physical security reviews, scenario-based tests, and end-to-end resilience testing. Organizations are required to conduct these assessments regularly to identify vulnerabilities, test response capabilities, and ensure the effectiveness of their cybersecurity measures.
  1. Vendor and Third-Party Risk Management: DORA mandates a comprehensive approach to managing vendor and third-party risks. Organizations must identify, assess, and report critical or important functions performed by service providers. This control also includes analyzing potential concentration risks, particularly when using providers in third countries. DORA provides specific requirements and guidelines to ensure robust vendor and third-party risk management practices.
  1. Information Sharing: DORA encourages entities to share cyber threat information and intelligence. This control emphasizes the importance of sharing indicators of compromise, tactics, techniques, and procedures to enhance collective cybersecurity defenses. By fostering information sharing, DORA aims to improve situational awareness and facilitate a proactive response to emerging cyber threats.


In summary, DORA holds great importance in the realm of cybersecurity and operational resilience for financial entities. It introduces comprehensive measures to enhance the management of cyber risks, promote information sharing, and foster a proactive approach to cybersecurity. By harmonizing rules and regulations at the EU level, DORA aims to streamline the operational resilience and cybersecurity requirements across the financial industry. Its focus on business process-led cyber risk assessment, and proactive & continuous risk management including the third parties signifies a shift towards a more resilient and secure digital landscape. DORA serves as a catalyst for financial entities to prioritize cybersecurity, strengthen their defenses, and collaborate in sharing vital information to combat cyber threats effectively.

Technology plays a crucial role in streamlining the implementation and compliance with DORA regulation. Automation and integration technologies can be leveraged to facilitate robust cyber risk assessment, incident management, and reporting processes. By embracing automation, financial entities can efficiently assess their cybersecurity posture, model risks, and respond proactively to them. By leveraging technology tools and solutions, financial entities can streamline their operations, enhance their cybersecurity capabilities, and meet the rigorous demands of DORA, ultimately fostering a safer and more resilient digital environment for the financial industry.

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The Seven Steps to Automating Cyber Risk
Michael Rasmussen
The GRC Pundit & Analyst
Aug 29
1400 GMT
0700 PT