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The Digital Operational Resilience Act (DORA) is a significant regulatory mandate that targets the European financial sector, setting the deadline for compliance by January 17, 2025. This article provides a comprehensive guide to navigating DORA compliance, focusing on the intricacies of the ICT risk management framework, digital operational resilience testing, and ICT third-party risks management.

Understanding DORA: A Pragmatic Approach

The Digital Operational Resilience Act demands meticulousness, the allocation of appropriate resources, and time for successful implementation. Hence, we suggest a methodological approach to DORA compliance, organized like a Russian doll of policies, with each policy enveloping the next, providing a robust framework of digital operational resilience.

Structuring the ICT Risk Management Framework

One of the crucial areas of DORA compliance is the ICT risk management framework. This framework should encompass several key components, including:

  1. A robust digital operational resilience strategy
  2. An ICT business continuity policy
  3. Backup, restoration, and recovery procedures
  4. Records of activities during disruptions
  5. An incident management process
  6. An incident response plan
  7. Crisis communication plans

Mastering Digital Operational Resilience Testing

To ensure ongoing digital resilience, organizations are required to conduct several types of tests:

  1. Digital operational resilience tests annually
  2. For applicable entities, threat-based penetration tests at least every three years, adhering to the TIBER-EU framework

Managing ICT Third-Party Risks

The final major area of DORA compliance is managing the risks associated with third-party ICT service providers. This requires careful documentation of the collaborative relationship from start to finish, including:

  1. Mandatory contractual provisions
  2. Exit plans for the most sensitive providers
  3. Obligations to monitor cyber threats
  4. Mandatory training for C-Levels and employees

Navigating Sanctions

While DORA is less coercive than NIS2, it does not mean there are no penalties for non-compliance. Article 50(4) of DORA specifies that competent authorities may adopt measures, including financial ones, to ensure that financial entities continue to meet legal requirements. These authorities also have the right to make public statements about the nature of the violation and the identity of the responsible party.


Navigating DORA compliance is a significant task that demands a methodical approach and a thorough understanding of its three key areas: the ICT risk management framework, digital operational resilience testing, and ICT third-party risk management. With careful planning, comprehensive testing, and robust risk management, organizations can achieve compliance and enhance their operational resilience. This guide offers a blueprint for navigating DORA compliance, but the journey to compliance is an ongoing process that requires continuous effort and vigilance.