Fast-Track · Weeks, Not Months

DORA Compliance

EU Digital Operational Resilience Act Compliance for Financial Entities & ICT Providers

Praxis-Q delivers DORA compliance for EU financial entities and their ICT service providers. DORA has been fully applicable since January 2025. We align DORA ICT risk management requirements with ISO 27001:2022 and NIS2 - building a single integrated resilience framework that satisfies all three simultaneously.

At a Glance

Regulation

EU 2022/2554

In Force

Jan 2025

Fines

€5M/1% daily

ISO Aligned

27001:2022

DORA (the Digital Operational Resilience Act) took effect on 17 January 2025 and applies to virtually every EU financial entity - banks, insurers, investment firms, payment institutions and crypto-asset service providers - plus, critically, their critical ICT third-party providers, which is what makes DORA reach well beyond the financial sector itself into the cloud and software vendors that serve it. It mandates a formal ICT risk-management framework with defined governance structures and board accountability, contractually embedded third-party ICT risk management with specific due diligence and exit-strategy provisions, major-incident reporting against defined classification criteria, and regular digital operational resilience testing including, for the largest entities, advanced threat-led penetration testing. Praxis-Q runs the gap assessment, vendor-contract review and resilience-testing programme DORA requires, for both financial entities directly in scope and the ICT vendors serving them who now face DORA-driven contractual requirements even without being financial entities themselves.

DORA

DORA Compliance

EU Digital Operational Resilience Act Compliance for Financial Entities & ICT Providers

The Problem

DORA makes operational resilience a regulatory requirement for financial entities and their ICT providers. Gaps in testing or third-party oversight now draw supervisory action.

What We Do

  • DORA Scoping
  • ICT Risk Framework
  • Incident Management
  • Resilience Testing
  • Third-Party Risk

What You Get

  • DORA Chapter II ICT risk management framework
  • DORA Chapter III incident management and reporting
  • DORA Chapter IV digital operational resilience testing (TLPT)
  • DORA Chapter V ICT third-party risk management
  • ISO 27001 to DORA control mapping
  • Threat-Led Penetration Testing (TLPT) preparation
  • DORA and NIS2 integrated compliance programme
  • Applicable to banks, insurers, investment firms, and ICT providers

Why weeks, not months

AI-assisted evidence review, one client portal

Every DORA engagement runs on the Praxis-Q compliance platform. You upload evidence per control, AI scores it against the requirement, and your auditor reviews in the same workflow — from scoping through to the issued, publicly verifiable certificate.

AI evidence scoring

Every upload is scored against the control before an auditor sees it — gaps surface in minutes, not at the review meeting.

One client portal

Scoping, evidence, auditor queries and status live in one place. No email chains, no spreadsheet trackers.

Auditor sign-off

Praxis-Q auditors review inside the same workflow, so review rounds shrink and the certificate issues sooner.

Who DORA Actually Covers

DORA applies directly to a broad list of EU financial entities - credit institutions, payment institutions, investment firms, insurance and reinsurance undertakings, crypto-asset service providers, and several other categories - but its reach extends further through the third-party risk provisions: any ICT provider designated as 'critical' to the financial sector (a status the European Supervisory Authorities can assign to major cloud and technology providers) falls under direct oversight, and even non-critical ICT vendors face DORA-driven contractual obligations flowing down from their financial-entity customers' own compliance requirements. Praxis-Q works with both direct financial-entity clients and their technology vendors, since the compliance obligations look different depending on which side of that relationship an organisation sits on.

The ICT Risk-Management Framework

DORA requires a documented ICT risk-management framework with clear governance - the management body bears direct responsibility and accountability for ICT risk, not just delegated oversight - covering identification of ICT-supported business functions and assets, protection and prevention measures, detection mechanisms, response and recovery procedures, and a communication plan for both internal stakeholders and, where relevant, the public and regulators. Praxis-Q builds this framework to map directly onto an existing ISO 27001 ISMS where one exists, since the two share substantial structural overlap around risk assessment and governance.

Third-Party ICT Risk Management

DORA imposes specific, prescriptive requirements on contracts with ICT third-party providers: pre-contractual due diligence assessing concentration risk, mandatory contractual clauses covering service levels, data location, audit rights, and cooperation during incidents, and a documented exit strategy for every critical or important function outsourced to an ICT provider. Financial entities must also maintain a register of information on all ICT third-party arrangements, reportable to their competent authority. Praxis-Q reviews existing vendor contracts against these specific requirements and drafts the amendments or new clauses needed, which is often the most operationally disruptive part of a DORA programme since it requires actually renegotiating vendor agreements, not just internal policy changes.

