Cybersecurity & Compliance Insights

Understanding DORA: The New EU Financial Sector Security Regulation

Written by Ken Pomella | August 29, 2025

In a rapidly digitizing financial world, regulators are stepping up efforts to ensure that the institutions handling critical infrastructure are prepared for cyber risks. One of the most impactful developments in this space is the Digital Operational Resilience Act (DORA)—a new regulation from the European Union that sets a unified framework for ICT (Information and Communication Technology) risk management across the financial sector.

Set to go into full effect in January 2025, DORA is reshaping how financial institutions and their third-party providers manage cybersecurity, operational resilience, and incident response. In this blog, we’ll break down what DORA is, who it affects, what it requires, and how organizations can prepare.

What Is DORA?

The Digital Operational Resilience Act (DORA) is an EU regulation designed to ensure that financial entities can withstand, respond to, and recover from ICT-related disruptions and cyber threats. It was published in the EU’s Official Journal in December 2022 and becomes enforceable on January 17, 2025.

DORA is part of the EU’s Digital Finance Package and applies uniformly across all EU member states. Unlike previous directives, which allowed for local interpretations, DORA is a regulation, meaning it’s legally binding in its entirety.

Why DORA Matters

Cyberattacks on financial institutions have become increasingly sophisticated, frequent, and damaging. Legacy risk management practices are no longer enough, especially as institutions grow more dependent on third-party cloud services, SaaS platforms, and interconnected digital systems.

DORA aims to:

  • Establish a standardized framework for managing ICT risks
  • Improve incident detection and response
  • Increase transparency in the use of third-party vendors
  • Strengthen the overall resilience of the EU financial system

Whether your organization is based in the EU or works with EU-based financial entities, understanding DORA is critical for compliance, risk reduction, and business continuity.

Who Is Affected by DORA?

DORA applies to a wide range of financial sector participants, including:

  • Banks and credit institutions
  • Insurance and reinsurance companies
  • Investment firms and brokers
  • Crypto-asset service providers
  • Payment institutions and e-money firms
  • Pension funds and credit rating agencies
  • ICT third-party service providers (cloud providers, software vendors, MSPs)

Even non-EU companies may fall under DORA if they serve or support EU-based financial entities.

Key Pillars of DORA Compliance

DORA introduces five core pillars that financial entities must implement and demonstrate:

1. ICT Risk Management Framework

Organizations must establish and maintain a comprehensive risk management strategy for ICT systems. This includes:

  • Governance structures and accountability
  • Identification and classification of ICT assets
  • Regular risk assessments
  • Business continuity and disaster recovery plans
  • Clear roles and responsibilities

Security must be embedded across the lifecycle of systems and data.

2. Incident Reporting

DORA standardizes incident reporting across the EU. Financial entities must:

  • Detect and classify incidents rapidly
  • Notify relevant authorities (such as ESAs or national regulators) within tight timeframes
  • Provide follow-up analysis and root cause reporting

This ensures regulators can assess systemic risk in near real-time.

3. Digital Operational Resilience Testing

Organizations must regularly test the effectiveness of their cybersecurity controls. This includes:

  • Vulnerability assessments
  • Penetration testing
  • Scenario-based tabletop exercises
  • Threat-led penetration testing (TLPT) for critical entities

The goal is to move from passive compliance to active resilience.

4. Third-Party Risk Management

DORA introduces strict rules for managing ICT third-party providers, including:

  • Mandatory risk assessments before onboarding
  • Contractual obligations on service levels, availability, and data handling
  • Exit and contingency planning
  • Reporting of subcontractors in critical services

A new oversight framework will also regulate critical ICT service providers, such as cloud infrastructure vendors.

5. Information Sharing

DORA encourages voluntary threat intelligence sharing between financial entities. Organizations that participate must ensure information is:

  • Timely, accurate, and relevant
  • Shared in a secure, anonymized manner
  • Used to improve collective cyber resilience

This aims to foster collaboration without compromising competitiveness.

How to Prepare for DORA Compliance in 2025

If your organization falls under the scope of DORA—or partners with one that does—now is the time to prepare. Here’s how to get started:

1. Assess Your Current State

Perform a gap analysis against the DORA framework. Identify where your current ICT risk management practices fall short in areas like incident detection, third-party oversight, or resilience testing.

2. Update Policies and Procedures

Ensure you have documented and tested:

  • ICT governance policies
  • Incident response plans
  • Disaster recovery and business continuity procedures
  • Vendor management and contract clauses
  • Internal audit and compliance tracking systems

3. Implement Automation and Monitoring

Real-time monitoring tools, SIEM platforms, and automated incident response systems can help you meet DORA’s requirements more efficiently and continuously.

4. Strengthen Vendor Due Diligence

Revise your third-party onboarding and oversight processes. You may need to renegotiate contracts, conduct vendor risk assessments, and implement contingency planning for critical services.

5. Educate Your Teams

Training is essential—especially for IT, risk, legal, and procurement teams. Everyone must understand their role in meeting DORA obligations.

DORA vs. Other Compliance Frameworks

While DORA shares elements with ISO 27001, SOC 2, and NIS2, it goes further in requiring a holistic and continuous approach to ICT risk management. For example:

  • It applies across all EU financial sectors
  • It mandates incident reporting timelines and content
  • It places significant oversight on third-party ICT providers
  • It introduces formal resilience testing expectations

Even if your organization is already ISO 27001 certified or SOC 2 compliant, additional work may be needed to fully meet DORA’s demands.

Conclusion: A New Era of Digital Resilience

DORA is a game-changer for how financial entities approach cybersecurity and operational risk. Rather than treating compliance as a once-a-year checkbox, DORA requires organizations to adopt a living, adaptive security strategy—one that’s resilient in the face of ongoing threats and evolving technology.

As the January 2025 deadline approaches, proactive planning is essential. Whether you're a bank, fintech startup, or cloud provider supporting financial services, aligning with DORA will help you build trust, reduce risk, and gain a competitive edge in a regulated market.

Need help getting ready for DORA? Let’s talk about building a security-first compliance strategy.