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Two-minute brief

DORA requirements explained: video brief

A two-minute brief on the duties of financial entities under the Digital Operational Resilience Act, chapter by chapter.

  • Two-minute brief
  • 2 min

Key takeaways

  • The management body bears ultimate responsibility for ICT risk.
  • The ICT risk framework is reviewed at least yearly and after major incidents.
  • Major ICT-related incidents are classified and reported to the competent authority.
  • The register of information records ICT third-party contracts.
  • Critical ICT providers are overseen by the European Supervisory Authorities.

Governance and the ICT risk management framework

The Regulation has 64 articles in nine chapters; the duties of financial entities sit in Chapters II to VI, detailed by the Commission's technical standards. This short film maps them. Article 5 sets the governance: the management body defines, approves, oversees and answers for the ICT risk management framework, bears ultimate responsibility for ICT risk, approves the digital operational resilience strategy, allocates budget and keeps its knowledge current through regular training. The evidence is minutes approving the framework and strategy, a named owner of ICT risk, budget decisions and board training records.

Articles 6 to 16 require a sound, comprehensive and well-documented ICT risk management framework within overall risk management, reviewed at least yearly and after major incidents, and internally audited except in microenterprises. It covers identification, protection and prevention, detection, response and recovery, backup and restoration to recovery time and recovery point objectives, learning and evolving, and communication. Entities listed in Article 16 apply a simplified framework.

Incidents, testing, third parties and information sharing

Chapter III requires ICT-related incidents to be managed, classified and, where major, reported to the competent authority within the deadlines set. Chapter IV requires a digital operational resilience testing programme. Chapter V governs ICT third-party risk, including the register of information on ICT contracts, and sets up the Oversight Framework through which the European Supervisory Authorities, EBA, EIOPA and ESMA, oversee ICT providers designated as critical. Chapter VI provides for information sharing on cyber threats.

Article 2 lists twenty types of financial entity, from credit, payment and e-money institutions, investment firms and crypto-asset service providers to insurers, pension institutions, fund managers, market infrastructures and credit rating agencies, with a few exclusions. DORA has applied since 17 January 2025. It contains no certification; compliance is supervised by your competent authority, and legal interpretation goes to your legal advisers.

ICT third-party service providers based outside the EU are reached too, through the contracts financial entities sign with them and, for critical providers, through the Oversight Framework.

DORA at a glance

Purpose
Digital operational resilience: financial entities able to withstand, respond to and recover from ICT disruptions and threats, including those that start at a provider
Relevant to
Twenty types of EU financial entity listed in Article 2, from banks and insurers to payment, e-money and crypto-asset firms, and the ICT providers serving them, wherever they are based
Edition
Regulation (EU) 2022/2554, in application since 17 January 2025, detailed by Commission technical standards in force since 2024 and 2025
Certification
None exists. Compliance is supervised by your competent authority; ISO/IEC 27001 or ISO 22301 certificates evidence parts of it, never the whole
Sterling's role
Gap analysis, framework, register of information and evidence built with your team, with Effivity, training and internal audit, then Sustain™
Cost and timing
Total investment for a DORA compliance programme depends on the current maturity of your processes, the scope, locations and number of employees. The process typically takes 4 to 9 months

DORA: the complete guide →

DORA: questions people ask

Is there such a thing as DORA certification?

No. The Regulation contains no certification of compliance, no seal and no accredited scheme. Your competent authority supervises through reporting, requests and inspections; ICT providers are judged by their clients and, if designated critical, overseen by the ESAs. A "DORA certificate" is its issuer's own badge; ISO/IEC 27001 and ISO 22301 certificates support the evidence but certify nothing under DORA.

Does ISO/IEC 27001 or ISO 22301 certification make us DORA compliant?

No, though it is a strong start. The ICT risk management technical standard requires security policies based on leading practices and, where applicable, standards (a definition covering ISO and IEC standards), and a certified ISMS or BCMS already holds inventories, risk assessments, controls and exercise records. It does not produce what is specific to DORA: the register templates, classification and reporting to your authority, DORA's testing programme and TLPT, the Article 30 contract terms and the board's ultimate responsibility for ICT risk.

We provide ICT services to EU banks from outside the EU. Does DORA apply to us?

Not directly, unless the ESAs designate you as critical; it reaches you through your clients. Article 30 requires written terms on services, data locations, security, access to and return of data, service levels, incident assistance, cooperation with authorities, termination and training, and, for critical or important functions, contingency plans, participation in threat-led testing, unrestricted rights of access, inspection and audit, and exit support. A critical provider established outside the EU needs an EU subsidiary within 12 months of designation for financial entities to keep using it.

What is the register of information, and who keeps it?

Every financial entity keeps a register of all its ICT contractual arrangements, not only the critical ones, at entity level and, in groups, at sub-consolidated and consolidated level, on the templates of Implementing Regulation (EU) 2024/2956. It reports at least yearly on new arrangements, provides the full register on request and tells the authority in good time about planned arrangements for critical or important functions. In 2025 competent authorities had to pass the registers to the ESAs by 30 April, data that fed the first designation of critical providers.

How quickly must a major ICT-related incident be reported?

Classify it against Article 18 and the thresholds of Delegated Regulation (EU) 2024/1772. If it is major, Delegated Regulation (EU) 2025/301 sets the clocks: the initial notification within four hours of classification and no later than 24 hours after becoming aware of it, an intermediate report within 72 hours of the initial notification, and a final report within one month of the latest intermediate report, using the templates of Implementing Regulation (EU) 2025/302. Affected clients are told without undue delay. Reporting can be outsourced; responsibility cannot.

More DORA questions and answers →

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