Published on: August 14, 2025 at 12:04 AM

DORA Compliance Checklist

The financial industry is undergoing a digital revolution. Cloud computing, data analytics, AI, and interconnected systems are bringing unmatched innovation — but they also expose financial entities to growing operational and cybersecurity threats. In response, the European Union introduced the Digital Operational Resilience Act (DORA), a regulation that sets strict and unified standards for managing ICT (Information and Communication Technology) risks across all EU financial entities.

DORA, effective from January 17, 2025, ensures that financial institutions can prevent, withstand, recover from, and learn from ICT-related disruptions. Unlike voluntary frameworks or regional guidelines, DORA is binding and introduces specific legal obligations across five main pillars: ICT risk management, incident reporting, digital operational resilience testing, third-party risk, and information sharing. This blog outlines a comprehensive DORA compliance checklist, combining narrative explanation with actionable points and professional insight to guide your organization’s readiness.

Step 1: Build a Comprehensive ICT Risk Management Framework

Every organization covered by DORA must develop and maintain an internal ICT risk management framework tailored to its size, complexity, and risk profile. The goal is to maintain control over digital assets, detect vulnerabilities proactively, and ensure continuity of services during adverse events.

Key components of this framework include:

• Identification and classification of ICT assets and their criticality
• Documentation of all business functions and mapping to supporting ICT systems
• Definition of acceptable ICT risk tolerance and thresholds
• Implementation of preventive and detective security controls such as:
  • Firewalls, IDS/IPS, endpoint security
  • Identity and access management (IAM)
  • Data encryption and secure configurations
  • Network segmentation and secure coding practices
• Periodic testing and updating of controls, including threat modeling and vulnerability assessments
• Centralized risk register with ownership assignments and mitigation strategies

In short, your ICT risk management strategy must be embedded across operations — not isolated within IT. Risk awareness and reporting should extend from technical teams to executive management.

Step 2: Formalize ICT Incident Response and Reporting Procedures

Operational resilience hinges on the speed and effectiveness of incident response. DORA mandates financial institutions to establish end-to-end incident management policies that can rapidly detect, categorize, escalate, and recover from ICT disruptions.

To achieve this, institutions must:

• Set up automated monitoring tools to detect security incidents and system failures
• Define severity levels and classification criteria (major, significant, minor)
• Establish clear escalation paths and assign communication responsibilities
• Maintain an incident response playbook with predefined workflows for common scenarios (e.g., ransomware, data breach, cloud outage)
• Train teams regularly through tabletop exercises and simulations

DORA also enforces a structured regulatory reporting regime for major ICT-related incidents. Reporting must be done in three phases:

1. Initial Notification: Within strict timeframes, describing the nature and estimated impact
2. Intermediate Report: A follow-up with more detailed findings and ongoing mitigation efforts
3. Final Report: A conclusive document with root cause analysis, lessons learned, and recovery actions

Post-incident reviews must be conducted after every significant event to analyze failures, refine processes, and enhance future readiness. Documentation of these reviews is a regulatory requirement and should be available during audits.

Step 3: Conduct Operational Resilience Testing

Resilience testing validates your readiness under stress. DORA requires financial institutions to plan and execute periodic testing exercises that evaluate the integrity and recovery capabilities of ICT systems supporting critical or important functions.

Types of resilience testing include:

• Business Continuity Tests: Evaluating the organization’s ability to maintain operations during disruptions
• Disaster Recovery Drills: Verifying system backups, failover processes, and data restoration timelines
• Penetration Testing: Simulating attacks to identify technical vulnerabilities
• Scenario-Based Testing: Running simulations such as insider threats, supply chain breaches, or ransomware attacks

For entities deemed systemically important, DORA introduces Threat-Led Penetration Testing (TLPT). This advanced form of red teaming mimics real-world attackers, requires third-party certified testers, and must adhere to EU testing frameworks.

