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DORA simplified RMF
Article 36: ICT security testing

Requirement description

1. The financial entities referred to in Article 16(1) of Regulation (EU) 2022/2554 shall establish and implement an ICT security testing plan to validate the effectiveness of their ICT security measures developed in accordance with Articles 33, 34 and 35 and Articles 37 and 38 of this Regulation. Financial entities shall ensure that that plan considers threats and vulnerabilities identified as part of the simplified ICT risk management framework referred to in Article 31 of this Regulation.

2. The financial entities referred to in paragraph 1 shall review, asses and test ICT security measures, taking into consideration the overall risk profile of the ICT assets of the financial entity.

3. The financial entities referred to in paragraph 1 shall monitor and evaluate the results of the security tests and update their security measures accordingly without undue delay in the case of ICT systems supporting critical or important functions.

How to fill the requirement

DORA simplified RMF

Article 36: ICT security testing

Task name
Priority
Status
Theme
Policy
Other requirements
Regularly conducting threat-led penetration testing (TLPT)
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Development and cloud
Technical vulnerability management
2
requirements

Examples of other requirements this task affects

Article 26: Advanced testing of ICT tools, systems and processes based on TLPT
DORA
Article 36: ICT security testing
DORA simplified RMF
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Regularly conducting threat-led penetration testing (TLPT)
1. Task description

Organization has a process for regulalry conducting threat-led penetration testing (TLPT).

TLPT process fills the following requirements:

  1. Frequency: Financial entities are required to conduct advanced TLPT by default every three years.
  2. Scope: Each TLPT must cover several or all critical or important functions of the entity and must be conducted on live production systems that support these functions.
  3. Inclusion of third-party ICT providers: If critical functions are outsourced to third-party ICT service providers, these providers must be included in the TLPT.
  4. Vulnerability mitigation: Entities must (in collaboration with third-party providers and testers) apply effective risk management controls to mitigate potential impacts on data, assets, and operations.
  5. Test reporting: Upon completing the testing, entities must provide a summary of findings and remediation plans to the designated authority.
  6. Tester requirements: Entities must engage testers as specified in the regulations, using external testers periodically (every three tests) unless classified as significant, in which case only external testers must be used.
Executing and documenting internal audits
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

12.7: Information systems audit considerations
ISO 27001
12.7.1: Information systems audit controls
ISO 27001
18.2.1: Independent review of information security
ISO 27001
ID.GV-3: Legal and regulatory requirements
NIST
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.

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
17
requirements

Examples of other requirements this task affects

ID.GV-3: Legal and regulatory requirements
NIST
14.6.: Vadovybės atsakomybė
NIS2 Lithuania
7.5: Requirements for documented information
ISO 27001
9.2: Internal audit
ISO 27001
CC1.5: Accountability for responsibilities
SOC 2
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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
Testing security functions that are affected by the changes to ICT systems
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Development and cloud
Secure development
2
requirements

Examples of other requirements this task affects

2.10.3: Test affected security functions
NSM ICT-SP
Article 36: ICT security testing
DORA simplified RMF
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Testing security functions that are affected by the changes to ICT systems
1. Task description

Test security functions that are affected by changes to ICT systems both before and after deployment in order to maintain secure state. It is important to ensure that security functions are tested because changes to ICT systems can often create new vulnerabilities.

Continuous improvement and documentation
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Risk management and leadership
Cyber security management
14
requirements

Examples of other requirements this task affects

PR.IP-7: Protection processes
NIST
10.2: Continuous improvement
ISO 27001
CC4.2: Evaluation and communication of internal control deficiencies
SOC 2
21.4: Non-conformities and corrective actions
NIS2
1.5.2: External review of ISMS
TISAX
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Continuous improvement and documentation
1. Task description

The organization shall continuously strive to improve the performance of the information security management system. Ways to improve are being actively sought - not just through audits or clear non-conformities.

Task owner is responsible for documenting the improvements made to the management system and dividing them into tasks to be performed, monitoring task execution and assessing the reached effects.

Regular analysis and utilization of information related to information security threats
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Development and cloud
Technical vulnerability management
13
requirements

Examples of other requirements this task affects

5.7: Threat intelligence
ISO 27001
23: Häiriöiden- ja poikkeamienhallintaprosessi
Digiturvan kokonaiskuvapalvelu
THREAT-2: Respond to Threats and Share Threat Information
C2M2
Article 13: Learning and evolving
DORA
3.3.4: Obtain and process threat information from relevant sources
NSM ICT-SP
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Regular analysis and utilization of information related to information security threats
1. Task description

Organization carries out threat intelligence by analyzing and utilizing collected information about relevant cyber security threats related and corresponding protections.

