Understanding the Digital Operational Resilience Act (DORA): A Comprehensive Guide for Financial Institutions.

30 April 2024

The Digital Operational Resilience Act (DORA) is a significant regulatory development within the European Union (EU), designed to enhance the resilience of the financial sector against digital risks. This article provides an overview of DORA, its objectives, scope, enforcement mechanisms, and key requirements for financial entities and their technology service providers.

What is DORA?

DORA, officially known as the Digital Operational Resilience Act, is an EU regulation aimed at establishing a robust framework for managing information and communication technology (ICT) risks in the financial services industry. It mandates technical standards for ICT systems and services, with a compliance deadline set for January 17, 2025.

Objectives of DORA:

DORA serves two primary objectives:

  1. To comprehensively address ICT risk management in the financial sector.
  2. To harmonise existing ICT risk management regulations across EU member states.

Pre-DORA Landscape:

Before DORA, EU regulations primarily focused on capital adequacy requirements for financial institutions, with limited guidance on ICT risk management. This led to a fragmented regulatory landscape across member states, making compliance challenging for financial entities.

Scope of DORA:

DORA applies to all financial institutions operating within the EU, including traditional banks, investment firms, and non-traditional entities such as crypto-asset service providers. It also covers third-party technology service providers supplying critical ICT systems to financial firms.

Enforcement Mechanisms:

Enforcement of DORA standards will be overseen by competent authorities in each EU member state. These authorities have the power to request security measures, impose penalties for non-compliance, and supervise critical ICT service providers. Lead overseers appointed by the European Supervisory Authorities (ESAs) will directly supervise critical ICT providers.

Key Requirements:

DORA mandates compliance with technical standards across four key domains:

  1. ICT risk management and governance.
  2. Incident response and reporting.
  3. Digital operational resilience testing.
  4. Third-party risk management.


DORA represents a significant step towards enhancing the digital resilience of the EU financial sector. By establishing a harmonized framework for ICT risk management, DORA aims to promote consistency, transparency, and accountability across member states. Financial institutions and their technology service providers must prioritise compliance with DORA requirements to mitigate digital risks effectively.

For further updates and insights on DORA compliance and its implications for financial institutions, please do not hesitate to contact us.



Theo Antoniou
Partner - Corporate and Financial Services Regulatory
Theo Antoniou is a Partner Solicitor at Spencer West. He specialises in Investment Funds, FinTech, Virtual Assets, MiCAR