Implementing DORA: From Compliance to Long-Term Resilience

The Digital Operational Resilience Act (DORA) is no longer a concept on the horizon—it’s here. By now, most financial institutions understand what it requires. But while awareness is widespread, effective implementation remains a challenge. Many firms still view DORA as a regulatory hurdle rather than an opportunity, leading to reactive, short-term fixes instead of building long-term resilience.

The true goal of DORA isn’t just compliance—it’s future-proofing financial services against escalating digital risks. Yet, many organizations still treat resilience as an IT or compliance issue rather than a core business priority. The real divide is becoming clear: institutions that integrate DORA into their strategic vision will strengthen their operations, while those applying band-aid solutions risk falling behind.

Let’s talk about what implementing DORA really means—beyond policies, checklists, and regulatory fine print. 

Understanding the Implementation Roadmap 

DORA compliance isn’t an overnight process—it requires careful planning and phased execution. The timeline for DORA implementation can vary based on an organization’s size, resources, and preparedness, but a typical roadmap may include: 

• Months 1–3: Initial assessment, planning, and tooling selection 

• Months 4–6: Training and capability building 

• Months 7–9: Pilot implementation within select teams 

• Months 10–12: Organization-wide rollout 

• Month 13 onwards: Continuous improvement and reassessment 

However, these timelines may be compressed or expanded based on factors such as budget availability, board-level support, or the complexity of system dependencies. The key takeaway? If you haven’t started yet, don’t delay—compliance requires demonstrable evidence, not just intent. 

Why Implementation Is the Hardest Part 

At its core, DORA forces institutions to think differently about risk, operations, and digital infrastructure. It isn’t just another regulatory hoop to jump through; it’s a shift in mindset. The real challenge isn’t the regulation itself, but how organizations embed it into their existing structures without disrupting operations or stifling innovation. 

Most institutions will struggle with: 

• Fragmented risk management frameworks – Many still treat ICT risk as an IT problem rather than an enterprise-wide issue. 

• Third-party dependencies – Outsourcing has become a double-edged sword. Vendors often pose the biggest resilience risk, yet financial firms have limited visibility into their security postures. 

• Legacy systems and tech debt – The financial sector is riddled with aging infrastructure, making it difficult to adapt to modern resilience standards. 

• Cultural resistance – Risk and compliance teams understand DORA’s importance, but buy-in from leadership and business units is often lacking. 

So how do you move from compliance to genuine operational resilience? 

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Lessons from the Frontlines: Where Companies Are Getting Stuck 

While DORA outlines clear regulatory expectations, financial institutions are facing significant hurdles in translating these requirements into practical, scalable implementation strategies. Conversations with industry leaders, CISOs, and technology executives reveal common bottlenecks—where institutions struggle the most and why many are still stuck in compliance mode rather than achieving true operational resilience.

1. ICT Risk Management: A Fragmented and Siloed Approach 

Not all financial institutions claim to have strong ICT risk management frameworks.  They’re often disjointed, reactive, and outdated. Some firms are still conducting risk assessments manually, while others rely on legacy tools that don’t provide real-time insights. 

What the best companies are doing: 

• Embedding risk management into business operations rather than treating it as an isolated compliance function. This means real-time monitoring, dynamic risk scoring, and automated reporting—not static spreadsheets. 

• Using real-time risk analytics to predict and prevent incidents rather than just reacting when things go wrong. Some of the more forward-thinking banks are leveraging AI-driven risk models to detect anomalies before they escalate. 

• Gaining board-level engagement by shifting risk discussions from technical reports to financial and reputational impact analyses. 

2. Incident Reporting: The Achilles’ Heel of Most Institutions 

Most organizations are not prepared for the level of scrutiny DORA imposes on incident reporting. Regulators will expect institutions to classify incidents accurately, report them quickly, and demonstrate that they have processes in place to prevent recurrence. 

What’s going wrong? 

• Many firms lack standardized incident classification systems, leading to inconsistent reporting. 

• Incident response teams often operate in silos, delaying information-sharing across the organization. 

• There’s a huge gap in real-time analytics—without proper visibility, incidents are often detected too late. 

Leading institutions are: 

• Adopting automated reporting tools that streamline classification and escalation processes. 

• Running continuous simulation exercises to ensure teams know exactly how to respond to different types of cyber incidents. 

• Building regulatory engagement strategies—the firms that proactively work with regulators rather than scrambling to meet reporting deadlines are the ones that avoid scrutiny. 

