The Digital Operational Resilience Act (DORA Regulation) is an EU regulation designed to ensure that financial organizations can continue operating even when digital systems fail, are attacked, or experience disruption.

In simple terms, DORA is about making sure technology problems do not become business-stopping events.

Unlike earlier regulations that focused mainly on policies or risk assessments, DORA looks at how organizations actually operate under pressure — during cyber incidents, system outages, or failures caused by third-party providers.

DORA applies not only to banks and insurance companies, but also to a wide range of financial entities and the ICT service providers they rely on, including cloud platforms, SaaS vendors, and managed service providers. This makes digital resilience a shared responsibility across the financial ecosystem, not an isolated compliance task.

What makes DORA different is its emphasis on continuous operational resilience:

• real-time visibility into ICT risks
• early detection of incidents
• structured response and reporting
• and ongoing testing of digital resilience

For many organizations, this requires a shift in mindset. DORA is not about preparing for an audit once a year it is about being able to demonstrate control and resilience every day.

Organizations that understand their exposure early can approach DORA in a structured, calm way  strengthening operations without disrupting the business.

Who Does the DORA Regulation Apply To? (Not Only Banks)

The DORA Regulation applies to a much broader audience than many organizations initially expect.

It is not limited to traditional banks or large financial institutions.

At its core, DORA covers financial entities operating within the EU, including:

• banks and credit institutions
• insurance and reinsurance companies
• investment firms and asset managers
• payment institutions and electronic money providers
• crypto-asset service providers

However, one of the most important aspects of DORA is that it also extends beyond the financial institutions themselves.

ICT and Third-Party Service Providers Are in Scope

DORA explicitly recognizes that financial entities rely heavily on external technology providers.

As a result, ICT third-party service providers play a critical role in digital resilience.

This includes organizations providing:

• cloud infrastructure and hosting services
• SaaS platforms used for core operations
• data analytics and processing services
• managed IT and security services

Even if an organization is not a financial entity, it may still fall under DORA indirectly if it provides critical ICT services to regulated financial clients.

What About Non-EU Organizations?

DORA is not limited by geography.

Non-EU companies that support EU-based financial institutions — for example, cloud providers or SaaS vendors headquartered outside Europe — may still be subject to DORA-related requirements through contractual and regulatory obligations.

In practice, this means many global technology providers will need to demonstrate:

• operational resilience
• incident handling capabilities
• and ongoing risk management

to remain trusted vendors for EU financial organizations.

Why This Scope Matters?

The wide scope of DORA reflects a simple reality:

a financial organization’s resilience is only as strong as the technology ecosystem it depends on.

For many companies, discovering they are “in scope” is the first real trigger to assess digital resilience seriously — not as a future requirement, but as a current operational risk.

What Are the Core DORA Requirements?

DORA is structured around one central expectation:

organizations must be able to continue operating safely even when digital disruptions occur and prove it with evidence.

To achieve this, the regulation defines several core requirement areas that every in-scope organization must address.

The table below summarizes what DORA requires — and what regulators expect to see in practice.

Core DORA Requirements – Overview

DORA Requirement Area	What DORA Requires	What This Means in Practice
ICT Risk Management	Continuous identification and management of ICT risks	Knowing which systems are critical, what can fail, and who is responsible
Incident Detection & Reporting	Early detection, classification, and timely reporting of ICT incidents	Real-time visibility, clear severity levels, and documented response
Digital Resilience Testing	Regular testing of systems and controls	Proving resilience through realistic scenarios, not assumptions
Third-Party Risk Management	Control and oversight of ICT service providers	Understanding supplier dependencies and monitoring them continuously
Governance & Accountability	Clear ownership at management level	Defined roles, reporting lines, and decision-making authority

 

ICT Risk Management: Understanding What Can Break

DORA requires organizations to actively manage ICT risks across their environment.

This includes identifying critical assets, understanding system dependencies, and implementing controls that reduce both likelihood and impact of failures.

The emphasis is on ongoing risk management, not one-time assessments.

Incident Detection, Classification, and Reporting

Organizations must be able to detect ICT-related incidents early and understand their impact quickly.

DORA expects structured processes that define what constitutes an incident, how it is classified, and when it must be reported.

Without real-time detection and clear classification, compliance becomes reactive and risky.

Digital Operational Resilience Testing

DORA mandates regular testing to validate that controls work under stress.