Incident Reporting and Digital Operational Resilience Testing

DORA requires major ICT-related incidents to be reported to the relevant competent authority against defined classification criteria and timelines, broadly aligned in spirit with NIS2's reporting structure though DORA's specific criteria and thresholds are its own. Separately, DORA mandates regular digital operational resilience testing - a proportionate programme scaled to the entity's size and risk profile, with the largest and most systemically important entities required to undergo advanced threat-led penetration testing (TLPT) at least every three years, following a specific methodology and using independent, qualified testers. Praxis-Q scopes standard resilience testing for most clients and coordinates TLPT-qualified partners for entities where that advanced testing tier applies.

Engagement Model

Gap assessment against DORA's requirements, including determining which specific provisions apply based on entity type and size, typically runs two to three weeks given the framework's breadth. Vendor contract review and remediation is scoped separately since it depends on the number and complexity of existing ICT vendor relationships. Praxis-Q builds the resilience testing programme as an ongoing annual cycle rather than a one-time exercise, since DORA expects continuous testing proportionate to risk, not a single point-in-time assessment.

Frequently Asked Questions

Who does DORA apply to?
DORA applies to EU financial entities including banks, insurance companies, investment firms, payment institutions, and crypto-asset service providers. It also applies to critical ICT service providers to the financial sector designated by EU supervisory authorities.
What is the relationship between DORA, ISO 27001, and NIS2?
DORA builds on but does not replace ISO 27001 and NIS2. ISO 27001 provides the ISMS governance foundation mapping to DORA Chapters II and III. DORA adds financial sector-specific requirements: ICT risk classification, resilience testing (TLPT), and prescriptive third-party oversight.
What are the DORA penalties for ICT providers?
Critical ICT third-party service providers face fines up to EUR 5 million or 1% of average daily worldwide turnover, applied daily until compliance is achieved.
Does DORA apply to us if we're a technology vendor, not a financial company?
It can, in two ways: directly if a European Supervisory Authority designates you as a 'critical' ICT third-party provider to the financial sector, or indirectly through contractual requirements your financial-entity customers now need to embed in vendor contracts under DORA's third-party risk provisions. Praxis-Q assesses which applies and what specific obligations follow.
What is threat-led penetration testing (TLPT) and do we need it?
TLPT is DORA's advanced resilience-testing requirement for the largest and most systemically important financial entities, conducted at least every three years using a specific methodology and independent, qualified testers who simulate realistic threat actor tactics. Most entities fall under DORA's standard, more proportionate testing requirements rather than the TLPT tier - Praxis-Q determines which applies based on your entity's size and systemic importance.
How does DORA relate to NIS2?
Both require risk-management frameworks and incident reporting with broadly similar structures, but DORA is financial-sector-specific and more prescriptive about ICT third-party contract terms, while NIS2 covers a much broader range of sectors. A financial entity in scope of both needs to satisfy DORA's specific requirements as the more detailed, sector-specific standard; Praxis-Q builds one control set that satisfies both where an entity falls under both regimes.
What has to be in our ICT vendor contracts now?
DORA mandates specific contractual provisions for ICT third-party arrangements supporting critical or important functions: service level clauses, data location and audit rights, cooperation obligations during incidents, and a documented exit strategy. Praxis-Q reviews existing contracts against these requirements and drafts the specific amendments needed, which is often the most time-consuming part of a DORA programme.
Does our ISO 27001 certification cover DORA?
It covers meaningful ground - the ICT risk-management framework requirements overlap substantially with ISO 27001 Annex A - but DORA has specific requirements ISO 27001 doesn't address on its own, particularly around the third-party contract provisions and the register of ICT third-party arrangements. Praxis-Q builds DORA compliance on top of an existing ISMS rather than duplicating the risk assessment work.
What are the reporting timelines for a major ICT incident under DORA?
DORA sets specific classification criteria and reporting timelines to the relevant competent authority, broadly similar in structure to NIS2's staged reporting clock though DORA's specific thresholds are its own. Praxis-Q builds the incident response plan around DORA's specific criteria rather than assuming NIS2's timeline applies identically.

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