Every test should be documented and include:

• Test objectives and scope
• Methodology and tools used
• Findings, including exploited vulnerabilities
• Corrective measures and responsible owners

An annual testing strategy, approved by senior management, is required to define frequency, coverage, and alignment with identified risks.

Step 4: Strengthen Governance and Internal Oversight

DORA places ultimate accountability for ICT risk with the board of directors. Compliance, therefore, cannot be delegated to IT alone — it requires structured governance and an enterprise-wide commitment.

Governance under DORA includes:

• Board-approved ICT strategy aligned with business objectives
• Defined roles and responsibilities across the three lines of defense (business, risk/control, and audit)
• Regular board briefings and ICT risk reporting
• Appointment of a DORA compliance officer or function
• Training programs for board members and senior executives on digital resilience

Internal audit functions must periodically assess the maturity and effectiveness of the ICT risk management framework and report directly to the board. Accountability should be clearly assigned across all layers, with documented policies and escalation procedures.

Step 5: Manage ICT Third-Party and Outsourcing Risks

Modern financial institutions rely heavily on external ICT service providers — cloud vendors, software suppliers, managed services — which introduces dependency and concentration risks. DORA enforces stricter rules around third-party risk management.

Institutions must maintain a centralized register of all ICT third-party providers that includes:

• Names and services delivered
• Criticality assessments (i.e., whether they support important functions)
• Geographic location and legal jurisdiction

For each critical ICT outsourcing arrangement, contracts must contain specific clauses to meet DORA requirements:

• Data protection and information security obligations
• Audit and inspection rights for the financial institution and regulators
• Business continuity provisions and testing rights
• Termination rights and clear exit strategies

Before onboarding a provider, organizations must perform comprehensive due diligence. Ongoing monitoring, periodic reviews, and performance metrics must be built into the vendor lifecycle. Institutions must also test their ability to switch providers or bring services in-house without business disruption.

Step 6: Ensure Documentation and Audit Readiness

Documentation is the backbone of DORA compliance. Institutions must maintain clear, up-to-date, and version-controlled records demonstrating their operational resilience efforts.

Required documentation includes:

• ICT policies, standards, and procedures
• Risk assessments and control test results
• Incident logs and post-incident reviews
• Training records and test reports
• Vendor registers and contracts
• Meeting minutes from board and governance committees

All documents should be stored in secure repositories with role-based access controls. Regulatory authorities may request these records at any time, so organizations must be prepared for inspections and audits.

Step 7: Engage Effectively with Regulators

DORA introduces greater supervisory powers for regulators, including the ability to conduct audits, inspect third-party providers, and request information directly. Institutions must therefore maintain proactive and transparent relationships with their national competent authorities.

To prepare for regulator interactions, institutions should:

• Appoint points of contact for regulatory communication
• Track and respond to DORA-related inquiries promptly
• Submit incident reports and testing summaries on time
• Maintain readiness for on-site inspections and document requests

Regulators will assess not just compliance, but organizational culture. Demonstrating a proactive, resilient posture — rather than ticking boxes — will be crucial for long-term success.

Conclusion

The Digital Operational Resilience Act is more than a regulation — it is a call to action for the financial sector to rethink how it manages technology risk. It creates a harmonized, mandatory standard across the EU that shifts operational resilience from a nice-to-have to a core business requirement.

By following the DORA compliance checklist outlined in this blog — from risk frameworks and incident response to governance, testing, and third-party oversight — institutions can build a robust foundation for secure, uninterrupted operations in a volatile digital world. Compliance will require significant effort, investment, and coordination — but it will also deliver long-term benefits in terms of trust, agility, and regulatory certainty.

With the implementation date fast approaching, the time to act is now. Assess your organization’s current state, close the compliance gaps, and align your technology, people, and governance to DORA’s expectations. In doing so, you'll not only meet regulatory demands — you'll fortify your organization for the future of finance.