This includes technical testing and scenario-based exercises that reflect real operational threats.

The goal is simple: prove that resilience exists — before an incident happens.

ICT Third-Party Risk Management

External providers are treated as an extension of the organization’s risk surface.

DORA requires visibility into supplier risks, contractual safeguards, and the ability to respond if a critical provider fails.

Vendor risk is no longer optional it is a regulated responsibility.

Governance and Accountability

DORA places accountability squarely on management.

Regulators expect to see who owns ICT risk decisions, how issues are escalated, and how resilience is governed at the organizational level.

“Shared responsibility” without ownership is no longer sufficient.

What DORA Expects in Practice?

DORA does not evaluate intentions or documentation alone – it evaluates behavior over time.

Regulators want to understand how an organization actually operates when something goes wrong.

In practice, this means moving from statements like “we have controls” to clear answers to questions such as:

• What did you detect?
• When did you detect it?
• How did you respond?
• Who made the decision?
• What changed afterward?

A Realistic Example from the Field

A mid-size financial services firm operating in the EU experienced an unusual access pattern from a third-party SaaS integration used for reporting.

The activity did not immediately cause an outage and would have gone unnoticed in a traditional, alert-heavy environment.

However, continuous monitoring identified:

• an abnormal authentication sequence
• a deviation from normal API usage
• and a change in data access volume

Because the activity was detected early, the organization:

• isolated the integration
• validated that no sensitive data was exfiltrated
• documented the event and response
• and updated third-party access controls

From a DORA perspective, the key point was not that an incident occurred — but that the organization could demonstrate visibility, decision-making, and corrective action.

What Regulators Are Really Looking For?

Under DORA, regulators expect to see:

• continuous monitoring, not periodic reviews
• evidence of real incident handling, not theoretical playbooks
• clear accountability for decisions and escalation
• learning and improvement after events

An organization that can show this level of operational maturity is not only compliant — it is resilient.

Where Organizations Commonly Fail with DORA?

Most organizations do not fail DORA because of missing policies — they fail because of operational gaps.

The documentation exists, but the day-to-day reality does not support it.

The most common failure points include:

Lack of Real-Time Visibility

Organizations often lack a clear view of what is happening across cloud systems, SaaS platforms, users, and third parties.

Without continuous visibility, incidents are detected too late — or not at all.

Fragmented Monitoring

Logs exist, but they are scattered across systems with no correlation.

This makes it difficult to understand context, assess impact, or respond quickly.

No Clear Decision-Making in Real Time

When something unusual happens, no one is clearly responsible for deciding what to do next.

Delays in escalation turn small issues into reportable incidents.

Over-Reliance on Vendors

Many organizations assume their cloud or SaaS providers will handle resilience for them.

Under DORA, responsibility remains with the organization — even when the failure originates from a third party.

Reactive Incident Handling

Incidents are handled after disruption occurs, rather than being detected and contained early.

DORA explicitly aims to eliminate this reactive model.

In most cases, the issue is not lack of effort — it is lack of continuous, connected operational control.

Continuous Monitoring and Accountability Under DORA

DORA does not separate technology from responsibility.

It expects organizations to monitor continuously and know who is accountable when something happens.

Without real-time visibility, management cannot make informed decisions.

Without clear ownership, monitoring has no operational value.

Why Continuous Monitoring Is Not Optional

DORA assumes that ICT incidents will happen.

The real question is whether the organization can detect them early and respond correctly.

Continuous monitoring enables:

• early identification of abnormal activity
• understanding of impact on critical systems
• evidence-based incident handling

This is the foundation of operational resilience.

From Monitoring to Decision-Making

DORA does not require reacting to every alert — it requires making the right decisions at the right time.

An effective monitoring capability:

• reduces noise
• highlights events with real business or regulatory impact
• provides context for fast, informed decisions

This is where operational resilience becomes practical, not theoretical.

Who Is Accountable Under DORA?

DORA expects to see clear ownership.

Not “shared responsibility”, and not “handled by IT”.

Management must be able to demonstrate:

• who oversees ICT risk
• who approves responses during incidents
• how decisions are escalated and documented

Whether fulfilled by an internal role or a managed security leadership model, accountability must be explicit and provable.

What Regulators Ultimately Look For?

Under DORA, regulators want to see:

• continuous visibility
• structured decision-making
• documented response
• and clear accountability

When monitoring and governance work together, compliance becomes a byproduct of good operations — not a separate effort.

