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Digital Operational Resilience Act (DORA)
Article 5: Governance and organisation

Requirement description

1. Financial entities shall have in place an internal governance and control framework that ensures an effective and prudent management of ICT risk, in accordance with Article 6(4), in order to achieve a high level of digital operational resilience.
2. The management body of the financial entity shall define, approve, oversee and be responsible for the implementation of all arrangements related to the ICT risk management framework referred to in Article 6(1). For the purposes of the first subparagraph, the management body shall:
(a) bear the ultimate responsibility for managing the financial entity’s ICT risk;
(b) put in place policies that aim to ensure the maintenance of high standards of availability, authenticity, integrity and confidentiality, of data;
(c) set clear roles and responsibilities for all ICT-related functions and establish appropriate governance arrangements to ensure effective and timely communication, cooperation and coordination among those functions;
(d) bear the overall responsibility for setting and approving the digital operational resilience strategy as referred to in Article 6(8), including the determination of the appropriate risk tolerance level of ICT risk of the financial entity, as referred to in Article 6(8), point (b);
(e) approve, oversee and periodically review the implementation of the financial entity’s ICT business continuity policy and ICT response and recovery plans, referred to, respectively, in Article 11(1) and (3), which may be adopted as a dedicated specific policy forming an integral part of the financial entity’s overall business continuity policy and response and recovery plan;
(f) approve and periodically review the financial entity’s ICT internal audit plans, ICT audits and material modifications to them;
(g) allocate and periodically review the appropriate budget to fulfil the financial entity’s digital operational resilience needs in respect of all types of resources, including relevant ICT security awareness programmes and digital operational resilience training referred to in Article 13(6), and ICT skills for all staff; 27.12.2022 EN Official Journal of the European Union L 333/29
(h) approve and periodically review the financial entity’s policy on arrangements regarding the use of ICT services provided by ICT third-party service providers;
(i) put in place, at corporate level, reporting channels enabling it to be duly informed of the following:
(i) arrangements concluded with ICT third-party service providers on the use of ICT services,
(ii) any relevant planned material changes regarding the ICT third-party service providers,
(iii) the potential impact of such changes on the critical or important functions subject to those arrangements, including a risk analysis summary to assess the impact of those changes, and at least major ICT-related incidents and their impact, as well as response, recovery and corrective measures.
3. Financial entities, other than microenterprises, shall establish a role in order to monitor the arrangements concluded with ICT third-party service providers on the use of ICT services, or shall designate a member of senior management as responsible for overseeing the related risk exposure and relevant documentation.
4. Members of the management body of the financial entity shall actively keep up to date with sufficient knowledge and skills to understand and assess ICT risk and its impact on the operations of the financial entity, including by following specific training on a regular basis, commensurate to the ICT risk being managed.

How to fill the requirement

Digital Operational Resilience Act (DORA)

Article 5: Governance and organisation

Task name
Priority
Status
Theme
Policy
Other requirements
Creating and maintaining risk management framework -report
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Risk management and leadership
Risk management
2
requirements

Examples of other requirements this task affects

Article 5: Governance and organisation
DORA
Article 6: ICT risk management framework
DORA
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Creating and maintaining risk management framework -report
1. Task description

Organisation must create and maintain comperhensive and well-documented a risk management framework.

The risk management framework should include at least:

  • Strategies
  • policies
  • procedures
  • protocls
  • tools

used in cyber risk management.

The risk management framework must be reviewed at least yearly.

Internal audit procedure -report publishing and maintenance
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Risk management and leadership
Cyber security management
15
requirements

Examples of other requirements this task affects

ID.GV-3: Legal and regulatory requirements
NIST
7.5: Requirements for documented information
ISO27k1 Full
9.2: Internal audit
ISO27k1 Full
CC1.5: Accountability for responsibilities
SOC 2
Article 5: Governance and organisation
DORA
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Internal audit procedure -report publishing and maintenance
1. Task description

The organization has established a procedure for conducting internal audits. The procedure shall describe at least:

  • how often audits are carried out
  • who may carry out the audits (including audit criteria)
  • how the actual audit is carried out
  • how audit results are documented and to whom the results are reported
  • results should be reported to a competent authority if it's law regulated
Executing and documenting internal audits
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Risk management and leadership
Cyber security management
29
requirements

Examples of other requirements this task affects

12.7: Information systems audit considerations
ISO27 Full
12.7.1: Information systems audit controls
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HAL-07: Seuranta ja valvonta
Julkri
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Executing and documenting internal audits
1. Task description

The organization conducts internal audits in accordance with its internal audit procedure. The aim is to check:

  • whether the information security management system complies with the organisation's cyber security requirements
  • whether the information security management system complies with other operational security requirements or standards complied with
  • whether the information security management system is implemented effectively

Documented information on the execution and results of audits must be kept.

