DORA Compliance 2025: What Financial Firms Must Know

Operational resilience has become essential, as cybercrime is now expected to cost the global economy over $10.5 trillion annually by the end of 2025. DORA responds to such urgencies by setting clear standards for financial institutions and their service providers to prepare for disruptions. You need systems, controls, testing, and vendor oversight to protect your operations. Therefore, it is critical to implement effective governance, structured testing, third-party accountability, and incident procedures. 

In this blog, we will explore actionable guidance on DORA compliance, including the benefits of meeting regulatory expectations.

Key Takeaways

• DORA has been in force since January 17, 2025, and financial institutions are expected to comply now.
• The regulation applies to banks, insurers, asset managers, fintechs, crypto firms, and ICT vendors worldwide that serve EU financial institutions.
• Compliance requires a structured ICT risk management framework, rapid incident reporting, regular resilience testing, third-party oversight, and intelligence sharing.
• Organizations must set governance structures, run gap analyses, classify incidents, update vendor contracts, and execute resilience testing programs.
• Firms that fail to comply face fines, regulatory action, and restricted market access within the EU.
• Those that comply benefit from improved operational resilience, stronger vendor negotiations, regulator trust, and a unified EU framework that replaces fragmented national rules.
• Compliance is not a one-off project — it requires continuous monitoring, testing, and evidence packs to stay audit-ready.

What is DORA Compliance?

DORA compliance means adhering to the Digital Operational Resilience Act (EU Regulation 2022/2554), which has been in force since January 17, 2025. It was introduced to ensure that financial institutions and their third-party information and communication technology (ICT)  service providers can recover from cybersecurity breaches. 

Five core areas for the DORA compliance include ICT risk management, incident reporting, information sharing, digital operational resilience testing, and more for critical third-party providers.  For U.S.-based organizations, DORA compliance becomes relevant if they serve or partner with EU financial entities. It makes it essential to evaluate vendor contracts and reporting processes against regulatory standards. 

To meet regulatory expectations, you must understand DORA’s five primary requirements, each forming the foundation of operational resilience.

5 Primary Requirements of DORA

As of mid-2025, nearly 96% of financial institutions in Europe report that their data resilience is not yet where it needs to be. DORA outlines five requirements that relevant ICT providers must meet under European regulatory bodies, including the EBA and ESMA, among others.

1. ICT Risk Management Framework

You need a structured approach to identify, assess, and manage technology risks from defining governing roles to placing response plans and continuity procedures. 

2. Incident Reporting and Reporting

DORA provides a systematic process for reporting critical ICT-related incidents, including those based on severity and the issuance of details such as response actions. Organizations must report without delay to ensure timely response and enable coordinated efforts to reduce impacts across financial sectors. 

3. Digital Operational Resilience Testing

Conduct regular testing from vulnerability assessment to advanced threat-led penetration testing (TLPT) to validate resilience measures and strengthen cyber risk management. Insights from such tests should inform continuous improvements to resilience strategies and help demonstrate compliance with the standards of EU supervisory bodies. 

4. Third-Party Risk Oversight

Maintain strict oversight of ICT service providers with necessary contractual agreements and documentations for vendor relationships in a centralized unit to meet regulatory requirements. Additionally, critical third-party providers may also be subject to additional oversight to protect financial operations. 

5.Information and Intelligence Sharing

Participate in trusted networks that exchange threat intelligence, supported by insights from cybersecurity audit practices, to enhance resilience by regulatory bodies. Additionally, regulatory cooperation is emphasized to support a coordinated response to systemic risks. 

Determining who falls under DORA compliance is crucial, as its scope encompasses financial institutions, ICT providers, and supporting entities.

Who Needs to Be DORA Compliant?

A recent report suggests that the average implementation level of mid-sized financial firms is 45%, indicating that organizations are still adopting the DORA compliance. The regulation applies to a wide range of entities in the EU, as well as to U.S. firms that support EU-based financial clients. 

Here are some of the organizations that need to be DORA compliant in 2025:

• EU Financial Institutions: This includes banks, credit and investment firms, insurance companies, asset managers, and trading venues, all of which are regulated by EU supervisory authorities such as ESMA and EIOPA. 
• Critical ICT Third-Party Service Providers (CTPPs): EU regulators can designate non‑EU ICT providers that deliver vital services to financial institutions. These providers must directly meet DORA requirements and may be subject to oversight by the European Supervisory Authorities. 
• Non-EU ICT Vendors: A company providing infrastructure, software, and cloud services to EU financial institutions falls under the scope of DORA, even if its primary operations are based in the USA. 
• Fintech and Crypto Firms: U.S.-based fintechs, hedge funds, brokers, and crypto platforms, or any other financial services provider that serves EU customers, must adhere to DORA. Failure to comply results in reduced market access and fines, highlighting the importance of continuous risk monitoring.  
• Organizations with Enterprise-Level ICT Dependency: Any organization that plays a role in the ICT value chain for the covered financial institutions must ensure its resilience and meet DORA standards. 