How DORA Fits Within the Broader Regulatory Landscape

DORA does not replace existing cybersecurity or privacy regulations — it connects them operationally.

Its role is to make sure that what organizations claim in other frameworks is actually enforced, monitored, and tested in real time.

For example, standards like ISO/IEC 27001 focus on building an information security management system: policies, risk assessments, and controls.

DORA takes this one step further by asking: does this system hold up during real operational stress?

Similarly, SOC 2 compliance frameworks emphasize trust, control effectiveness, and consistency over time.

DORA aligns closely with this approach but adds regulatory enforcement and clear expectations around incident handling and third-party resilience.

DORA also complements regulations such as GDPR and NIS2.

While GDPR focuses on personal data protection and NIS2 on network and infrastructure security, DORA addresses the operational layer that ties them together — especially during ICT incidents that affect availability, integrity, or continuity.

In practice, organizations that already work according to recognized standards are not starting from zero.

However, DORA requires them to close the gap between governance and day-to-day operations, particularly in monitoring, response, and accountability.

This is why DORA is often described not as “another regulation,” but as a framework that forces existing controls to work together — under pressure, and in real time.

DORA Is About Responsibility, Not Just Compliance

At its core, the DORA Regulation is not about ticking regulatory boxes.

It is about operational responsibility — knowing what is happening in your digital environment, understanding the risk, and being able to act before disruption turns into damage.

Organizations that treat DORA as a documentation exercise often discover the gaps only when something breaks:

an incident that wasn’t detected in time, a third-party failure with no visibility, or a response process that exists only on paper.

Organizations that approach DORA correctly gain more than compliance.

They gain:

• clearer operational control
• faster decision-making during incidents
• reduced dependency risk
• and confidence when facing regulators, customers, and partners

This level of resilience does not come from a single tool or annual assessment.

It comes from connecting monitoring, governance, testing, and accountability into one operational picture.

At CyberSafe, we help organizations bridge that exact gap  between regulation and reality.

By combining continuous monitoring, operational security leadership, and resilience-focused practices, we support organizations in building measurable, defensible digital resilience, aligned with DORA’s real expectations.

If you want to understand where your organization stands  and what needs to be strengthened before DORA enforcement becomes a risk the right first step is visibility.

Frequently Asked Questions – DORA Regulation

What is the DORA Regulation in simple terms?

The DORA Regulation is an EU law that requires financial organizations to stay operational during cyber incidents, system failures, or third-party outages.

Its goal is to ensure that digital disruptions do not stop critical financial services.

Who must comply with DORA?

DORA applies to financial entities operating in the EU and to ICT service providers that support them.

This includes banks, insurers, payment providers, crypto service providers, and also cloud, SaaS, and technology vendors that deliver critical services to those entities.

Does DORA apply to non-EU companies?

Yes, in many cases. Non-EU organizations must align with DORA if they provide ICT services to EU financial institutions, usually through contractual and regulatory obligations imposed by their clients.

What does DORA require beyond policies and documentation?

DORA requires proof of how an organization operates in practice.

Regulators expect evidence of continuous monitoring, early incident detection, structured response, third-party oversight, and clear accountability — not just written procedures.

What is considered an ICT incident under DORA?

An ICT incident under DORA is any event that affects the availability, integrity, confidentiality, or continuity of digital systems supporting financial services.

This includes cyberattacks, system outages, cloud failures, and significant third-party disruptions.

How is DORA different from ISO 27001?

ISO 27001 focuses on building an information security management system.

DORA focuses on operational resilience — how systems, people, and processes behave during real disruptions and whether the organization can continue operating safely.

How does DORA relate to SOC 2?

SOC 2 demonstrates control effectiveness and trust over time, mainly for customers and partners.

DORA adds regulatory enforcement and specific operational resilience requirements, especially around incident handling and third-party risk.

Is continuous monitoring required under DORA?

Yes. DORA assumes incidents will happen, so organizations must detect them early through continuous monitoring rather than periodic reviews or audits.

Who is responsible for DORA compliance inside the organization?

Responsibility lies with management.

DORA expects clear ownership, defined roles, and documented decision-making — not vague or shared responsibility across teams.

What happens if an organization is not ready for DORA?

Lack of readiness can lead to regulatory findings, operational disruption, reputational damage, and increased supervisory scrutiny.

More importantly, it exposes the organization to real business risk during digital incidents.