Compliance walkthrough
How to comply with DORA: video walkthrough
A walkthrough of building a Digital Operational Resilience Act programme your competent authority can examine, from the ICT risk management framework to the register of information.
Key takeaways
- DORA is an EU regulation, directly applicable since 17 January 2025.
- It covers twenty types of financial entity and reaches the ICT providers serving them.
- Five pillars: ICT risk, incidents, testing, third-party risk and information sharing.
- The register of information must match your ICT contracts.
- There is no DORA certificate; the competent authority supervises.
DORA is supervised, not certified
The Digital Operational Resilience Act, Regulation (EU) 2022/2554, is the EU law on ICT risk in finance. Directly applicable in every Member State since 17 January 2025, it gives twenty types of financial entity one harmonised rulebook so that they can withstand, respond to and recover from ICT disruptions such as cyberattacks or system failures, including those that start at a provider.
Its obligations fall into five areas, often called its pillars: ICT risk management, ICT-related incident management, classification and reporting, digital operational resilience testing, ICT third-party risk and information sharing. The Regulation contains no certification of compliance: your competent authority supervises, and for an ICT provider, clients audit. This short film walks through how the programme is built and shown.
Build the arrangements, run them, then show them
Settle the scope first: the entities and group levels, the competent authorities, whether the simplified framework or microenterprise rules apply, your critical or important functions and, for a provider, which client obligations reach you. A gap analysis then measures today's arrangements against the Regulation and the Commission's technical standards, across governance, the framework, incidents, testing, third parties and information sharing, reusing ISO/IEC 27001 and ISO 22301 evidence where it exists, and fixes actions, owners and dates.
The build delivers an ICT risk management framework the board owns, incident classification and reporting within the deadlines, a testing programme that finds weaknesses first, and a register of information that matches your ICT contracts. The management body approves the framework and the digital operational resilience strategy, allocates budget and keeps its knowledge current through training. Internal audit and review then show what remains before the supervisor examines it.
Sterling's expert and experienced consultants work alongside your ICT, risk, procurement and legal teams under Sterling OS™, with the evidence held in Effivity. Certificates such as ISO/IEC 27001 or ISO 22301 evidence parts of DORA, never the whole, and legal interpretation goes to your legal advisers.
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: 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.
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