The Digital Operational Resilience Act (DORA) is a European Union regulation designed to strengthen the digital operational resilience of financial entities and critical service providers. Despite its origins as a steering mechanism to guide firms toward robust practices, many organizations risk turning DORA compliance into an overcomplicated, bureaucratic exercise. The real intent of DORA is to unify, simplify, and modernize practices, acting as a catalyst for positive transformation rather than a “beating stick.”
In this article I explore the core purpose of DORA, the common pitfalls of overengineering a DORA implementation, and practical strategies for using the regulation as a meaningful “reset” on outdated processes.
?DORA in a Nutshell : The Purpose and Scope
?DORA is part of the EU’s broader digital finance strategy and applies primarily to financial institutions and third-party ICT (Information and Communication Technology) service providers. Its overarching goal is to ensure organizations can effectively prevent, detect, contain, and recover from ICT-related incidents. Essentially, it strengthens operational resilience by aligning and standardizing cybersecurity and digital risk requirements across EU financial services.
The 5 key pillars of DORA
- ICT Risk Management – Building robust policies, procedures, and controls to manage and mitigate ICT risks.
- Incident Reporting – Establishing clear processes to identify, categorize, and report major ICT-related incidents.
- Digital Operational Resilience Testing – Periodically testing the effectiveness and efficiency of ICT systems under stress conditions or simulated attacks.
- ICT Third-Party Risk Management – Ensuring consistent oversight of third-party providers, especially those offering critical ICT services.
- Information Sharing – Promoting the sharing of information on cyber threats and vulnerabilities among financial entities and regulators.
The Trap of Overcomplicating Implementation
While DORA sets clear expectations, the biggest pitfall is viewing compliance as a Tick-box ? exercise that adds layers of ICT, risk, governance and compliance procedures without any real benefit. When organizations interpret DORA as yet another regulatory burden, they often:
- Reinforce Legacy Systems and Processes Instead of leveraging DORA to phase out antiquated frameworks, many companies simply add new layers on top of existing, legacy and outdated systems and structures. For example, a decade-old standard, process or policy might be “updated” with modern buzzwords for compliance, but its flawed foundation remains intact, leading to confusion and inefficiency.
- Create Document Overload from initial feedback on some prior DORA posts and articles, companies often respond to DORA by producing lengthy, unwieldy documentation, outlining every possible scenario without pragmatic considerations for day-to-day operations. These reams of text seldom get read or fully understood by the teams who need to implement them, usually resulting in cases of analysis-paralysis.
- Overburden IT and GRC Teams Overly complex and drawn out procedures can translate into unrealistic workloads. Instead of improving resilience, teams are stuck managing administrative tasks and responding to endless queries about compliance, detracting from their core mission of safeguarding operations.
- Lose Sight of the True Objective The spirit of DORA is not just to meet regulatory demands but to improve operational resilience.
By treating DORA as a punitive requirement rather than a guiding framework, organizations miss the chance to genuinely enhance their systems, processes, and culture.
Using DORA as a “Reset” Instead of a “GRC Beating Stick”
?To realize the true benefits of DORA, organizations should treat it as an opportunity to streamline and modernize. Instead of ramming additional DORA requirements into outdated structures, focus on resetting operational resilience practices:
- Conduct a Meaningful Gap Analysis Compare current resilience measures against DORA’s baseline. Where are the real gaps? Use this assessment to prioritize areas needing immediate attention—whether it’s outdated architecture, unclear incident response plans, or insufficient vendor oversight.
- Eliminate Redundant Processes If a process or control adds no value and only exists because “it always has,” consider decommissioning it. DORA should help you strip away redundant bureaucracy.
- Adopt a Risk-Based Approach DORA’s flexibility allows you to scale the requirements to your organization’s risk appetite. Focus on quality over quantity: implement measures that address real threats to the organization’s resilience rather than superficially covering every corner case within the scope of DORA.
- Leverage Automation and Modern Tools If you find yourself layering manual processes on top of each other, it’s time to revisit your technology stack. Automation can reduce human error, streamline reporting, and cut down on administrative burdens.
Where to Focus and What to Have as a Minimum
?Minimum Focus Areas for Effective DORA Implementation
- Clear Accountability Structures: Define who owns ICT risk management within region, office or location, similar for incident reporting, testing, and vendor oversight. A clear chain of responsibility prevents confusion and ensures timely decision-making. This is where multi-nationals and nationals need to relay and trust their people they employed within regions. Keep it simple where possible.
- Robust Incident Management Plan: Have a plan that outlines roles, responsibilities, and escalation paths for various incident severities. Make sure it’s tested and well-understood by all relevant teams and communicated to the business and easily accessible to all who might need to reference it some day.
- Resilience Testing and Reporting: Establish a realistic testing schedule—from tabletop exercises to full simulations. The goal is consistent improvement, not a one-off check that is done annually.
- Third-Party Oversight: Identify your critical suppliers and implement proportionate controls. Maintain transparency with vendors about your resilience objectives and expectations.
Knowing Where You Are and Where You’re Headed
- Set Clear Objectives: Tie your DORA compliance efforts to tangible business outcomes. For instance, you might aim to reduce average incident response times by 25% within a year. Alternatively you could focus on increasing the scope of your Business continuity planning and testing. Be realistic and focus where it matters to you. If you are trying to focus on DORA in its entirety, you will most likely alienate those you rely on for support when needed.
- Monitor and Measure: Define and document key metrics (e.g., Mean Time to Detect (MTTD), Mean Time to Recover (MTTR), number of critical vulnerabilities). Regularly review these metrics and adjust your approach as needed and be transparent with all stakeholders on outcomes.
- Stay Agile: DORA is not static. As the threat landscape evolves, so will regulatory guidance. Build adaptability into your processes so you can pivot quickly when new risks emerge. If you are just adding more layers to legacy and what is there, you lose Agility and add complexity.
- Communicate the Bigger Picture: Ensure everyone—from top management to frontline staff—understands that DORA is about resilience and customer trust, not just paperwork and additional administration load.
Key takeaways is that DORA represents a significant step in harmonizing and strengthening digital operational resilience across the EU. However, the risk of overcomplication can undermine its true value. Rather than piling on extra documentation and overburdening IT and GRC teams, organizations should use DORA as a springboard for meaningful, long-term digital and business transformation.
By embracing DORA as a steering mechanism, with effective organizational change and transformation management, companies can streamline outdated processes, focus on genuine risk reduction, and foster a culture of resilience. Ultimately, this approach not only satisfies regulatory requirements but also positions organizations to adapt quickly to future challenges in a rapidly changing digital environment.
Are you owning DORA through proper organizational change management or are you trusting a consultancy to manage the deployment and implementation. It can literally be the difference between being agile and able to act quickly or being stuck in place and relying on someone else to think and guide you. Time is not a luxury many have in 2025 and beyond.
