DORA Regulation: Summary, Compliance Checklist + Training

Updated

January 10, 2025

Written by

Fact checked by

James Briscoe (Security Awareness Specialist, Hoxhunt)

The clock is ticking for financial firms across the EU to comply with the Digital Operational Resilience Act (DORA).

This game-changing regulatory framework isn’t just about following rules - it’s about building the cyber resilience needed to survive in the modern threat landscape.

Whether you’re a bank, a crypto-asset service provider, or a critical ICT third-party provider, understanding DORA's framework and deadlines is essential to protect your business and maintain customer trust.

This guide will break down everything you need to know about how DORA requirements work, who it impacts, and how to ensure you're compliant.

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DORA regulation summary

DORA (Digital Operational Resilience Act) is a unified ICT risk management framework for EU financial entities.

Its goal is to ensure organizations can withstand and recover from ICT-related risks, enhancing operational resilience and cybersecurity across the financial sector.

DORA is not just about compliance; it's about embedding resilience into the DNA of financial entities.

DORA establishes a framework to ensure that financial entities can withstand, respond to, and recover from ICT-related incidents and operational disruptions.

It mandates the adoption of the following processes:

ICT risk management: Policies and controls to mitigate risks associated with information and communication technologies.
Third-party risk management: Rigorous assessments of ICT third-party service providers.
Incident reporting and response: Timely detection, classification, and reporting of ICT-related incidents.
Operational resilience testing: Regular stress tests to validate preparedness.
Information sharing: Collaboration and transparency between entities to share insights on emerging threats.

Resilience doesn't mean stopping every attack...

It's about ensuring the financial sector can continue to operate even when attacks occur.

DORA highlights the role of critical third-party providers and cloud service providers, ensuring these entities meet strict resilience standards.

This means that Organizations relying on critical assets must continuously assess their risk profile.

The regulation ensures these providers maintain compliance with vulnerability evaluations and contractual clauses for operational continuity.

DORA also considers proportionality - not all financial entities face identical risks or operate on the same scale.

Smaller entities may tailor compliance efforts proportionally, but they still need to prioritize resilience.

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DORA compliance deadline

Organizations must comply with DORA by January 17, 2025.

If this deadline is missed, you'll face potential fines, increased regulatory scrutiny, and reputational risks.

Non-compliance impacts more than just finances; it can erode customer and stakeholder trust.

By the deadline date, all financial entities operating within the EU must fully adhere to its provisions.

This includes establishing ICT-related incident management processes, operational resilience frameworks, and compliance mechanisms.

The timeline also includes milestones for aligning contractual arrangements with critical ICT third-party providers.

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What's the difference between EU directives and regulations?

Understanding the distinction between EU directives and regulations is essential when discussing DORA.

A directive sets minimum standards that EU member states must implement through their national laws, allowing some flexibility in how the requirements are applied.
And a regulation, like DORA, applies uniformly across all member states without the need for transposition into national legislation.

DORA’s status as a regulation eliminates the variability seen in directives, ensuring a harmonized approach to operational resilience across the EU.

This uniformity is meant to reduce inconsistencies and strengthen systemic stability throughout the financial services sector.

DORA being a regulation, rather than directive simplifies oversight for competent authorities and ensures the development of consistent technical standards across member states...

And its uniformity also reduces admin burdens and clarifies the role of compliance oversight for financial services institutions.

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Why is DORA regulation necessary?

DORA is necessary due to the growing cyber threat landscape and the interconnected nature of the financial sector.

The financial sector is a prime target for cyber attackers because it's where the money is.

A single breach can ripple across the broader supply chain, affecting critical infrastructure and eroding trust in financial systems.

DORA aims to address these vulnerabilities by:

Establishing a unified framework to manage ICT-related risks.
Enhancing resilience to ensure financial entities can recover from disruptions.
Reducing systemic risk through robust ICT third-party risk management and incident response mechanisms.

DORA regulation sets clear expectations for financial firms and reporting service providers, requiring detailed documentation of risk management practices.

Comprehensive business continuity policies must align with DORA’s emphasis on effective incident management approaches.

Requirements such as regular penetration tests and disaster recovery plans ensure you're prepared for ICT-related disruptions.

DORA’s focus on resilience over just compliance is somewhat of a game-changer for the financial sector...

And its emphasis on operational resilience reflects the reality of modern cyber threats.

Cybercriminals exploit weak points in supply chains and ICT services, which is why DORA ensures entities are prepared for cascading impacts.

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Who is impacted by DORA?

DORA applies to a broad spectrum of financial entities, including but not limited to:

Banks and credit institutions.
Insurance companies and reinsurance undertakings.
Payment institutions and electronic money institutions.
Investment firms, alternative investment funds, and management companies.
Third-party ICT providers servicing financial entities.

The regulation also indirectly impacts ICT service providers outside the financial sector if they supply critical ICT-related services to regulated entities.

Emerging sectors like crypto-asset service providers and crowdfunding service providers are also explicitly included under DORA’s scope, as well as entities such as credit rating agencies and ancillary insurance intermediaries.

DORA’s reach extends deep into the supply chain, ensuring systemic resilience across the financial ecosystem.

This also includes entities across borders.

Organizations outside the EU with subsidiaries or business relationships in Europe are not exempt from DORA’s provisions.

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DORA framework metrics you need to measure

To achieve compliance and operational excellence under DORA, financial entities must measure key metrics aligned with its framework:

Incident response metrics

Time taken to detect, classify, and report ICT-related incidents.
Volume and severity of ICT-related incidents.

Operational resilience metrics

Results of operational resilience testing on ICT systems.
Mean Time to Recover (MTTR) from disruptions.

