DORA Compliance: What It Means for Global Institutions

As cyber threats grow in complexity and financial systems become increasingly reliant on interconnected digital infrastructure, the European Union’s Digital Operational Resilience Act (DORA) is redefining the technical and governance requirements for how financial entities and their Information and Communication Technology (ICT) service providers manage, withstand, and recover from operational disruptions. Though rooted in EU legislation, DORA’s influence extends globally—setting a new benchmark for digital operations across the financial sector.

Below, we’ll discuss what the Digital Operational Resilience Act requires, who’s in scope (hint: it’s broader than you think), and how to align with its five key pillars.

Whether you’re in the EU or serve EU clients, compliance isn’t optional. Learn how to validate your controls, manage third-party risk, and turn regulatory readiness into real operational resilience.

A Resilience Framework for Financial Firms

The framework mandates that financial institutions demonstrate their ability to withstand, respond to, and recover from ICT-related incidents. It moves beyond traditional cybersecurity frameworks by requiring a unified, risk-based governance model across the entire enterprise.

Though rooted in EU legislation, DORA’s influence extends globally—setting a new benchmark for digital operations across the financial sector. Compliance requires a combination of policy, process, and technical controls across five key areas (more on that below).

For global institutions—especially those operating in or partnering with EU financial entities—meeting the requirements of the Digital Operational Resilience Act is not optional; it’s a prerequisite for market access.

ICT Providers Are Squarely in Scope

If your business provides infrastructure, platforms, software, or data services to EU financial firms, you fall within DORA’s scope under Article 2. That includes:

• Cloud service providers – delivering infrastructure, platforms, or software hosting critical to day-to-day operations (e.g., AWS, Azure, Google Cloud).
• Software vendors – supplying key applications such as trading platforms, risk analytics, customer onboarding tools, or compliance systems.
• Managed service providers (MSPs/MSSPs) – offering outsourced IT or security operations, including monitoring, detection, or response services.
• Data centers and hosting providers – handling physical infrastructure or private/hybrid cloud environments used by financial entities.
• Telecommunication providers – enabling secure data transmission and communications across distributed systems and offices.
• Payment and transaction processors – managing critical financial infrastructure or interfacing with regulated services.
• Business continuity and disaster recovery vendors – supporting systems and services relied upon during ICT disruptions.
• Open banking/API aggregators – facilitating connections between banks and third-party providers for data or payment services.

These third-party ICT providers may also be designated as “critical,” triggering enhanced regulatory scrutiny and direct oversight from EU authorities.

Bottom line: If your services support the digital backbone of an EU financial firm, DORA applies to you.

Breaking Down the Five DORA Pillars

At the core of digital operational resilience are five interconnected pillars that define how financial institutions and ICT providers must build, manage, and prove their ability to withstand disruptions. These pillars form the foundation of a resilient, well-governed digital infrastructure—and must be addressed holistically.

Pillar 1: ICT Risk Management

Organizations are required to embed ICT risk into their enterprise risk management frameworks. This includes:

• Establishing governance and accountability at the board level
• Maintaining an up-to-date risk inventory
• Implementing controls to prevent, detect, and recover from ICT-related threats
• Continuously assessing vulnerabilities across systems, processes, and people

Risk management must be proactive, end-to-end, and continuously monitored—not reactive or siloed within IT.

Pillar 2: Incident Reporting

Entities must classify, track, and report major ICT-related incidents to their competent authorities under strict timelines—often within four hours for initial notification.

Requirements include:

• Predefined criteria for what constitutes a major incident
• Internal escalation protocols
• Procedures for notifying regulators and stakeholders
• Post-incident reviews and lessons learned

Pillar 3: Digital Operational Resilience Testing

Organizations must regularly test their ability to withstand and recover from ICT disruptions using:

• Scenario-based exercises
• Continuity and recovery drills
• Penetration testing (including threat-led testing for critical entities)

Testing must be risk-based, documented, and repeatable, with clear remediation workflows.

Article 26.2 requires that this testing take place against critical, live production systems. Specifically lab testing is no longer sufficient for DORA compliance purposes.

Pillar 4: ICT Third-Party Risk Management

The scope of responsibility now extends to external ICT providers. Firms must:

• Maintain a full inventory of ICT contracts
• Conduct due diligence and risk assessments
• Define exit strategies and substitution plans
• Ensure providers meet contractual obligations around resilience and reporting

Your third-party risks are your risks. You’re accountable for their impact on your operations.

