Table of Contents

Introduction & Why DORA Matters

Digital Operational Resilience Act (DORA) Overview

A DORA compliant ICT risk register is now mandatory for every EU‑regulated bank, insurer, and payments firm under Articles 24‑29 of the Digital Operational Resilience Act (DORA). Its main objectives are to ensure that all participants and their critical ICT providers can withstand, respond to, and recover from disruptive ICT incidents.

DORA requires financial entities to:

Identify and monitor all ICT dependencies: Include both direct (third‑party) and
subcontracted (fourth‑party) relationships.
Assess and document risk: Develop detailed risk ratings, perform resilience tests, and maintain a comprehensive risk register.
Ensure accountability and reporting: Establish clear documentation and reporting to streamline regulatory submissions.

Example: A bank using a cloud provider for core banking may also depend on an outsourced data recovery service from that provider. Both these relationships must be clearly mapped in the register.

Importance of Managing Third‑ and Fourth‑Party ICT Risks

Modern financial services rely on external ICT service providers for critical functions like cloud hosting, cybersecurity, and software development. The interconnected nature of these relationships means that a failure in one link, whether directly contracted (third‑party) or indirectly subcontracted (fourth‑party), can disrupt operations, compromise data integrity, or lead to regulatory sanctions.

Key risk impacts include:

Operational Continuity: Disruption in any part of the supplier chain (e.g., a cloud
provider’s outage) can halt business activities.
Regulatory Compliance: Non‑compliance with DORA can lead to fines, reputational
damage, or business restrictions.
Reputation Management: Visibility of ICT failures can damage client and investor
confidence.

Example: If a managed IT provider (third‑party) hands over server maintenance to a facility management company (fourth‑party), a failure at the subcontractor level might cascade and affect the bank’s data availability.

Benefits of a DORA‑Compliant Register

A robust register centralises and standardises all critical information on external ICT relationships, enabling:

Enhanced transparency and accountability across business functions.
Streamlined regulatory reporting and readiness for audits.
Rapid incident response using up‑to‑date vendor data and risk assessments.
Informed decision‑making during vendor selection and contract reviews.

Regulatory Foundations and Compliance Requirements

Key Provisions of DORA for ICT Risk Management

DORA mandates that financial entities:

Manage ICT Risks: Implement controls over risks from all ICT suppliers, including due diligence, regular monitoring, and incident reporting.
Maintain a Comprehensive Register: Document all ICT-related contracts, service dependencies, risk assessments, and exit strategies.
Implement Governance and Auditability: Ensure clear board‑level accountability and maintain detailed audit trails.

Third‑ versus Fourth‑Party Providers

Third‑Party Providers: Directly contracted companies that deliver ICT services (e.g., cloud hosting, managed security services).
Fourth‑Party Providers: Subcontractors engaged by third‑party providers whose performance can directly affect the primary service.

Example: A bank outsourcing cybersecurity to a vendor (third‑party) that itself subcontracts incident monitoring to a specialist firm (fourth‑party) requires a mapping of both layers.

Consequences of Non‑Compliance

Non‑compliance can expose institutions to:

Regulatory Fines: Sanctions from bodies like the European Supervisory Authorities (ESAs).
Operational Disruptions: Increased vulnerability to outages, cyberattacks, and failures in the extended supply chain.
Reputational Damage: Negative public exposure and erosion of customer trust.
Civil Liability: Potential legal claims resulting from data breaches or service interruptions.

Building a DORA‑Compliant ICT Risk Register Step‑by‑Step

Step 1: Define the Scope

A clear scoping exercise lays the foundation for an effective register by identifying which ICT services and suppliers need documentation.

Identifying ICT Services

Catalogue all essential ICT services, such as cloud platforms, payment processing systems, digital authentication solutions, and outsourced IT helpdesks.
Include every vendor that supports core or mission‑critical functions.

Example: Document a SaaS platform for payments along with its underlying cloud infrastructure and any subcontractors involved in data storage.

Mapping Third‑ and Fourth‑Party Relationships

List all direct suppliers and then trace their subcontractors.
Collaborate with procurement, legal, IT, and risk management teams to gather a complete picture.

Prioritising by Criticality

Critical: Providers that directly support core banking or customer data management.
Important: Providers linked to non‑core but significant functions (e.g., HR software).
Non‑Critical: Vendors with low impact or substitutable services.

