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DORA Compliance: Checklist for 2025

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DORA Compliance Checklist for 2025

Financial organizations across Europe are actively preparing for the Digital Operational Resilience Act (DORA), taking effect in January 2025. Meeting DORA compliance requirements has become essential for financial institutions as they adjust their operations to match new regulatory standards. The legislation brings substantial changes to information and communication technology (ICT) risk management practices, security protocols, and third-party oversight. These requirements affect daily operations, risk assessments, and technology infrastructure management across the financial sector.

Organizations need clear, practical steps to achieve and maintain DORA compliance while strengthening their operational resilience. This guide outlines the crucial compliance requirements and provides actionable steps through a detailed DORA compliance checklist to help you evaluate current preparedness, identify gaps, and implement necessary changes to meet regulatory expectations before the deadline.

Understanding DORA Compliance Fundamentals

DORA compliance requires financial organizations to meet specific standards and regulations.

What is DORA and Its Purpose

The Digital Operational Resilience Act (DORA) is a European Union regulation designed to strengthen the financial sector’s technology infrastructure. Introduced in December 2022, DORA creates uniform standards for managing digital risks across EU financial entities. The regulation focuses on ICT risk management, incident reporting, and system testing requirements. The European Banking Authority oversees these standards to ensure consistent implementation throughout EU member states.

Key Stakeholders and Scope of Application

These organizations fall under DORA regulations:

  • Credit institutions and payment service providers
  • Investment firms and fund managers
  • Trading venues and central securities depositories
  • Insurance and reinsurance companies
  • Crypto-asset service providers
  • ICT third-party service providers to financial entities

Organizations must evaluate their risk management practices to ensure that they meet DORA standards. The regulations require financial institutions to maintain essential operations during disruptions, implement reliable backup systems, and establish clear recovery procedures.

DORA sets specific guidelines for incident classification and reporting timeframes. Financial institutions must establish direct communication channels with supervisory authorities and maintain accurate records of their ICT systems and risk management procedures. These requirements help create reliable financial services while protecting customer data and maintaining operational stability.

Essential DORA Compliance Requirements

Financial organizations seeking DORA compliance must focus on three essential components that work together to ensure security and operational continuity. Each element serves specific functions in maintaining technical resilience and protecting sensitive operations.

ICT Risk Management Framework

The core requirement for DORA compliance starts with a well-structured ICT risk management framework. Drawing from European Insurance and Occupational Pensions Authority guidelines, companies must create specific policies that address technology risk identification and control. This includes keeping detailed records of mission-critical systems, tracking technology assets, and setting up consistent schedules for reviewing risk management practices.

Incident Management and Reporting

Precise incident handling procedures stand as another key requirement for financial institutions. These procedures must enable fast identification and handling of ICT incidents. Companies need to sort incidents into categories based on their potential damage and urgency, with each category having its own reporting schedule. Serious disruptions require immediate notification to regulators, often within a few hours. Organizations should keep thorough records of all incidents and examine them afterward to strengthen their prevention methods.

Digital Operational Resilience Testing

Testing ICT systems and security measures helps organizations find and fix weaknesses early. Financial institutions must perform several types of evaluations, such as security scans, penetration tests, and real-world scenario assessments. While testing requirements change depending on company size, every organization needs to document their testing methods and outcomes thoroughly.

Implementing a DORA Compliance Checklist

Financial organizations need practical implementation steps to maintain DORA compliance effectively. The right structured approach creates a strong operational resilience program while ensuring that all requirements receive proper attention.

Risk Assessment and Documentation

Organizations must start with thorough mapping of their critical ICT assets and services. The Basel Committee on Banking Supervision requires financial institutions to keep detailed records of technology resources and conduct systematic threat evaluations. This process includes mapping system interdependencies, setting recovery time objectives, and assigning clear ownership for every system component.

Third-Party Risk Management

Successful oversight of third-party relationships demands consistent monitoring and assessment practices. Financial firms need service level agreements that meet DORA standards, regular evaluations of critical service providers, and contingency plans for essential services. Contract reviews must verify the inclusion of required incident reporting guidelines and measurable performance standards.

