Ensure Ongoing DORA Compliance Across Your Third-Party Risk Management Program

The Digital Operational Resilience Act (DORA) is a regulatory framework established by the European Union to ensure the operational resilience of financial entities and their service providers in the face of growing ICT-related risks. While its implementation was first introduced to the market back in 2020, the time is finally here for Information and Communication Technology (ICT) partners required to comply with these new regulations.

DORA requirements include solid and verifiable ICT risk management, incident reporting, resilience testing, and oversight of critical third-party providers, which is expected to impact how many teams conduct digital risk management.

By setting a standard for financial institutions and ICT providers, DORA is a catalyst for organizations to take third-party risk management more seriously. While compliance is a regulatory requirement, DORA’s emphasis on operational resilience helps organizations develop more mature and robust risk management programs. This renewed TPRM focus fosters greater business continuity, enhances stakeholder confidence, and positions companies as leaders in resilience and reliability to businesses, consumers, and partners.

We compiled a quick outline to ensure your program readiness for DORA’s requirements to help facilitate the work your team needs to do to comply with new regulations.

For further help ensuring your program is compliant with new DORA regulations, contact the ProcessUnity team today. We deliver a best practice approach and automated workflow to accelerate your path to compliance.

Key Areas of DORA

DORA introduces specific requirements that directly impact TPRM programs, including:

1. ICT Risk Management: Ensuring that third-party providers in the ICT space comply with DORA-specific risk management practices.
2. Incident Reporting: Identifying, reporting, and responding to ICT-related incidents in a responsible time frame.
3. Resilience Testing: Conducting regular assessments of the resilience of ICT providers and their controls.
4. Oversight of Critical Third-Party Providers: Maintaining control and monitoring of vendors whose services are essential to operations.

Unsure of Who Qualifies as an ICT Organization?

ICT (Information and Communication Technology) organizations are entities that provide technology-based services or solutions. These include cloud service providers, data centers, cybersecurity firms, and software vendors. Examples of ICT providers might include Amazon Web Services (AWS), Microsoft Azure, or third-party developers of banking software. DORA’s focus on ICT organizations underscores the need for robust third-party oversight in this space.

Financial entities must trust their vendors to uphold operational resilience, mitigate risks, and comply with regulatory standards. Organizations may face operational disruptions, regulatory penalties, and reputational damage under DORA without strong vendor risk practices.

So, what can you do to ensure DORA readiness for your Third-Party Risk Management program?

Identify Gaps in Your Current Program

Before adapting your TPRM program to DORA’s standards, it is critical to evaluate your program’s current state to uncover vulnerabilities. Conducting a gap analysis involves reviewing your existing processes, tools, and policies against DORA requirements. This could include examining your ICT risk management practices, incident reporting processes, and vendor oversight and visibility to determine where there are current gaps that designate you as non-compliant.

Once gaps are identified, it is essential to prioritize areas that pose the highest risk to your organization. This could mean addressing inadequate monitoring of critical vendors or developing clearer incident reporting workflows.

It’s crucial for your business to have a vendor tiering system in place to help group together business-critical vendors that have access to financial and consumer data that falls under the DORA guidelines. By focusing on high-impact areas first, your organization can efficiently make progress toward DORA compliance while laying a strong foundation for addressing additional gaps over time.

For a deeper dive into how ProcessUnity’s DORA Compliance Framework can work for your business, download our complete guide here.

Enhancing Your ICT Risk Management Framework

A robust ICT risk management framework is central to DORA compliance. For organizations without a current framework, the first step is to define clear policies and procedures for identifying, assessing, and mitigating risks associated with ICT systems and third-party providers. This includes establishing oversight and assessment structure and assigning responsibilities to relevant stakeholders.

For those with existing frameworks, integrating DORA requirements is the focus. This might involve updating risk assessment criteria to reflect DORA’s focus on operational resilience and enhancing continuous monitoring practices to ensure ongoing compliance. Leveraging technology solutions, such as a TPRM platform, can simplify this process by providing tools for real-time risk monitoring, vulnerability detection, automated assessments, and streamlined reporting.

Strengthening Incident Reporting and Response

Incident reporting is a critical component of DORA, emphasizing the need for organizations to respond quickly and transparently to ICT-related vulnerabilities, while maintaining a way to represent their response and threat management processes.

To achieve this, organizations must establish clear protocols for identifying and escalating incidents. This includes defining what constitutes a reportable incident and having an internal communication plan in place, all while ensuring compliance with regulatory timelines.

Developing a comprehensive incident response plan should detail how incidents are managed from detection to resolution, including communication strategies with stakeholders, customers, and authorities. Regular training and simulation exercises can help teams stay prepared and ensure that response efforts align with the DORA requirements.

Establishing a Resilient Program

Resilience testing is essential under the new DORA requirements to ensure that ICT-related systems and processes can withstand operational disruptions. This involves conducting various types of tests internally and with third parties, such as scenario-based simulations, to assess responses to real-world threats and uncover vulnerabilities in your systems.

Regularly scheduled resilience tests enable organizations to identify weaknesses before they lead to disruptions. Moreover, it’s crucial to update resilience measures based on test findings and evolving threat landscapes.

Management Plans for Critical Third-Party Providers

Critical third-party providers play a significant role in an organization’s operational resilience, and now DORA places heightened emphasis on their oversight. The first step is to identify these vendors by evaluating your vendor portfolio based on importance to your operations, and the level of access they have to sensitive data.

Once business-critical providers are identified, organizations must establish robust monitoring and oversight plans. This includes conducting regular audits, continuously monitoring vendor performance, and ensuring compliance with DORA’s requirements. Collaboration is key; it’s important to work with your vendors to provide clear expectations, share what’s working with other third parties, and address any compliance gaps together.

In Conclusion: What to Remember Moving Forward

To stay ahead of evolving DORA requirements, organizations must prioritize:

• Staying Up to Date with Adjustments: Stay aware and on top of any changes to DORA, and update your TPRM program accordingly.
• Training and Awareness: Foster a culture of resilience by educating internal teams on DORA’s impact and best practices.
• Stakeholder Engagement: Collaborate with legal, compliance, IT, and business teams to build a unified approach to vendor risk management.

Don’t Do It Alone: Leverage Technology Solutions as Partners

Regulatory compliance can be daunting without the right tools. Technology such as ProcessUnity’s Third-Party Risk Management platform can streamline your path to DORA compliance by:

• Providing DORA-compliant assessment workflows.
• Delivering a pre-made DORA data model for quick and accurate implementation.
• Enabling continuous monitoring and streamlined risk remediation.

With ProcessUnity, your team can efficiently navigate the complexities of DORA compliance, ensuring your TPRM program is resilient, robust, and ready for the future.

To see how ProcessUnity can integrate easily into your program to improve DORA compliance in 2025, request a demo today.