When analyzing and utilizing the collected threat intelligence information, the following points must be taken into account:

  • analyzing how the threat intelligence information relates to to our own operations
  • analyzing how relevant threat intelligence information is to our operations
  • communicating and sharing information in an understandable form to relevant persons
  • utilizing the findings of threat intelligence to determine the adequacy of technical protections, technologies used and information security testing methods for analysis

Tasks included in the policy

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

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38: Kiberuzbrukumu attiecināšana
NIS2 Latvia
1.1 (MIL2): Manage IT and OT Asset Inventory
C2M2
1.1 (MIL3): Manage IT and OT Asset Inventory
C2M2
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
1.1: Establish and Maintain Detailed Enterprise Asset Inventory
CIS 18
1.2 (MIL2): Manage Information Asset Inventory
C2M2
1.2 (MIL3): Manage Information Asset Inventory
C2M2
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: Address Unauthorized Assets
CIS 18
1.2: Manage Information Asset Inventory
C2M2
1.3 (MIL2): Manage IT and OT Asset Configuration
C2M2
1.3 (MIL3): Manage IT and OT Asset Configuration
C2M2
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
1.3: Utilize an Active Discovery Tool
CIS 18
1.4 (MIL2): Manage Changes to IT and OT Assets
C2M2
1.4 (MIL3): Manage Changes to IT and OT Assets
C2M2
1.4.1: Management of Information Security Risks
TISAX
1.4: Manage Changes to IT and OT Assets
C2M2
1.4: Use Dynamic Host Configuration Protocol (DHCP) Logging to Update Enterprise Asset Inventory
CIS 18
1.5 (MIL1): Management Activities for the ASSET domain
C2M2
1.5 (MIL2): Management Activities for the ASSET domain
C2M2
1.5 (MIL3): Management Activities for the ASSET domain
C2M2
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
1.5: Use a Passive Asset Discovery Tool
CIS 18
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
Kyberturvallisuuslaki
10. Processing of personal data relating to criminal convictions and offences
GDPR
10.1 (MIL2): Establish Cybersecurity Program Strategy
C2M2
10.1 (MIL3): Establish Cybersecurity Program Strategy
C2M2
10.1.1: Policy on the use of cryptographic controls
ISO 27001
10.1.2: Key management
ISO 27001
10.1.2: Key management
ISO 27017
10.1: Cryptographic controls
ISO 27001
10.1: Cryptographic controls
ISO 27017
10.1: Deploy and Maintain Anti-Malware Software
CIS 18
10.1: Establish Cybersecurity Program Strategy
C2M2
10.1: Non-conformity and corrective action
ISO 27001
10.2 (MIL2): Establish and Maintain Cybersecurity Program
C2M2
10.2 (MIL3): Establish and Maintain Cybersecurity Program
C2M2
10.2: Establish and Maintain Cybersecurity Program
C2M2
10.2: Configure Automatic Anti-Malware Signature Updates
CIS 18
10.2: Continuous improvement
ISO 27001
10.3 (MIL1): Management Activities for the PROGRAM domain
C2M2
10.3 (MIL2): Management Activities for the PROGRAM domain
C2M2
10.3 (MIL3): Management Activities for the PROGRAM domain
C2M2
10.3: Disable Autorun and Autoplay for Removable Media
CIS 18
10.3: Management Activities for the PROGRAM domain
C2M2
10.4: Configure Automatic Anti-Malware Scanning of Removable Media
CIS 18
10.5: Enable Anti-Exploitation Features
CIS 18
10.6: Centrally Manage Anti-Malware Software
CIS 18
10.7: Use Behavior-Based Anti-Malware Software
CIS 18
10: Cryptography
ISO 27001
10: Cryptography
ISO 27017
10: Cybersecurity Program Management (PROGRAM)
C2M2
10: Prosessi väärinkäytöksiin reagoimiseksi
Digiturvan kokonaiskuvapalvelu
11 §: Poikkeamailmoitukset viranomaiselle
Kyberturvallisuuslaki
11. Processing which does not require identification
GDPR
11.1.1: Physical security perimeter
ISO 27001
11.1.2: Physical entry controls
ISO 27001
11.1.3: Securing offices, rooms and facilities
ISO 27001
11.1.4: Protecting against external and environmental threats
ISO 27001
11.1.5: Working in secure areas
ISO 27001
11.1.6: Delivery and loading areas
ISO 27001
11.1: Establish and Maintain a Data Recovery Process
CIS 18
11.1: Secure areas
ISO 27001
11.2.1: Equipment siting and protection
ISO 27001
11.2.2: Supporting utilities
ISO 27001
11.2.3: Cabling security
ISO 27001
11.2.4: Equipment maintenance
ISO 27001
11.2.5: Removal of assets
ISO 27001
11.2.6: Security of equipment and assets off-premises
ISO 27001
11.2.7: Secure disposal or re-use of equipment
ISO 27001
11.2.7: Secure disposal or re-use of equipment
ISO 27017
11.2.8: Unattended user equipment
ISO 27001
11.2.9: Clear desk and clear screen policy
ISO 27001
11.2: Equipment
ISO 27001