Understanding DORA compliance: Key steps to prepare your organization

The Digital Operational Resilience Act (DORA) is an EU regulation aimed at ensuring that organizations in the financial sector have robust measures in place to manage digital risks. It sets a framework for assessing, monitoring, and mitigating risks related to information and communication technology (ICT). DORA covers everything from internal risk management processes to how companies work with third-party service providers.

While many organizations understand the basics of DORA, implementing compliance is the real challenge. This article provides a structured, step-by-step guide to help you understand the key aspects of DORA and get started.

Why DORA Matters for SMEs and IT Managers

• Importance of Digital Resilience: Organizations must be prepared to handle cyber threats and system failures to protect their operations and customer data.
• Impact on Operational Risk Management: DORA drives improvements in how businesses manage and monitor digital risks, reducing downtime and financial losses.

Organizations Subject to DORA

DORA is designed to strengthen the digital resilience of entities in the financial sector, and its requirements extend beyond traditional banks. Here's a breakdown of who needs to comply:

• Financial Institutions & Payment Service Providers
  Align ICT frameworks with DORA, ensure secure and uninterrupted operations, implement risk management policies.
• Insurance Companies & Investment Firms
  Adopt strong digital risk management practices, protect customer data and financial assets, conduct regular risk assessments.
• Critical Third-Party Service Providers
  Includes cloud service providers (AWS, Azure), payment processors, IT infrastructure providers, cybersecurity firms, and outsourced data storage services. These companies must meet DORA security standards, ensure operational resilience, and integrate cybersecurity measures in their service offerings.
• Small & Medium-Sized Enterprises (SMEs)
  Includes FinTech companies, software vendors, IT consulting firms, and managed service providers (MSPs) that supply solutions to financial institutions. SMEs must strengthen cybersecurity controls, implement risk management policies, and comply with supply chain risk requirements when working with regulated entities.

DORA compliance checklist: Practical steps for compliance

DORA outlines a set of requirements to ensure operational resilience, but specific technical standards further clarify these obligations. It emphasizes the need for robust frameworks, regular testing, and clear governance to tackle evolving cyber threats.

Below is an overview of the main themes and key actions organizations should take. For more detailed guidance and full requirements, you can refer to the official DORA technical standards.

Read more: 10 compliance traps & how to avoid them

Organizations can simplify their DORA compliance by using Cyberday, an ISMS that breaks down complex frameworks into actionable tasks. Cyberday helps organizations track their compliance progress, assign responsibilities, and ensure continuous adherence to regulations like DORA.

The requirements of DORA can be divided into five themes:

1. ICT risk management
2. Incident reporting
3. Operational resilience testing
4. Third-party risk management
5. Governance and oversight

You can assess your current compliance with DORA using our free compliance assessment here.

ICT risk management

To meet DORA requirements, organizations should focus on establishing a comprehensive ICT risk management framework. This includes:

• Develop a risk management framework: Set up processes for identifying, assessing, and mitigating ICT risks across all digital systems.
• Define roles and responsibilities: Clearly assign accountability for ICT risk management within your organization.
• Conduct regular risk assessments: Periodically evaluate potential threats, vulnerabilities, and impacts on operations.
• Implement security policies and controls: Establish and enforce policies that cover data protection, system monitoring, and incident response.
• Monitor and update processes: Continuously review and adjust risk management strategies to keep pace with evolving digital threats.
• Train staff on ICT security: Ensure that employees are aware of risk management practices and know how to react in case of security incidents.

Using Cyberday, organizations can systematically track these risk management activities, ensuring that all processes are well-documented and continuously improved.

Incident reporting

DORA requires organizations to have prompt and transparent reporting systems in place to minimize damage from ICT incidents. Establishing a clear, well-documented incident reporting process ensures that all security breaches and operational disruptions are addressed quickly.

• Develop an incident reporting framework: Create a standardized process for reporting incidents that aligns with DORA guidelines.
• Implement automated monitoring systems: Use tools that continuously monitor your systems and can quickly detect anomalies or breaches.
• Define clear reporting protocols: Establish who should report incidents, what information must be included, and the timeline for reporting.
• Train your team: Ensure employees know how to identify and report incidents, including regular training sessions and drills.
• Coordinate with stakeholders: Maintain communication channels with relevant internal and external parties to facilitate quick and coordinated responses.

Cyberday streamlines incident reporting, ensuring that all reported cases are logged, assessed, and acted upon efficiently.

Operational resilience testing

To comply with DORA, you must conduct regular resilience tests to ensure your digital systems can withstand cyber threats and quickly recover from disruptions.

• Schedule regular stress tests: Plan periodic tests to assess the performance of your systems under simulated disruptive scenarios.
• Conduct simulation exercises: Run drills that mimic various attack vectors or system failures.
• Evaluate and document outcomes: Analyze test results to identify areas of weakness and document lessons learned.
• Adjust strategies based on findings: Use insights from testing to refine operational resilience plans.
• Engage third-party experts: Consider involving external specialists for unbiased assessments.

Cyberday allows businesses to document test results, track corrective actions, and maintain a structured approach to resilience testing.

Third-party risk management

DORA emphasizes managing risks arising from outsourcing and relying on external service providers.

• Review vendor contracts: Integrate compliance and risk management clauses in contracts with third-party providers.
• Conduct regular risk assessments: Evaluate the security posture of vendors through periodic assessments and audits.
• Set clear performance standards: Establish benchmarks and key performance indicators related to digital resilience.
• Monitor vendor performance: Continuously track the effectiveness of vendors' risk management practices.
• Develop contingency plans: Prepare backup strategies in case a third-party provider fails to meet DORA requirements.

Cyberday simplifies third-party risk management by offering structured tools to assess, monitor, and document vendor compliance.

Governance and oversight

DORA requires organizations to establish clear governance structures to manage and monitor digital operational risks.

• Define clear roles and responsibilities: Establish dedicated teams or committees for digital resilience oversight.
• Implement robust reporting mechanisms: Develop internal reporting systems that track compliance efforts.
• Maintain comprehensive documentation: Keep detailed records of policies, procedures, and compliance activities.
• Conduct regular governance reviews: Schedule periodic evaluations of governance structures.
• Integrate DORA into overall business strategy: Ensure that digital operational resilience is embedded into broader risk management plans.

With Cyberday, organizations can maintain governance structures efficiently, ensuring compliance with DORA while keeping track of progress in a centralized system. Test your current DORA compliance level with our free online assessment.

DORA requirements summary: What’s next?

To successfully comply with DORA, organizations must take a structured approach to managing digital resilience. Here’s a high-level summary of the key focus areas and actions required. However, keep in mind that this is not an exhaustive list of all DORA requirements.

• ICT risk management: Establish a structured risk framework, conduct assessments, and implement security controls.
• Incident reporting: Develop protocols, monitor incidents, and train teams for rapid response.
• Operational resilience testing: Regularly stress-test systems and refine resilience strategies.
• Third-party risk management: Ensure vendors comply with DORA by monitoring their risk frameworks.
• Governance and oversight: Maintain clear accountability, reporting, and compliance documentation.

Cyberday is designed for teams that need a clear, structured way to manage compliance tasks in one place—ensuring nothing gets overlooked.

By using Cyberday, organizations can simplify compliance with DORA by transforming complex regulatory requirements into structured, actionable steps. With Cyberday, businesses can ensure DORA requirements are seamlessly integrated into their operational workflows. This allows organizations to proactively manage risks, maintain transparency, and ensure continuous adherence to DORA regulations.

Start your 14-day free trial today and strengthen your organization's digital resilience and compliance strategy.