Pillar 5: Information Sharing

Voluntary participation in cyber threat intelligence (CTI) sharing initiatives is strongly encouraged to strengthen collective security across the financial sector. The goal is to enhance preparedness by sharing:

• Indicators of compromise (IoCs)
• Tactics, techniques, and procedures (TTPs)
• Threat actor insights

Compliance Readiness and DORA Deadlines

The Digital Operational Resilience Act took full effect on January 17, 2025, marking the end of the planning phase and the beginning of regulatory enforcement. Key milestones leading up to this included:

• Finalization of regulatory technical standards (RTS) in mid-2024, providing detailed rules around ICT risk management, incident reporting, and operational testing.
• Preparation and implementation throughout 2024, including internal assessments, vendor engagement, and updates to governance and controls.
• Full enforcement beginning in January 2025.

With the window for preparation now closed, organizations must execute—validating controls, documenting governance, and proving operational readiness.

Priorities for late adopters:

• Closing outstanding compliance gaps
• Validating control effectiveness (ideally with real evidence)
• Strengthening incident response and third-party oversight
• Preparing for audits or inquiries from competent authorities

How Non-EU Companies Can Prepare

For financial institutions and ICT providers outside the EU, the real work is just beginning. If your business serves EU-based clients, meeting regulatory expectations isn’t optional. Here’s how to align effectively with the new operational resilience standards.

1. Map Existing Frameworks to the Five Pillars

Start by aligning your current controls:

Pillar	Common Framework Alignment
ICT Risk Management	ISO 27005, NIST RMF (SP 800-37)
Incident Reporting	ISO 27035, NIST (SP 800-61)
Digital Operational Resilience Testing	TLPT, NIST (SP 800-53 (RA/CA))
ICT Third-Party Risk Management	ISO 27036, NIST (SP 800-161)
Information Sharing	ISO 27010, NIST (SP 800-150)

Conduct a gap analysis to identify shortfalls and create a roadmap to full alignment.

2. Validate Controls with Real-World Evidence

Regulators demand proof—not just policy. To achieve compliance, you must demonstrate that controls:

• Are implemented and operational
• Work as intended
• Can be validated with real-world evidence

This goes beyond traditional audits. Adopt solutions that deliver:

• Continuous control validation
• Breach and attack simulation (BAS)
• Real-time visibility into detection and response capabilities
• Audit-ready reporting aligned with regulatory standards

Platforms like SafeBreach enable organizations to simulate real-world threats, test security stack effectiveness, and produce the evidence required by regulators.

3. Reassess Third-Party Risk and Contracts

Your vendors and sub-processors are part of your compliance perimeter. You are expected to:

• Maintain a registry of ICT service providers
• Define exit strategies and risk mitigation plans
• Establish contractual obligations around business continuity plans (BCPs), service level agreements (SLAs), and incident reporting

Actions to take:

• Update contracts and SLAs to include clauses for incident notification timelines, audit rights, and participation in operational testing
• Reevaluate any subcontracting relationships that may affect EU clients or data
• Implement tools or workflows for continuous vendor risk monitoring

4. Conduct Operational Resilience Testing

Regulatory expectations now require financial entities and critical ICT providers to conduct regular testing, including:

• Scenario-based exercises
• Threat-led penetration testing (TLPT) for high-risk environments
• Analysis of response effectiveness and improvement areas

Even if your organization isn’t designated as a “critical” provider, your clients may require you to participate in coordinated testing efforts. Be prepared to:

• Document testing procedures and results
• Share test outputs with regulators
• Adjust internal processes based on test findings

5. Monitor RTS Developments and Regulatory Updates

Much of the practical enforcement is shaped by Regulatory Technical Standards (RTS) issued by the European Supervisory Authorities (ESAs). These outline the “how” behind the regulation’s “what.”

To stay aligned:

• Assign internal owners to track RTS publications from the EBA, ESMA, and EIOPA
• Align internal policies and documentation with RTS definitions, especially around thresholds for incident reporting and third-party criticality

6. Treat Compliance as a Commercial Imperative

Even if you’re not directly regulated, your EU clients are—and their expectations are rising. Compliance posture now influences:

• Request for Proposal (RFP) scoring and vendor selection
• Annual supplier reviews
• Contract renewal and retention decisions

Organizations that can prove resilience will gain a competitive edge. Those that can’t risk losing access to the EU market.

Turning Regulatory Readiness into Operational Resilience

Whether you’re just starting or accelerating your compliance program, SafeBreach helps financial institutions and ICT providers move from reactive to proactive, measurable cyber resilience.

With the SafeBreach Exposure Validation Platform, organizations can:

• Continuously test and validate control effectiveness
• Identify and close gaps in real time
• Generate audit-ready evidence aligned with regulatory expectations

DORA compliance is no longer optional. It’s a test of your ability to withstand disruption—and prove it. SafeBreach delivers the validation, automation, and evidence regulators demand.

Get your personalized demo to see how SafeBreach can help you meet DORA requirements and continuously validate your defenses with confidence.