Information security policy -report publishing, informing and maintenance
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Risk management and leadership
Cyber security management
37
requirements

Examples of other requirements this task affects

5: Information security policies
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5.1: Management direction for information security
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5.1.2: Review of the policies for information security
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T01: Turvallisuusperiaatteet
Katakri
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Information security policy -report publishing, informing and maintenance
1. Task description

The organization has an information security policy developed and approved by top management. The policy shall include at least the following:

  • the basis for setting the organization’s security objectives
  • commitment to meeting information security requirements
  • commitment to continuous improvement of the information security management system

In addition, the task owner shall ensure that:

  • the is appropriate for the organization's business idea
  • the policy is communicated to the entire organization
  • the policy is available to stakeholders as appropriate
Determination and adequacy of the cyber security budget
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Risk management and leadership
Cyber security management
4
requirements

Examples of other requirements this task affects

5: Riittävä digiturvallisuuden budjetti
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DORA
10 §: Johdon vastuu
KyberTL
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Determination and adequacy of the cyber security budget
1. Task description

The organization has clearly defined a budget dedicated to the maintenance and development of digital security. The budget is sufficient to achieve the goals set for digital security.

When budgeting for digital security, three key areas must be considered in particular - personnel costs, technology solutions and operational costs.

Management commitment to cyber security management and management system
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Risk management and leadership
Cyber security management
26
requirements

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24. Responsibility of the controller
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5.1.1: Policies for information security
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7.2.2: Information security awareness, education and training
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ID.GV-1: Cybersecurity policy
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Management commitment to cyber security management and management system
1. Task description

The organization's top management must demonstrate a commitment to cyber security work and the management system. Management commits to:

  • defining the frameworks or other requirements that form the basis for work (e.g. customer promises, regulations or certificates)
  • determining the resources needed to manage security
  • communicating the importance of cyber security
  • ensuring that the work achieves the desired results
  • promoting the continuous improvement of cyber security

Top management also decides the scope of the information security management system and records the decision in the description of the system. This means, for example, whether some parts of the organisation's activities or information are excluded from the scope of the management system, or whether it applies to all information / activities of the organization.

Defining security roles and responsibilities
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Risk management and leadership
Cyber security management
33
requirements

Examples of other requirements this task affects

24. Responsibility of the controller
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6.1.1: Information security roles and responsibilities
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T02: Turvallisuustyön tehtävien ja vastuiden määrittäminen
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ID.GV-2: Cybersecurity role coordination
NIST
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Defining security roles and responsibilities
1. Task description

Top management must ensure clear responsibilities / authority on at least the following themes:

  • who is primarily responsible for ensuring that the information security management system complies with the information security requirements
  • who act as ISMS theme owners responsible for the main themes of the information security management system
  • who has the responsibility and authority to report to top management on the performance of the information security management system
  • who is authorized to carry out internal audits

The ISMS theme owners are presented on the desktop of the management system and in the Information security policy report.

In addition, top management shall ensure that all roles relevant to information security, as well as related responsibilities and authorities, are defined and communicated. It is also important to recognize the roles and responsibilities of external partners and providers.

Evaluating the efficiency of internal audits
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Risk management and leadership
Cyber security management
1
requirements

Examples of other requirements this task affects

Article 5: Governance and organisation
DORA
See all related requirements and other information from tasks own page.
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Evaluating the efficiency of internal audits
1. Task description

Task owner regularly evaluates the implementation of internal audits, especially from the following perspectives:

  • whether the auditors have been selected in such a way that the objectivity and impartiality of the audit process are realized
  • whether the audits were performed in such a way that the objectivity and impartiality of the audit process were realized

If necessary, task owner makes changes to the internal audit procedure.

Tasks included in the policy

Task name
Priority
Status
Theme
Policy
Other requirements
No items found.