Example Categorisation:

Critical: Core IT infrastructure.
Important: Payment gateway software.
Non‑Critical: Social media management tools.

Step 2: Map and Document Relationships

Gathering Essential Vendor Data (RT.01 Series)

Basic identification, such as Legal Entity Identifier (LEI), company registration, and group relationships.
Include data for parent companies, subsidiaries, and affiliates.

Example Table:

Vendor Name	LEI	Service Provided	Legal Details
SoftCom AG	529900T8BM49Q	Cloud Data Hosting	Registered in Germany
NetLink Ltd	213800Q7NGCBP	Payment Processing	Headquartered in France

Documenting Contractual Arrangements (RT.02 Series)

Record key contract details: obligations, terms, renewal dates, and cybersecurity clauses.
Ensure any subcontracting, data localisation, or incident response clauses are explicitly stated.

Example: A contract with a cloud provider must indicate data encryption standards, incident response timelines, and termination rights.

Building the Service Provider Register (RT.03 & RT.04 Series)

Categorise each provider by functionality and risk level.
Map downstream dependencies by linking subcontractors (RT.05 Series).

Visual Example:

graph TD;

A[Financial Institution] –> B[Payments Platform (Third Party)]
B –> C[Cloud Service Provider (Fourth Party)]
B –> D[Software Support Vendor (Fourth Party)]
A –> E[Cybersecurity Provider (Third Party)]

Step 3: Conduct Risk and Criticality Assessments

Establishing Criticality Criteria

Evaluate each ICT provider based on:

Impact on Core Functions: Does the vendor support critical payment systems or data
processing?
Data Volume and Sensitivity: Is regulated or sensitive data handled by the vendor?
Systemic Risk: Could a vendor’s failure affect multiple business units?
Substitutability: Are alternatives available if a vendor fails?

Example: A cloud platform hosting core banking must be classified as “Critical” because its failure could halt all banking operations.

Applying Structured Risk Methodologies

Follow a step‑by‑step risk evaluation process:

Gather Detailed Information: Document services, access levels, and subcontracted dependencies.
Identify Threats: Consider cyberattacks, operational failures, and geopolitical risks.
Assess Vulnerabilities and Impact: Rate the potential damage using a risk matrix.
Determine Likelihood: Use historical data and expert judgment to score frequency.

Example Risk Table:

Provider	Risk Scenario	Impact	Likelihood	Classification
Cloud Vendor A	Service Outage	High	Medium	Critical
Payments ISP B	Data Breach	Medium	Low	Critical
HR SaaS C	Insider Threat	Low	Low	Non‑Critical

Integrating Risk Data into the Register (RT.06 & RT.07 Series)

Link risk assessments to each vendor entry.
Maintain fields such as assessment date, risk owner, and mitigation measures.

Example Register Mapping:

Provider	Service	Criticality	Risks Identified	Mitigating Controls
Cloud Vendor A	Core Banking Hosting	Critical	Service outages, ransomware risk	Redundancy and encryption measures
Payments ISP B	Payment Processing	Critical	Critical Data breach, system compromise	Regular security audits

Step 4: Collect and Document Data for the Register

Essential Data Fields

For each ICT arrangement, record:

Vendor Identification: Vendor name, LEI, registration details.
Service Description: Detailed description of services and criticality.
Contractual Details: Contract IDs, start/end dates, cybersecurity clauses.
Risk Assessments: Summary rating and due diligence outcomes.
Incident History: Past events, remediation steps, and lessons learned.
Fourth‑Party Information: Details of any subcontractors and their roles.

Example Entry:

Vendor Name	LEI	Service	Contract End Date	Criticality	Last Assessment	Past Incidents	Subcontractors
SoftCom AG	529900T8BM49Q	Cloud Data Hosting	2025‑07‑15	High	2024‑01‑10	Data outage 2023‑04	ApexIT (Backup Services)
NetLink Ltd	213800Q7NGCBP	Payments Platform	2026‑01‑31	Medium	2024‑02‑18	None	Zeta3 (Software Patching)

Best Practices in Documentation

Centralised Data: Use robust GRC platforms or a secure SharePoint to ensure only one
version of truth.
Link Evidence: Attach contract scans, risk reports, and audit trails.
Regular Reviews: Schedule routine updates (quarterly or post‑incident) to keep data
current.

