DORA Compliance

DORA Compliance for Fintech Companies in the EU

Our DORA compliance services, primarily serving EMIs, PIs and CASPs, cover ICT risk frameworks, continuity planning (BCP/DR), third-party oversight, TLPT/ICT scenario testing, and staff training. The outcome is a practical, regulator-aligned compliance program that works in day-to-day operations.

Regulators expect companies to demonstrate more than policies on paper. They require tested procedures, verifiable evidence and effective oversight of ICT providers. Developing such capabilities internally can be resource-heavy, which is why regulated companies choose to source their DORA compliance services from us.

We deliver frameworks that include policies, registers, playbooks, test reports, training records, and management briefings, aligned with DORA obligations and recognised standards such as ISO 27001. Our documentation is designed for internal governance and regulatory inspections, supporting continuous compliance. This enables to present verifiable evidence and deliver structured reporting.

Expert Support for DORA Compliance

Our EU-based teams combine legal, compliance, and technical expertise to deliver regulator-ready DORA frameworks that work in practice.

Book a meeting with our team today!

How We Deliver DORA Compliance in Practice

Our Three-Pillar Approach

We deliver DORA (The Digital Operational Resilience Act, EU Regulation 2022/2554) compliance through a structured methodology built around three core pillars. Each step produces regulator-ready documentation and evidence while ensuring the framework remains proportionate, effective and workable for daily operations.

1

Readiness & Gap Assessment for DORA Alignment

We establish your starting point and a proportionate plan to reach compliance.

  • Governance review: assess ICT governance, risk registers, incident handling.
  • Continuity & outsourcing: review BCP/DR and provider agreements.
  • Remediation roadmap: prioritised findings, owners, milestones, timelines.
  • Management baseline: summary suitable for supervisory discussions.
2

Implementation of Policies, Controls & Governance

We operationalise DORA requirements and align roles, approvals, and oversight.

  • Policy & registers: full DORA set tailored to operations.
  • Governance alignment: roles, escalation chains, accountability.
  • Playbooks & controls: incident, continuity, oversight procedures.
  • Contractual addenda: audit rights, duties, exit strategies.
3

Testing, Training & Ongoing Compliance

We evidence that arrangements work in practice and remain maintained over time.

  • ICT scenario testing & TLPT scope (where applicable).
  • Remediation tracking: evidence of gap closure.
  • Staff & management training: attendance records maintained.
  • Ongoing monitoring: review cycles and metrics.

What it Takes to Achieve DORA Compliance

Key Services for DORA Compliance and ICT Risk Management

We can support at all stages of the DORA compliance journey while taking care of all cybersecurity measures and policies required. We provide companies with tools and documentation that withstand regulatory scrutiny while remaining workable in daily operations. Each area is supported by evidence, registers, and reporting mechanisms, ensuring compliance is demonstrable and sustainable.

A core requirement of DORA is the establishment of a structured ICT risk management framework that demonstrates both accountability and proportionality. Regulators expect companies to maintain verifiable processes that show risks are identified, assessed, and governed in line with compliance obligations.

We support with designing and documenting ICT risk frameworks that meet these expectations while remaining practical for daily operations. This includes the preparation of risk registers that categorise ICT threats, control mappings that connect risks to mitigation measures, and escalation procedures that ensure incidents are reported and addressed in a timely manner. Governance structures are aligned so ICT risks are integrated into overall management oversight and board reporting.

The outcome is not only a documented risk framework but a defensible system that can be presented to regulators during inspections or supervisory dialogue. Our approach ensures companies can demonstrate that ICT risks are actively monitored, proportionately mitigated, and continuously reviewed, fulfilling the key obligations of DORA compliance in a regulator-ready manner.

Under DORA, companies must show they can detect, escalate, and recover from ICT-related disruptions within defined timeframes. Regulators expect clear escalation paths, crisis communication procedures, and documented recovery objectives. Two key metrics are the Recovery Time Objective (RTO), the maximum time a service may be unavailable, and the Recovery Point Objective (RPO), the maximum tolerable data loss measured in time.

We design incident playbooks, escalation workflows, and Business Continuity and Disaster Recovery (BCP/DR) arrangements that address both internal processes and third-party dependencies. Our work includes conducting business impact assessments, setting measurable recovery objectives, and organising test exercises that validate plans in practice.

The outcome is a tested and regulator-ready framework that ensures disruptions can be managed effectively, recovery targets are realistic and evidenced, and continuity measures are integrated into daily operations in line with DORA compliance requirements.

DORA places strong emphasis on risks arising from ICT service providers and outsourcing arrangements.

Regulators expect companies to maintain registers of critical providers, perform due diligence and ongoing assessments, and ensure contracts include enforceable provisions such as audit rights, resilience obligations, and exit strategies. These requirements aim to reduce dependency risks and ensure operational continuity even if a provider fails.

We establish oversight frameworks that classify vendors by risk level, assess their resilience, and document clear exit plans. Where required, we coordinate resilience testing, including Threat-Led Penetration Testing (TLPT) for entities in scope, and prepare verifiable evidence for regulators.

The outcome is a structured and defensible system of third-party oversight. Companies gain visibility into their ICT supply chain, maintain regulator-ready documentation, and demonstrate that outsourcing risks are actively managed in line with DORA compliance requirements.

An effective DORA compliance framework depends on a maintained and consistent set of policies, procedures, and evidence logs. Regulators require companies not only to adopt written rules but to demonstrate that they are actively implemented, regularly reviewed, and tailored to the business model. Policies must cover ICT risk management, incident response, third-party oversight, and testing obligations, all mapped directly to the regulation.

