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In this guide
- Key takeaways
- What are the five pillars of DORA?
- How does the ICT risk management pillar work?
- What does ICT - related incident management & reporting require?
- What is required for digital operational resilience testing?
- How does ICT third - party risk management protect the supply chain?
- What are the information - sharing arrangements about?
- Why do these pillars matter for compliance?
- How can you start implementing DORA’s pillars?
Key takeaways
- DORA’s five pillars are ICT risk management, incident management & reporting, resilience testing, third - party risk management, and information - sharing.
- Each pillar is detailed in specific article ranges of Regulation EU 2022/2554.
- Compliance requires board - approved frameworks, timely incident notifications, regular testing, strict supplier governance, and voluntary threat intel sharing.
What are the five pillars of DORA?
DORA organises its obligations into five distinct pillars, each covered in a dedicated chapter of the regulation. The pillars are ICT risk management, ICT - related incident management & reporting, digital operational resilience testing, ICT third - party risk management, and information - sharing arrangements.
How does the ICT risk management pillar work?
The ICT risk management pillar (Art. 5 - 16) requires organisations to adopt a board - approved risk - management framework that addresses identification, protection, detection, response, recovery, learning and communication. Practically, this means documenting risk assessments, defining security controls, and regularly reviewing the effectiveness of those controls.
What does ICT - related incident management & reporting require?
Under Art. 17 - 23, firms must detect, classify, handle and notify major ICT incidents to the competent authority. Notification deadlines are strict: an initial notice within 4 hours, an intermediate update within 72 hours, and a final report within one month.
What is required for digital operational resilience testing?
The resilience testing pillar (Art. 24 - 27) mandates a risk - based testing programme. All entities perform annual vulnerability assessments and scenario - based tests. Significant entities must also undergo a Threat - Led Penetration Test at least every three years.
How does ICT third - party risk management protect the supply chain?
Articles 28 - 44 govern outsourcing. Organisations must conduct due - diligence, embed contractual clauses, maintain a Register of Information on all ICT providers, assess concentration risk, and comply with an EU - level oversight regime for critical providers.
What are the information - sharing arrangements about?
Article 45 encourages voluntary exchange of cyber - threat intelligence and indicators of compromise among financial entities, often through Information Sharing and Analysis Centers (ISACs). While not mandatory, participation helps improve sector - wide resilience.
Why do these pillars matter for compliance?
Each pillar translates regulatory intent into concrete, auditable actions. Failure to meet any pillar can lead to supervisory penalties, reputational damage, and increased operational risk. By aligning internal processes with the five pillars, firms demonstrate a holistic approach to digital resilience that satisfies DORA’s requirements.
How can you start implementing DORA’s pillars?
- Create a governance charter that assigns board responsibility for ICT risk management.
- Set up incident response playbooks with defined escalation timelines matching the 4 - hour, 72 - hour, and 30 - day windows.
- Schedule regular testing - annual vulnerability scans and, for large entities, a Threat - Led Penetration Test every three years.
- Map all ICT suppliers into a register, perform due - diligence, and embed contractual security clauses.
- Join an industry ISAC or establish a peer - to - peer threat - intel sharing channel.
Following these steps aligns your organisation with DORA’s five pillars and builds a defensible, resilient digital operating environment.
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