Step 5: Integrate Frameworks and Maturity Models

Industry‑Standard Frameworks

Adopt frameworks such as:

NIST Cybersecurity Framework (CSF): Guides risk inventory, control selection, and vendor risk management.
ISO/IEC 27001: Supports systematic information security risk assessments and
contractual requirements.
EBA Guidelines: Provide detailed outsourcing and ICT risk management recommendations tailored for EU financial institutions.

Example: Map the vendor risk assessment process against NIST “Identify” and “Protect” domains, ensuring that each vendor’s data is integrated with the overall security dashboard.

Using Maturity Models for Continuous Improvement

Apply models such as:

CMMI for third‑party risk management: Evaluate your program on levels ranging from Initial to Optimising.
NIST Cybersecurity Maturity Model: Measure implementation consistency and process improvements.

Implementation Tip: If current assessments are informal (CMMI Level 1), standardise risk rubrics to progress towards a “Managed” status (Level 2 or 3).

Register Mapping Example for Framework Adherence

Supplier Name	Criticality	Frameworks Adopted	Maturity Level	Last Assessment	Key Actions
Vendor A	High	NIST CSF, EBA Guidelines	Level 2	2024‑04‑15	Implement formal onboarding
Vendor B	Moderate	ISO 27001	Level 3	2024‑05‑01	Automate vulnerability scanning
Vendor C	Critical	NIST CSF, ISO 27001, EBA	Level 4	2024‑03‑12	Deploy real‑time monitoring

Step 6: Establish Ongoing Monitoring and Maintenance Processes

Continuous Vendor Review and KPI Monitoring

Set Review Frequencies: Critical vendors should be reviewed quarterly; non‑critical vendors, semi‑annually.
Define KPIs and KRIs: Monitor vendor uptime, incident rates, and contract renewal indicators.

Example: An automated tool flags a drop in a vendor’s security score, triggering an immediate review by the risk team.

Automating Alerts and Integrating Early Detection Systems

Deploy Monitoring Tools: Use platforms that integrate with your vendor management system (e.g., Bitsight or SecurityScorecard) for continuous surveillance.
Integrate APIs: Connect the register with procurement and incident reporting systems to ensure live updates.

Scenario: If a vendor’s contract nears expiry without a DORA‑compliant clause update, an automated alert is issued to the relevant department.

Documentation and Audit Trails

Maintain full audit trails: Record every register update, review outcome, and decision rationale.
Centralised records: Host all changes in a secure, access‑controlled system for regulatory inspections.

Step 7: Effective Communication and Stakeholder Engagement

Delivering Clear, Structured Updates

Executive Summaries: Provide leadership with high‑level risk dashboards (e.g., red/yellow/green heatmaps) and summaries of key changes.
Technical Appendices: Offer detailed risk data and contract information for auditors and compliance teams.
Visual Aids: Use charts, graphs, and network maps for clarity.

Example: Quarterly presentations to the board include an executive slide deck summarising critical vendor risks and recent register updates, with detailed appendices for internal audit review.

Engaging Diverse Stakeholders

Compliance Officers: Involve them early in register updates and regular reviews.
Vendors: Clearly communicate data requests and share relevant register excerpts for validation.
Internal Teams: Facilitate cross‑functional workshops among procurement, IT, legal, and risk teams.
External Auditors: Prepare detailed reports with attached evidence from the register for inspection readiness.

Creating Tailored Reports and Feedback Mechanisms

Regulatory Submissions: Format the register in alignment with ESAs’ RT.01–RT.07 templates.
Internal Meetings: Use scenario analyses to discuss emerging risks and mitigation strategies.
Vendor Communications: Provide precise risk reports to assist vendors with contractual and compliance improvements.

Step 8: Training, Education, and Continuous Awareness

Building a Comprehensive Training Program

Target All Roles: Include training for IT, procurement, legal, risk, and executive management.
Role‑Based Modules: Develop separate modules for contract managers, technical teams, and senior leadership.
Scenario‑Based Exercises: Use simulated exercises and tabletop drills to practice identifying and mitigating ICT risks.

Example Module Structure:

DORA Fundamentals: Overview of requirements and obligations.
Register Management: Hands‑on exercises with actual register templates.
Incident Response: Role‑playing scenarios, such as data breaches.

Leveraging Educational Materials and External Resources

Official Guidance: Make DORA and ESAs documentation, FAQs, and white papers available.
Workshops and Webinars: Regularly organize sessions with industry experts and regulatory bodies.
Case Studies: Use anonymised examples from industry incidents to illustrate best practices and pitfalls.