Follow the steps below to build governance, evidence, and resilience, transitioning from policy to demonstrable compliance across systems and vendors.

Step-by-Step DORA Compliance

Achieving DORA compliance requires adherence to policy statements and providing evidence to demonstrate recovery from ICT disruptions. Regulators expect financial institutions and their service providers to demonstrate structured governance to meet oversight standards. 

Here’s a step-by-step guide to DORA compliance:

Step 1: Set Governance and Scope

Establish a board-approved policy, appoint an executive, and publish a RACI across ICT risks, incidents, and third-party oversights. Additionally, define critical functions, risk appetite, escalation paths, and reporting cadence to senior management. 

Step 2: Perform a Documented Gap Analysis and Control Mapping

Inventory systems, services, data flows, and dependencies, then map current controls to DORA requirements for each function. Score gaps, set remediation, and align reuse with ISO 27001 or NIST CSF where sensible, and maintain a register of information for ICT contracts. 

Step 3: Develop an Incident Classification 

Standardize severity levels and establish time-bound steps for initial, update, and final submissions with competent authorities. Define roles, evidence collection, and communication, and link SIEM/SOAR alerts to workflows. Rehearse with tabletop drills to validate readiness. 

Step 4: Improve Third-Party Contract Terms

Complete a vendor inventory with criticality scoring, keep the required contract register fields and refresh clauses, log access, data location, and BCP/DR commitments. Moreover. Track concentration risks, test supplier controls, and record filings, and establish a monitoring cadence with escalation procedures.

Step 5: Execute a Resilience Testing Program

Publish an annual test plan covering vulnerability management, scenario exercises, and recovery tests. Schedule TLPT depending on risk and supervisor expectations. Scope critical services, track remediation to closure, retest for effectiveness, and tie results to cybersecurity risk management metrics and board reporting. 

Also read: #1 ISO 27001 Compliance Software: Why VComply Is Considered the Best in 2025

Let’s explore how meeting DORA compliance strengthens resilience, reduces financial risk, improves vendor oversight, and builds long-term regulatory trust.

Benefits of Meeting DORA Compliance

In 2025, the median cost of a high-impact outage in the financial services sector reached $2.2 million per hour, highlighting resilience as a board-level priority. The DORA compliance turns resilience into an auditable standard that protects both financial stability and customer satisfaction. 

• Predictable compliance across the EU: DORA establishes a rulebook that replaces fragmented national requirements, providing financial entities and service providers with a unified framework applicable across multiple jurisdictions. 
• Regulator-ready evidence pack: Compliance requires maintaining a set of artifacts, including risk registers, vendor inventories, incident logs, and test results. It streamlines operations for supervisory reviews similar to documentation practices under US state-by-state data privacy laws. 
• Improved vendor negotiations: By embedding DORA’s mandatory contract clauses, financial institutions can expect greater transparency, enhanced audit rights, and increased cooperation from ICT providers. 
• Long-term resilience strategy: The testing cycles, reporting protocols, and board accountability under the DORA compliance ensure resilience, rather than as a one-off project. 

Also read: What is GRC in Cyber Security?

Let’s see how VComply’s automated solutions simplify compliance tasks, reduce manual errors, and give you real-time oversight and reporting.

Streamline Your DORA Compliance With VComply’s Automated GRC Solutions

VComply’s cloud-based GRC platform helps you simplify governance, risks, and compliance by automating manual tasks, centralizing controls, and providing audit-ready transperencies. 

• Policy and Control Management: Create, assign, and monitor controls while ensuring accountability through automated workflows.
• Automated Risk Assessments: Conduct structured risk assessments with scoring and workflows to identify and track vulnerabilities.
• Incident and Task Management: Log incidents, assign remediation tasks, and track progress in real time for complete visibility.
• Dashboards and Compliance Reporting: Access data through VComply’s dashboard and generate reports for faster supervisory reviews. 

Take charge of your DORA compliance today. Book a demo with VComply to streamline reporting, oversight, and strengthen operational resilience across financial services.

Final Thoughts 

Achieving DORA compliance requires appropriate regulatory alignment and maintaining operational continuity in the face of severe disruptions. By focusing on governance, risk monitoring, incident reporting, and testing, regulators can expect alignment between evidence and practices. 

Start simplifying compliance oversight and reducing reporting errors with VComply’s 21-day free trial, and streamline your DORA compliance checklist management with confidence. 

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