Make DORA compliance practical
With full DORA compliance required since January 2025, in‑scope organizations should now have a clear view of their status.
Our approach to DORA is simple: testing that makes sense, fits your organization, and meets regulatory expectations without unnecessary complexity.
What is DORA?
The Digital Operational Resilience Act (DORA) strengthens the resilience of the European financial sector.
DORA sets a uniform standard for ICT risk management, incident reporting, operational resilience testing, and third‑party risk. This ensures that organizations address cyber threats and disruptions in a consistent way.
It applies to a broad range of financial entities, including banks, insurance companies, investment firms, payment and e‑money institutions, pension institutions, and crypto service providers.
DORA compliance requirements
DORA’s comprehensive cybersecurity obligations for EU financial entities include:
- Digital operational resilience testing
- Risk management
- Incident reporting
- Third‑party risk management
Key requirements for ICT third‑party service providers (TPSPs) include:
- Implementing an appropriate security standard
- Adding specific clauses to contracts with financial entities to ensure digital resilience
Third parties deemed critical must meet additional requirements set by the Lead Overseers.
Supervisory actions range from reprimands and periodic payments to operational restrictions. Public enforcement can also create reputational risk.
Challenges we see for DORA compliance
Adapting to stricter vendor management is a key challenge under DORA. As our Principal Consultant Antti Laatikainen notes, it is slow work that starts with viewing longstanding supply chains in a new light.
Organizations need to show evidence of their controls, which means many cooperation agreements must be rewritten. It is time‑consuming, and many teams are unsure where to begin.
According to Antti, “re‑evaluating existing suppliers and service structures has proven considerably more difficult than implementing new technical controls.”
Overcoming these hurdles is an opportunity to build stronger operations that earn trust with customers and investors.
Our testing services
DORA expects financial entities to adopt a documented testing approach built on risk, traceability, and operational understanding. That starts with the right questions:
- Which systems are truly critical to your business?
- What should be tested, and how often, given your risk profile?
- Which testing methods fit your environment instead of defaulting to a template?
We design testing programs that answer these questions clearly, then deliver the technical work with the depth you expect from a security‑first team.
For DORA’s annual risk assessments, our team helps you identify ICT risks relevant to your organization. We then work with you to establish and maintain a testing program that tracks to the identified risks.
Many organizations split this work among multiple vendors, one for advisory and another for offensive security. The result can be misaligned scopes, gaps in documentation, extra meetings, and findings that don’t map back to the original risk model.
We remove that problem by running the full process ourselves. One team, one methodology, and one continuous line of accountability.
Our DORA testing package includes:
Risk modeling and critical asset discovery
Testing program design and validation
Offensive security testing
Remediation review and retesting
Mainframes that support critical or important functions must be covered by your annual testing program. Our rare expertise in mainframe architecture, operating systems, and languages ensures that DORA’s testing requirements are fully met.
Threat-led penetration testing (TLPT) is required for significant financial entities. Drawing on our experience delivering TIBER‑EU testing, we can also help you address DORA’s expectations for advanced threat‑led penetration testing.
Risk management
Under DORA, financial institutions must establish a documented governance and control framework with clear management involvement.
A short call with us can advise you in choosing the right starting point for your environment. Existing cybersecurity frameworks such as ISO 27001 or the NIST CSF provide a strong foundation for a DORA‑ready approach.
Once a framework is set, we can run a current state assessment to see how far you are in implementing it. We review your security policies, practices, and procedures to identify gaps between where you are and where you need to be.
To support implementation of the chosen framework, we provide capacity and practical guidance through our advisory services.
Incident management and third‑party risk management
DORA compliance requires a process for detecting, managing, and reporting incidents. Entities also need a strategy for ICT third‑party risk that keeps providers compliant with an appropriate security standard.
We support you in addressing both requirements. This includes developing documentation for policies, standards, and procedures, advising on required controls, and supporting thorough implementation.
We can work with your legal or IT teams to assess implementation using a current state assessment that includes documentation review, interviews, and control evaluation.
Our consultants can also complement your workforce or provide ongoing guidance as a trusted advisor.
Services for third-party service providers
If you are a third-party service provider, we support you in meeting your direct DORA obligations and satisfying contract‑based expectations from financial entities or a Lead Overseer.
- For critical providers, we advise you in selecting an appropriate security standard and map it to DORA so you can demonstrate readiness with clear evidence.
- Through documentation reviews, interviews, and control evaluation, we assess how far you are in implementing the chosen standard.
- We add capacity and direction to drive change, close gaps, and move you toward compliance or certification.
Book a session with us to plan your next steps and build operational resilience your customers can trust.