Best Practices for Building Awareness

Ensure continuous leadership engagement to set the right tone.
Use internal newsletters and digital portals to disseminate updated compliance tips.
Regularly update training content after audits or regulatory changes.

Tools and Technologies for Managing the Register

Evaluating and Selecting Software Solutions

Key evaluation criteria when selecting technology include:

Scalability: The tool must handle growing volumes and complex supplier relationships.
Integration: Ability to connect with ERP, procurement, and risk management systems via APIs.
Compliance Support: Native support for ESAs’ RT series templates, robust audit trails, and data security measures.
User Experience and Automation: Intuitive dashboards, automated alerts, and workflow automation features.
Reporting & Analytics: Customizable reports, real‑time risk dashboards, and advanced analytics capabilities.

Example Use Case: A mid‑size insurer uses a GRC platform that automatically syncs supplier data from its procurement system, applies risk ratings based on pre‑defined DORA criteria, and generates regulator‑ready reports in the prescribed ESAs template format.

Tool Options

Excel Spreadsheets: Useful for smaller organisations, but limited in automation and version control.
GRC Platforms: Options like RSA Archer, LogicManager, and ServiceNow GRC provide built‑in modules for third‑party risk.
Specialised Risk Management Tools: Platforms such as Prevalent, BitSight, and SecurityScorecard offer continuous risk ratings and monitoring.
Custom‑Built Solutions: Tailor‑made systems can be integrated deeply with internal processes, though they require higher initial investment and maintenance.

Overcoming Implementation Challenges

Common Pitfalls

Incomplete Scoping: Overlooking indirect fourth‑party relationships.
Fragmented Data Sources: Relying on siloed information from procurement, IT, and legal without centralised governance.
Manual Errors: Dependence on spreadsheets leading to outdated or incorrect entries.
Insufficient Contract Details: Missing clauses on subcontracting, data localisation, and incident management.
Underestimating Supply Chain Complexity: Failing to map all dependencies and continuously update the register.

Proactive Strategies

Assign Clear Ownership: Create a dedicated cross‑functional team responsible for register maintenance.
Centralised Data Management: Use integrated GRC platforms to consolidate supplier information.
Automate Processes: Implement automated workflows for contract updates, alerts on key changes, and real‑time risk monitoring.
Schedule Regular Reviews: Institute quarterly audits and post‑incident reviews to ensure data integrity.
Enhance Data Quality: Use standardised risk scoring models and data validation rules.

Lessons from Early Adopters:

Begin with a broad mapping and refine over time.
Integrate register updates within contract lifecycle management systems.
Regularly solicit and incorporate feedback from key stakeholders.

Future-Proofing Your DORA Compliance Efforts

Adapting to Regulatory and ICT Changes

Monitor Regulatory Developments: Stay alert to ESAs, EBA, and national body updates.
Engage in Industry Forums: Participate in working groups and roundtables for early insights into emerging policies.
Assess Emerging Threats: Implement threat intelligence programs and horizon scanning to adjust risk assessments.

Adaptive Governance and Automation

Dynamic Policies: Develop change management procedures to update the register in response to vendor onboarding, contract changes, and critical incidents.
Cross‑Department Collaboration: Formalise processes between compliance, legal, procurement, and ICT.
Automated Integration: Leverage APIs to ensure the register is updated in real time from vendor management and incident tracking systems.

Preparing for Compliance Audits

Maintain Robust Audit Trails: Document every change with timestamps and reviewer details.
Conduct Internal Reviews: Regularly test and update control processes.
Engage External Experts: Use independent auditors to validate your register and risk assessments.

Concluding Remarks and Next Steps

Building a DORA-compliant register is a continuous process that requires meticulous planning, cross‑functional collaboration, and robust technology solutions. Key next steps include:

Defining the scope and identifying all relevant ICT service providers.
Mapping out contractual arrangements and risk assessments in a centralised register.
Integrating industry-standard frameworks and maturity models.
Implementing automated monitoring tools and establishing continuous communication
channels.
Conducting regular training sessions and audits to maintain up‑to‑date compliance.

By following these best practices and leveraging the outlined tools and processes, financial institutions can improve operational resilience, meet strict regulatory requirements, and remain agile in the face of evolving ICT risks. Maintain your DORA compliant ICT risk register to stay audit‑ready.

DORA Compliant ICT Risk Register 2025 – Full Guide