ISMS Copilot
Supported frameworks

Digital Operational Resilience Act (DORA)

The Digital Operational Resilience Act (DORA) is an EU regulation that establishes comprehensive ICT risk management requirements for the financial sector. Effective January 17, 2025, DORA harmonizes digital resilience standards across EU member states, ensuring financial entities can withstand and recover from ICT-related disruptions.

ISMS Copilot has dedicated knowledge of DORA requirements. You can ask framework-specific questions, generate policies aligned with DORA pillars, and assess compliance gaps using the AI assistant.

Who Needs DORA Compliance?

DORA applies to over 20,000 financial entities across the EU, including:

  • Banks and credit institutions

  • Insurance and reinsurance undertakings

  • Investment firms and trading venues

  • Payment institutions and electronic money institutions

  • Crypto-asset service providers

  • Critical ICT third-party service providers (cloud providers, data centers, software vendors serving financial entities)

Both large institutions and smaller financial entities must comply, though proportionality considerations apply based on size, business nature, and risk profile.

Five Pillars of DORA

DORA structures requirements into five key pillars:

  1. ICT Risk Management: Comprehensive frameworks for identifying, managing, and mitigating ICT risks, including governance, risk assessment, and business continuity

  2. Incident Reporting: Mandatory reporting of major ICT-related incidents to regulators within strict timelines (initial notification, intermediate reports, final analysis)

  3. Digital Operational Resilience Testing: Regular testing programs including vulnerability assessments, scenario analysis, and advanced threat-led penetration testing (TLPT) for critical entities

  4. Third-Party Risk Management: Rigorous oversight of ICT service providers, including contractual requirements, due diligence, monitoring, and exit strategies

  5. Information Sharing: Voluntary arrangements to share cyber threat intelligence and best practices among financial entities

Key Requirements

Financial entities must implement several mandatory capabilities:

  • ICT risk management framework: Documented policies, procedures, and controls aligned with the five pillars

  • Governance and accountability: Board-level oversight, clear roles and responsibilities, and management body involvement

  • Resilience testing: Annual testing programs, including TLPT for significant entities every three years

  • Incident classification and reporting: Systems to detect, classify, and report major incidents within specified timelines

  • Third-party registers: Maintain comprehensive records of all ICT service providers and contractual arrangements

  • Business continuity and disaster recovery: Plans and capabilities to maintain operations during disruptions

DORA imposes significant penalties for non-compliance, including fines up to 2% of global annual turnover for serious breaches.

Critical ICT Third-Party Providers

DORA introduces a unique oversight framework for critical ICT third-party service providers (TPPs). These providers face:

  • Direct regulatory oversight: Supervision by European Supervisory Authorities (ESAs)

  • Designation criteria: Based on systemic importance, substitutability, and services to multiple financial entities

  • Enhanced obligations: Risk management, incident reporting, and resilience testing requirements

If you provide cloud, data center, or critical software services to EU financial entities, you may fall under DORA's TPP regime.

How ISMS Copilot Helps

ISMS Copilot provides comprehensive support for DORA compliance:

  • Framework-specific guidance: Ask questions about specific DORA pillars, articles, or requirements

  • Policy generation: Create audit-ready ICT risk management policies, incident response procedures, and third-party management frameworks

  • Gap analysis: Upload existing documentation to identify gaps against DORA requirements

  • Risk assessments: Generate DORA-aligned ICT risk assessments for systems and third-party relationships

  • Incident response planning: Develop incident classification schemes and reporting workflows

  • Workspace organization: Manage DORA projects separately from other compliance initiatives

The AI has direct knowledge of DORA's structure and regulatory technical standards (RTS), so you can reference specific articles or pillars in your prompts.

Try asking: "Generate an ICT third-party risk assessment template aligned with DORA Article 28" or "What are the incident reporting timelines under DORA?"

Getting Started

To begin DORA compliance work in ISMS Copilot:

  1. Create a dedicated workspace for DORA compliance

  2. Ask the AI to explain specific pillars or requirements relevant to your organization type

  3. Generate foundational policies for ICT risk management and incident response

  4. Upload existing ICT policies for gap analysis

  5. Develop a third-party register and risk assessment process using AI guidance

  • Official DORA regulation text: EUR-Lex

  • European Supervisory Authorities (ESAs) guidance and regulatory technical standards

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