Continuous Monitoring Strategies

Strong monitoring systems combine technology tools with expert staff knowledge to observe system health and identify potential problems. Essential monitoring elements include:

  • Real-time performance measurement with automated warning systems
  • Scheduled security testing and weakness identification
  • Regular testing and updates to incident response procedures
  • Complete records of monitoring methods and findings
  • Periodic assessment of monitoring threshold accuracy

Monitoring methods should match your organization’s acceptable risk levels and operational requirements. Frequent evaluations help maintain monitoring effectiveness as security threats continue to develop. Teams must record all monitoring tasks and establish reliable communication paths between technical staff and leadership.

Data Protection Solutions for DORA Compliance

Data protection forms an essential part of meeting DORA compliance standards. Financial institutions must put strong backup and recovery mechanisms in place that satisfy regulatory guidelines while keeping their operations running smoothly.

Backup and Recovery Requirements

DORA specifies strict backup requirements for protecting financial data and maintaining reliable operations. Financial organizations need automatic backup systems that preserve both data and associated metadata, giving them full restore capabilities when needed. Following ENISA’s risk management guidelines, banks and other financial companies should store backups across different geographic locations and use encryption to secure data whether it’s moving between systems or stored in databases.

How Trilio Supports DORA Compliance

Trilio’s Backup and Recovery platform meets critical DORA compliance needs through native cloud protection features. The system creates consistent backups across Kubernetes, OpenStack, and KubeVirt platforms, helping financial institutions maintain smooth operations during any disruptions. Users get access to specific point-in-time recovery options, scheduled automatic backups, and precise restore capabilities.

The platform works smoothly with existing systems and supports multiple storage types, including NFS, S3, and blob storage. This range of options lets organizations stay compliant while meeting their specific operational requirements. Through connections with tools like Ansible and ArgoCD, Trilio creates uniform backup rules and simplified recovery steps across different environments.

Security features include encrypted backups, permission-based access controls, and detailed activity records that satisfy DORA’s documentation standards. Financial institutions can monitor all backup and recovery actions, providing required proof during compliance checks. Organizations looking to improve their operational stability while meeting regulatory requirements can schedule a demo to see these capabilities firsthand.

Preparing for Future Compliance

Financial organizations face a clear deadline to meet DORA compliance requirements by January 2025. The task requires meticulous planning and reliable technology solutions. Companies must review their existing systems to identify gaps, make necessary improvements, and sustain strong data security protocols. Successful DORA compliance depends on effective risk management, ongoing system monitoring, and robust backup solutions working together to ensure operational stability. Organizations starting their preparations early will find themselves better positioned to address potential weaknesses and refine their procedures.

Want to learn how Trilio’s backup and recovery solutions can help you meet DORA compliance requirements while safeguarding your financial operations? Schedule a demo today.

FAQs

How does DORA compliance affect cross-border financial operations within the EU?

Financial institutions working between EU countries must meet specific DORA compliance standards throughout their operations. Each member state may have slight variations in how they interpret these rules, so banks and other financial firms need to align their ICT risk management systems accordingly. Companies operating in multiple EU nations should establish reliable reporting systems and maintain strong connections with regulatory bodies in each country to ensure that they meet all requirements.

What are the penalties for failing to maintain DORA compliance?

Missing DORA compliance targets can result in severe financial consequences—institutions might face fines up to €10 million or 2% of their yearly global revenue, depending on which amount is larger. Regulators have the authority to limit business activities, pause specific operations, or demand immediate fixes for compliance issues. Multiple violations could trigger management investigations and force companies to undergo external compliance reviews.

How often should financial organizations update their DORA compliance documentation?

Financial organizations need to check their DORA compliance papers every three months at a minimum. Changes should happen right away when systems are modified, security problems occur, or new risks emerge. Companies must track all document versions and keep clear records of any changes made to show that they’re staying on top of compliance needs.

Can smaller financial institutions obtain extensions for DORA compliance implementation?

Small financial institutions can’t get deadline extensions for DORA compliance, but they might qualify for adjusted requirements based on their business size and risk levels. These modifications focus on making compliance practical for smaller operations without changing the final deadlines. Such companies still need to show that they’re actively working toward meeting all requirements through detailed planning and regular progress updates.

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Picture of David Safaii

David Safaii

With more than 20 years of business management and executive leadership expertise, David is responsible for strategic partnerships, business development and corporate development of the company.

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