Third-party risk metrics

Proportion of critical ICT third-party providers evaluated annually.
Performance indicators of ICT third-party providers under stress scenarios.

Compliance metrics

Percentage of processes aligned with DORA requirements.
Status of cybersecurity maturity assessments.

The ability to measure and act on these metrics will distinguish leaders in the financial sector from those struggling to meet basic compliance requirements.

Metrics also extend to business disruption recovery time and the effectiveness of remedial measures.

Evaluating supply chain attacks and defining materiality thresholds are key to meeting DORA’s comprehensive rules.

These metrics align closely with requirements set by the European Banking Authority.

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DORA compliance checklist

Without comprehensive policies, procedures, and resilience testing, organizations risk falling short of DORA’s stringent requirements.

Achieving compliance with DORA requires meticulous planning and execution. Use the checklist below to align your operations with its mandates:

1. Establish ICT risk management policies

Document and implement frameworks to manage ICT-related risks effectively.
Conduct regular audits to identify security gaps.

2. Develop an incident management plan

Implement tools for ICT-related incident management, detection, classification, and reporting.
Set up a Security Operations Center (SOC) or Incident Response Team.
Use standardized templates for incident reporting to relevant authorities and European Supervisory Authorities.

3. Ensure ICT third-party risk management

Evaluate the cybersecurity posture of all critical ICT third-party service providers.
Include DORA-compliance clauses in contractual arrangements, ensuring oversight framework requirements are met.

4. Conduct operational resilience testing

Test critical systems for robustness against cyber attacks and operational disruptions.
Perform advanced testing techniques, such as threat-led penetration testing.

5. Optional information sharing

Optionally share insights on significant cyber threats with other financial entities to enhance collective resilience.

6. Train employees on DORA requirements

Provide targeted training to improve awareness of DORA regulations.
Educate staff on ICT-related incident response procedures and cybersecurity protocols.
Develop ICT security awareness programs and digital operational resilience training tailored to the roles and responsibilities of all employees.
Provide regular, targeted training for management bodies to ensure they stay up-to-date with ICT risks and their operational impact.

7. Document and monitor compliance

Maintain detailed records of processes, incidents, and corrective actions.
Regularly review and update compliance documentation.

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How Hoxhunt trains leaders on DORA

What is Hoxhunt?

Achieving compliance is not just about meeting regulatory deadlines; it’s about embedding resilience, ensuring trust, and safeguarding critical operations...

Hoxhunt helps security leaders and employees join forces to prevent data breaches.

Hoxhunt is a Human Risk Management platform that goes beyond security awareness to drive behavior change and measurably lower risk.

Hoxhunt's training is grounded in real-world experience

Focus on DORA’s Five Pillars: Hoxhunt examines DORA’s five pillars (risk management, incident reporting, resilience testing, third-party risk & information sharing)
Practical, actionable steps: Each module includes clear, actionable steps for leaders and outlines their oversight role in helping their teams meet compliance and build organizational resilience.
Leadership oversight: Training equips leaders to oversee cybersecurity processes, ensuring they meet DORA’s compliance standards and promote proactive cybersecurity awareness.
A practical, customer-tested approach: Hoxhunt partnered with Elisa, a leading Finnish telecommunications company, to ensure the training was grounded in real-world applicability.
Customer feedback integration: Training was refined based on direct feedback from Elisa and other customers, ensuring the training is practical, actionable, and aligned with the day-to-day challenges faced by leaders.
Additional tools for CISOs: This collaboration produced a CISO-friendly deck that enables CISOs to confidently deliver the training to their leadership teams.

What to expect from Hoxhunt's DORA training

Overview of DORA: Leaders are introduced to DORA’s scope, compliance timeline, and the leadership role in aligning organizational strategy with its five pillars.
Navigating DORA Compliance: Emphasizes maintaining up-to-date cybersecurity skills, fostering operational resilience, and aligning ICT risk management with organizational goals.
Leadership Cyber Awareness: Personal cybersecurity best practices, such as enabling MFA and recognizing phishing threats, are covered to inspire organization-wide responsibility.
Pillar 1 - Risk Management: Leaders learn to integrate ICT risks into the organization’s risk framework, approve policies, and oversee policy reviews to address evolving threats.
Pillar 2 - Incident Response: Essentials of creating a tested incident response plan and ensuring clear communication with stakeholders and regulators.
Pillar 2 - Incident Reporting: Focuses on timely, accurate reporting of major ICT-related incidents, including root cause analysis.
Pillar 2 - Post-Incident Learning: Conducting post-incident reviews to identify gaps and integrate lessons into updated policies.
Pillar 3 - Operational Resilience: Setting resilience goals, overseeing regular resilience testing, and monitoring third-party dependencies.
Pillar 4 - Third-Party Provider Resilience: Simplifies third-party risk management by maintaining contract registers, conducting risk assessments, and preparing tested exit strategies.
Pillar 5 - Information Sharing: Guides leaders on secure intelligence sharing and compliance with Information-sharing Arrangements.
DORA Top Priorities: Recaps top leadership responsibilities and immediate actions for DORA compliance.

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DORA regulation FAQ

What is DORA regulation in a nutshell?

DORA, or the Digital Operational Resilience Act, is an EU regulation designed to ensure financial entities can withstand and recover from ICT-related incidents.

It focuses on risk management, incident response, third-party oversight, operational resilience testing, and information sharing.

What are the 5 pillars of DORA regulation?

The five pillars of DORA are:

ICT Risk Management
Incident Reporting and Response
ICT Third-Party Risk Management
Operational Resilience Testing
Information Sharing and Intelligence Sharing

Who must comply with DORA?

DORA applies to a wide range of financial entities, including banks, payment service providers, insurance companies, investment firms, and ICT service providers to financial institutions.