3. Resilience Testing: The Most Overlooked Element 

DORA requires institutions to regularly test their operational resilience. While many are performing basic disaster recovery drills, very few are truly pressure-testing their systems under real-world conditions. 

What leading companies are doing differently: 

• Conducting intelligence-led threat simulations (TIBER-EU framework) to mimic real cyberattack scenarios. Some banks are running full-scale ransomware simulations to stress-test their response capabilities. 

• Testing third-party dependencies as part of their own resilience strategy—rather than assuming vendors are secure, they’re actively stress-testing vendor ecosystems. 

• Integrating resilience testing with cloud and digital transformation initiatives to ensure new technologies don’t introduce new risks. 

4. Third-Party Risk: The Weakest Link in Most Financial Institutions 

A single weak vendor can expose an entire financial institution to systemic risk. DORA mandates stronger oversight of third-party providers, yet many institutions still take a checklist-based approach rather than continuously assessing vendor risk. 

The most resilient firms: 

• Demand real-time security monitoring from critical third parties rather than relying on outdated annual audits. 

• Renegotiate contracts with vendors to include stricter resilience obligations—some financial institutions are even requiring vendors to meet the same security standards as internal teams. 

• Build redundancy into vendor relationships—institutions that rely too heavily on a single third-party provider are creating unnecessary risks. 

5. Information Sharing: An Industry-Wide Challenge 

DORA encourages financial institutions to share threat intelligence, but there’s a cultural resistance to open collaboration. Many firms see transparency as a competitive risk rather than an industry imperative. 

What’s changing? 

• Leading banks are actively participating in financial sector ISACs (Information Sharing and Analysis Centers) to stay ahead of emerging threats. 

• Some institutions are forming resilience partnerships with competitors—this might seem counterintuitive, but shared intelligence benefits the entire ecosystem. 

• Regulators are increasingly pushing for mandatory information-sharing requirements, meaning firms that aren’t proactive now may soon have no choice. 

Bridging DORA with Existing Security Frameworks 

Most financial institutions aren’t starting from scratch—many already adhere to frameworks like ISO 27001, NIST CSF, or the EBA ICT and Security Risk Guidelines. DORA doesn’t replace these but builds upon them, requiring firms to assess where overlap exists and where gaps need to be filled. A structured gap analysis between existing security frameworks and DORA requirements can help organizations avoid redundant efforts while ensuring compliance. 

For instance: 

• ICT Risk Management – Organizations following ISO 27005 (risk management) or NIST’s Risk Management Framework (RMF) already have foundational risk practices in place. Under DORA, they need to enhance real-time monitoring and incident classification. 
• Incident Reporting – While ISO 27035 provides guidance on security incident response, DORA demands a more prescriptive and time-sensitive reporting structure. 
• Third-Party Risk Management – Organizations following outsourcing guidelines from EBA, Basel, or SOC 2 reports must go further under DORA by ensuring continuous monitoring of vendor security postures—not just periodic audits. 

The Difference Between Compliance and Resilience 

DORA presents two paths for financial institutions. One is to treat it as a regulatory hurdle—checking boxes, submitting reports, and doing the bare minimum to avoid fines. The other is to see it as an opportunity to build long-term resilience, modernize infrastructure, and develop a security-first culture. 

The financial institutions that get this right aren’t just hiring more compliance officers or updating policy documents—they’re embedding resilience into every layer of their business. They’re leveraging automation, integrating risk into strategic decision-making, and ensuring that operational resilience is owned by the entire organization, not just the IT team. 

For assurance leaders, the challenge is clear: Don’t just comply with DORA—use it as a catalyst to transform your institution’s approach to resilience. Those who do will emerge not just as compliant firms, but as industry leaders in security, stability, and trust. 

How CERRIX Supports Resilient DORA Implementation 

By integrating risk management, incident reporting, resilience testing, and third-party management into a unified platform, CERRIX empowers financial institutions to streamline compliance efforts and proactively address ICT-related risks. 

Benefits of Integrating DORA’s Five Pillars with CERRIX 

1. Optimize Compliance Processes: Automate and centralize risk, reporting, and testing workflows for improved efficiency and accuracy. 

2. Improve Decision-Making: Centralize data and provide actionable insights to stakeholders, enabling informed decisions. 

3. Build Long-Term Resilience: Empower your organization to establish a proactive framework to address evolving ICT risks while integrating DORA into existing GRC frameworks. 

With CERRIX solutions, financial institutions can align with DORA’s requirements, transforming compliance from a regulatory obligation into a strategic advantage. 

Take Action: Download our white paper or schedule a demo to discover how CERRIX can empower your organization to achieve sustainable success under DORA.