DORADeadline: January 2025

DORA Compliance

Digital operational resilience for financial entities. Manage ICT risks, test resilience, and oversee third-party providers.

What is DORA?

The Digital Operational Resilience Act (DORA, Regulation 2022/2554) establishes a comprehensive ICT risk management framework for the EU financial sector. It ensures that financial entities can withstand, respond to, and recover from ICT-related disruptions and threats.

DORA applies to virtually all regulated financial entities — banks, insurance companies, investment firms, crypto-asset service providers, and more — plus their critical ICT third-party service providers. It creates a unified approach to digital resilience that replaces fragmented national rules.

The regulation has been in force since January 2025 and covers five core pillars: ICT risk management, ICT incident reporting, digital operational resilience testing, ICT third-party risk management, and information sharing arrangements.

Who needs to comply?

Applies to

  • Banks, credit institutions, and payment service providers
  • Insurance and reinsurance companies
  • Investment firms, fund managers, and crypto-asset service providers
  • Trading venues, central counterparties, and central securities depositories
  • Critical ICT third-party service providers (cloud, data analytics, software)

Exemptions

  • Micro enterprises (under 10 employees) may apply simplified requirements
  • Certain small financial entities with limited digital operations

Key Requirements

The most important articles and obligations you need to address.

Art. 5-16

ICT Risk Management

Comprehensive framework covering governance, risk identification, protection, detection, response, and recovery from ICT risks.

Art. 17-23

Incident Reporting

Classification, reporting, and notification of major ICT-related incidents to competent authorities, with harmonized templates.

Art. 24-27

Resilience Testing

Annual basic testing and triennial threat-led penetration testing (TLPT) for significant financial entities.

Art. 28-44

Third-Party Risk

Due diligence, contractual requirements, and ongoing monitoring of ICT third-party service providers, including cloud.

Art. 45

Information Sharing

Voluntary arrangements for sharing cyber threat intelligence between financial entities in trusted communities.

Art. 50-64

Oversight Framework

Critical ICT third-party providers are subject to direct oversight by European Supervisory Authorities (ESAs).

DORA Timeline

Key enforcement milestones

Jan 2023

DORA entered into force

In effect

Jan 2025

Full application date

In effect

Jan 2025

RTS/ITS standards apply

In effect

2025-26

Supervisory enforcement begins

How complixo helps with DORA

Purpose-built features to get you from zero to compliant.

ICT Risk Framework

Pre-built controls covering all DORA ICT risk management requirements: identification, protection, detection, response, and recovery.

Resilience Testing

Manage annual testing programs and TLPT with test strategies, plans, cases, and execution cycles linked to DORA requirements.

Third-Party Management

Track and assess ICT third-party providers with due diligence checklists, contractual requirements, and ongoing monitoring.

Incident Management

Classify and track ICT incidents with the structured reporting timelines and templates DORA requires.

Controls & Evidence

Map controls to specific DORA articles, collect evidence, and maintain full traceability for supervisory reviews.

Supervisory Reports

Generate audit-ready reports for competent authorities and ESAs in PDF, Excel, or Word format.

Frequently asked questions

Who does DORA apply to?

DORA applies to 21 types of financial entities including banks, insurers, investment firms, payment providers, crypto-asset service providers, and their critical ICT third-party service providers (cloud providers, data analytics firms, software vendors).

How does DORA relate to NIS2?

DORA is a sector-specific regulation for financial services that takes precedence over NIS2 for covered entities (lex specialis). Financial entities comply with DORA instead of NIS2 for ICT risk management and incident reporting. However, they may still need NIS2 compliance for non-ICT aspects.

What testing is required under DORA?

All financial entities must conduct annual basic ICT testing (vulnerability scanning, network security tests, gap analysis). Significant entities must additionally perform threat-led penetration testing (TLPT) at least every three years using qualified external testers.

What are the incident reporting requirements?

Major ICT incidents must be reported to the competent authority using standardized templates. Initial notification within 4 hours of classification, intermediate report within 72 hours, and final report within 1 month.

How does complixo help with DORA compliance?

complixo covers all five DORA pillars: ICT risk management with structured risk registers, incident tracking and documentation, control testing for resilience testing, third-party vendor assessments, and audit-ready reports for supervisory authority reviews.

Get DORA compliant in minutes

Pre-built checks, structured evidence, and audit-ready reports. No credit card required.