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1.1 (MIL2): Manage IT and OT Asset Inventory
C2M2: MIL1
1.1 (MIL3): Manage IT and OT Asset Inventory
C2M2: MIL1
1.1.1: Availability of information security policies
TISAX
1.1.1: Identify the organisation’s strategy and priorities
NSM ICT-SP
1.1.2: Identify the organisation’s structures and processes for security management
NSM ICT-SP
1.1.3: Identify the organisation’s processes for ICT risk management
NSM ICT-SP
1.1.4: Identify the organisation’s tolerances for ICT risk
NSM ICT-SP
1.1.5: Identify the organisation’s deliverables, information systems and supporting ICT functions
NSM ICT-SP
1.1.6: Identify information processing and data flow
NSM ICT-SP
1.2 (MIL2): Manage Information Asset Inventory
C2M2: MIL1
1.2 (MIL3): Manage Information Asset Inventory
C2M2: MIL1
1.2.1: Establish a process to identify devices and software in use at the organisation
NSM ICT-SP
1.2.1: Scope of Information Security management
TISAX
1.2.2: Establish organisational guidelines for approved devices and software
NSM ICT-SP
1.2.2: Information Security Responsibilities
TISAX
1.2.3: Identify devices in use at the organisation
NSM ICT-SP
1.2.3: Information Security requirements in projects
TISAX
1.2.4: Definition of responsibilities with service providers
TISAX
1.2.4: Identify the software in use at the organisation
NSM ICT-SP
1.2: Manage Information Asset Inventory
C2M2: MIL1
1.3 (MIL2): Manage IT and OT Asset Configuration
C2M2: MIL1
1.3 (MIL3): Manage IT and OT Asset Configuration
C2M2: MIL1
1.3.1: Identification of information assets
TISAX
1.3.1: Identify the users of the information systems
NSM ICT-SP
1.3.2: Classification of information assets
TISAX
1.3.2: Identify and define the different user categories
NSM ICT-SP
1.3.3: Identify roles and responsibilities linked especially to ICT security
NSM ICT-SP
1.3.3: Use of approved external IT services
TISAX
1.3.4: Use of approved software
TISAX
1.3: Manage IT and OT Asset Configuration
C2M2: MIL1
1.4 (MIL2): Manage Changes to IT and OT Assets
C2M2: MIL1
1.4 (MIL3): Manage Changes to IT and OT Assets
C2M2: MIL1
1.4.1: Management of Information Security Risks
TISAX
1.4: Manage Changes to IT and OT Assets
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1.5 (MIL1): Management Activities for the ASSET domain
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1.5 (MIL2): Management Activities for the ASSET domain
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1.5 (MIL3): Management Activities for the ASSET domain
C2M2: MIL1
1.5.1: Assessment of policies and requirements
TISAX
1.5.2: External review of ISMS
TISAX
1.5: Management Activities for the ASSET domain
C2M2: MIL1
1.6.1: Reporting of security events
TISAX
1.6.2: Management of reported events
TISAX
1.6.3: Crisis preparedness
TISAX
10 §: Johdon vastuu
KyberTL
10. Processing of personal data relating to criminal convictions and offences
GDPR
10.1 (MIL2): Establish Cybersecurity Program Strategy
C2M2: MIL1
10.1 (MIL3): Establish Cybersecurity Program Strategy
C2M2: MIL1
10.1.1: Policy on the use of cryptographic controls
ISO27 Full
10.1.2: Key management
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10.1.2: Key management
ISO 27017
10.1: Continuous improvement
ISO27k1 Full
10.1: Cryptographic controls
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10.1: Cryptographic controls
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10.1: Establish Cybersecurity Program Strategy
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10.2 (MIL2): Establish and Maintain Cybersecurity Program
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10.2 (MIL3): Establish and Maintain Cybersecurity Program
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10.2: Establish and Maintain Cybersecurity Program
C2M2: MIL1
10.2: Non-conformity and corrective action
ISO27k1 Full
10.3 (MIL1): Management Activities for the PROGRAM domain
C2M2: MIL1
10.3 (MIL2): Management Activities for the PROGRAM domain
C2M2: MIL1
10.3 (MIL3): Management Activities for the PROGRAM domain
C2M2: MIL1
10.3: Management Activities for the PROGRAM domain
C2M2: MIL1
10: Cryptography
ISO27 Full
10: Cryptography
ISO 27017
10: Cybersecurity Program Management (PROGRAM)
C2M2: MIL1
10: Prosessi väärinkäytöksiin reagoimiseksi
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11 §: Poikkeamailmoitukset viranomaiselle
KyberTL
11. Processing which does not require identification
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11.1.1: Physical security perimeter
ISO27 Full
11.1.2: Physical entry controls
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11.1.3: Securing offices, rooms and facilities
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11.1.4: Protecting against external and environmental threats
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11.1.5: Working in secure areas
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11.1.6: Delivery and loading areas
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11.1: Secure areas
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11.2.1: Equipment siting and protection
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11.2.2: Supporting utilities
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11.2.3: Cabling security
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11.2.4: Equipment maintenance
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11.2.5: Removal of assets
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11.2.6: Security of equipment and assets off-premises
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11.2.7: Secure disposal or re-use of equipment
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11.2.7: Secure disposal or re-use of equipment
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11.2.8: Unattended user equipment
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11.2.9: Clear desk and clear screen policy
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11.2: Equipment
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11.2: Equipment
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11: Digiturvan mittarien määrittäminen
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11: Physical and environmental security
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11: Physical and environmental security
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12 §: Poikkeamaa koskeva väliraportti
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12. Transparent information, communication and modalities for the exercise of the rights of the data subject
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12.1.1: Documented operating procedures
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12.1.2: Change management
ISO27 Full
12.1.3: Capacity management
ISO27 Full
12.1.4: Separation of development, testing and operational environments
ISO27 Full
12.1: Operational procedures and responsibilities
ISO27 Full
12.2.1: Controls against malware
ISO27 Full
12.2: Protection from malware
ISO27 Full