We prepare and adapt full documentation sets, including policies, registers, playbooks, and logs, ensuring they are aligned with both regulatory obligations and operational practices. Each document is drafted in a regulator-ready format, clearly referencing the relevant articles of DORA and integrated into the company’s governance structure.

The result is a coherent compliance library that can withstand supervisory review, reduce ambiguity during audits, and provide management with clear guidance. Companies benefit from a system that is not theoretical but embedded into daily operations, with documentation that both supports staff and satisfies regulatory scrutiny.

Timely incident reporting is a cornerstone of DORA compliance. Regulators require companies to detect ICT-related incidents, escalate them internally, notify authorities when thresholds are met, and maintain verifiable records of incidents and remediation. Failure to demonstrate structured reporting can lead to supervisory findings and sanctions.

We assist companies in implementing reporting procedures aligned with DORA’s incident classification and notification standards. This includes designing escalation protocols, maintaining incident registers, and preparing external notification templates for regulatory submissions. We also ensure companies have logs of remediation actions and testing results, which provide evidence of continuous improvement.

The outcome is a compliant incident reporting system that demonstrates accountability and preparedness. Companies can show regulators that incidents are recorded, assessed, and reported in line with legal obligations, while also using the process to strengthen internal resilience.

DORA requires companies to ensure that staff, management, and boards understand their roles in maintaining ICT risk management and operational stability. Regulators expect evidence of structured training programmes, attendance logs, and awareness initiatives that embed digital resilience into daily operations and decision-making.

We provide targeted training sessions for senior management, compliance teams, and operational staff. Content covers ICT risk awareness, incident response protocols, third-party oversight duties, and regulatory reporting expectations. Programmes are customised to the company’s business model, ensuring relevance and engagement. Attendance is tracked, and participants receive updated materials as regulations evolve.

The result is a workforce that is informed, accountable, and capable of responding to ICT disruptions in line with regulatory expectations. By documenting training sessions and outcomes, companies can demonstrate to regulators that operational resilience is not limited to policies, but is actively supported and maintained across the organisation.

DORA is not a one-time exercise but a continuous compliance obligation. Regulators expect companies to demonstrate that ICT risk frameworks, continuity arrangements, and third-party oversight remain up to date as systems, providers, and threats evolve. Regular reviews and monitoring cycles are therefore a critical part of maintaining compliance and avoiding supervisory findings.

We support companies by establishing monitoring routines and review schedules that fit their operational model. This includes scheduled policy reviews, periodic testing of continuity and recovery procedures, supplier re-assessments, and updates to risk registers. Evidence logs are maintained so that every review and remediation step can be demonstrated to regulators upon request.

The outcome is a living compliance framework that evolves with the company and the threat landscape. By embedding monitoring and reviews into governance, organisations can show regulators that they are not only compliant at a single point in time but consistently sustaining digital operational resilience in line with DORA obligations.

FAQ: Frequently Asked Questions

Which types of companies face the strictest obligations under the Digital Operational Resilience Act (DORA)?

While DORA applies to all financial entities in scope, larger institutions and those providing critical services, such as major EMIs, PIs, and CASPs, will face heightened regulatory scrutiny. These companies may be designated for advanced requirements such as Threat-Led Penetration Testing (TLPT) and more frequent reporting.

What are the core obligations and requirements introduced by DORA?

DORA sets mandatory rules for ICT risk management, incident detection and reporting, business continuity and disaster recovery (BCP/DR), third-party oversight, resilience testing, and training. All obligations must be documented, tested, and demonstrable to regulators.

Under what conditions is Threat-Led Penetration Testing (TLPT) required?

TLPT is required for entities considered critical based on size, systemic importance, and risk exposure. Supervisory authorities will identify which companies must undergo TLPT and specify the testing frequency.

How does the DORA incident classification and reporting process work in practice?

Companies must classify ICT-related incidents by severity, notify regulators within strict timeframes, and provide follow-up reports. Each report must show the timeline, mitigation measures, and corrective actions taken, supported by evidence.

How does DORA interact with existing EU regulations such as GDPR and NIS2?

DORA complements rather than replaces GDPR and NIS2. For example, a cyber incident may trigger reporting obligations under both GDPR (personal data breaches) and DORA (ICT operational disruption). Companies must align policies to avoid duplication and ensure consistency across frameworks.

What does DORA expect from companies when outsourcing ICT functions or using third-party providers?

Companies must maintain vendor registers, conduct risk assessments, and ensure contracts contain audit rights, resilience clauses, and exit strategies. Continuous monitoring of ICT providers is expected, not just one-time due diligence.

What documentation and evidence will regulators typically request during inspections?

Regulators will ask for ICT risk registers, incident logs, continuity and recovery test results, third-party oversight records, staff training logs, and management reporting packs. Evidence must show not only that policies exist, but that they are tested and effective in practice.

How long does DORA compliance implementation usually take, and what factors influence the timeline?

Implementation typically takes several months, depending on the company’s size, risk profile, and existing ICT maturity. Factors such as legacy systems, reliance on multiple third-party providers, and the need for advanced testing (like TLPT) can extend the timeline.

Questions? Book an Introductory call with our Compliance Team!

Book a meeting for DORA readiness

We provide a step-by-step plan and documentation checklist after a short discovery call. Our methodology follows a mapped control framework to ensure full coverage of DORA obligations and evidence requirements. Please contact our compliance team through the contact form below and we will revert shortly.

    Contact details

    Please contact us to schedule a meeting with our compliance projects manager.