The Digital Operational Resilience Act (DORA), passed by the European Union, marks a significant shift in how businesses manage and mitigate digital risks. Aimed primarily at financial institutions and critical service providers, DORA is designed to ensure that these entities remain operationally resilient despite digital disruptions, cyberattacks, and system failures. 

What organizations are subject to DORA? 

DORA impacts a wide range of entities, including 

• Banks and financial institutions 

• Payment processors and providers 

• Insurance firms 

• Information and Communications Technology (ICT) third-party service providers 

• Investment firms 

These organizations must adhere to DORA to safeguard the EU’s financial system from the cascading effects of digital disruptions. 

What does DORA require for compliance? 

DORA compliance revolves around several core pillars. 

• Risk Management: Organizations must implement comprehensive risk management frameworks that cover all aspects of their digital operations, from data integrity to security of systems.
• Incident Reporting: Institutions must establish a protocol for reporting significant digital incidents, ensuring that appropriate authorities are notified within specific timeframes.
• Testing: Regular testing of ICT systems is mandatory to ensure resilience against potential vulnerabilities.
• Operational Resilience Plans: Businesses need well-documented and executable plans to continue operations in the event of significant disruptions.
• Vendor Risk Management: One of the most stringent aspects of DORA is the focus on third-party vendor risk. Financial institutions must scrutinize their ICT third-party providers to ensure compliance with resilience standards. Vendor relationships need to be assessed, monitored, and managed to avoid introducing vulnerabilities into the organization. 

The stringency of vendor risk management 

DORA’s provisions for vendor risk management are particularly rigorous. Businesses must not only vet their vendors carefully but also have continuous oversight of their performance and compliance. Third-party providers must meet specific resilience standards, and contracts with these vendors must reflect the organization’s commitment to minimizing digital risk exposure. This heightened focus on third-party risk places significant responsibility on businesses to extend their operational resilience beyond their internal systems. 

DORA roll-out: A phased approach to compliance 

The roll-out of the EU’s DORA regulation is scheduled through January 2025. Key dates for businesses include 

• January 2023: DORA was formally adopted by the EU, marking the beginning of the awareness and preparation phase. 

• January 2025: This is the deadline by which businesses must be fully DORA compliant. By this date, financial institutions and relevant ICT service providers will be expected to implement the necessary frameworks and systems for digital operational resilience, including risk management, incident reporting, and vendor oversight. 

• Ongoing: Post-2025, supervisory authorities will start stringent enforcement, conducting audits and assessments to ensure continuous DORA compliance. Businesses will be required to regularly test their ICT systems, report significant incidents, and manage vendor risk proactively. 

Organizations should update internal processes and make sure that they align with DORA’s standards to avoid penalties and ensure operational resilience. 

HITRUST: Supporting DORA compliance

In this iteration of the HITRUST CSF, businesses will have the ability to assess and manage their DORA compliance efficiently. HITRUST, with its comprehensive risk management framework, will enable organizations to align with DORA’s requirements, particularly in areas like vendor risk management and operational resilience. As DORA continues to set the benchmark for operational resilience across the EU, HITRUST will ensure that businesses are equipped to meet these expectations, simplifying the certification process and maintaining the highest standards of security, privacy, and supply chain risk.