How to Achieve DORA Compliance: Key Requirements and Steps

Short Summary

DORA compliance is now mandatory for financial institutions operating in or with the EU, raising the bar for digital risk management and operational resilience. This blog explains what DORA compliance involves, which metrics matter, and how firms can meet ongoing requirements – from incident reporting to third-party oversight. 

Financial services run on technology. Core banking systems, cloud infrastructure, digital communications, payment platforms, AI-based fraud detection – every part of the industry depends on tech staying fast, secure, and uninterrupted. When that tech goes down, the impact can be immediate and widespread. 

Earlier this year, Barclays experienced a three-day IT failure that brought down online banking, card transactions, ATMs, and phone systems, just as millions of customers were expecting payday deposits and tax returns. The result was an estimated £7.5 million in compensation, plus reputational damage that no amount of money can fix. It’s a sharp reminder that operational resilience is financially, legally, and brand-critical. 

That’s where the EU’s Digital Operational Resilience Act (DORA) comes in. Introduced to strengthen how financial firms across the bloc handle digital disruptions, DORA sets out clear rules for managing IT risk, reporting major incidents, and making sure critical systems can recover quickly. The goal is to keep the financial system stable and trusted, even when the tech behind it is under pressure. 

DORA officially took effect in January 2025, and compliance is now a legal obligation for firms operating in or with the EU. The focus has shifted from preparation to execution and to demonstrating that systems, vendors, and teams are meeting the new standards in practice. 

This blog will walk through everything you need to know: what is DORA compliance, how to measure and monitor it, what steps to take to prepare, and the practical benefits that come with getting it right. 

What Are the Benefits of DORA Compliance? 

Getting DORA-compliant brings real advantages. Beyond meeting regulatory expectations, it pushes firms to build stronger, more resilient operations from the ground up. Here’s what that looks like in practice: 

• Fewer Disruptions, Faster Recovery: DORA encourages companies to map out their digital systems, identify weak spots, and plan for recovery. That means fewer surprises, and if incidents do happen, they’re easier to contain and resolve. 

• Stronger Third-Party Oversight: DORA’s focus on ICT third-party risk means firms are required to assess, monitor, and manage the tech partners they rely on, reducing hidden vulnerabilities. 

• Improved Incident Reporting and Learning: Having a structured, timely way to report ICT incidents helps firms spot patterns and adapt. It’s not just about reporting upwards to regulators, but also feeding lessons back into internal risk strategies. 

• Greater Trust from Clients and Stakeholders: Firms that can demonstrate operational resilience send a clear message: we’re prepared, we’re stable, and we take your data and money seriously. In a market where reputation can shift overnight, that kind of trust is critical. 

• Future-Proofing Operations: DORA compliance lays the foundation for long-term digital resilience. As cyber threats evolve and systems grow more complex, having these processes already in place makes it easier to adapt. 

What Does DORA Compliance Require? 

DORA sets out a structured approach to help financial firms build resilience across their digital operations. It touches everything from internal systems to third-party vendors, laying out clear expectations for how to handle risks and disruptions. To meet the regulation, companies need to focus on five core areas: 

• ICT Risk Management: Firms must establish a clear process for identifying, assessing, and managing risks related to their information and communication technologies. This includes regularly updating risk assessments and ensuring that leadership stays informed. 

• Incident Reporting: Major ICT-related incidents must be reported quickly and clearly to national regulators. This helps ensure early awareness and response to potential systemic threats across the financial sector. 

• Digital Operational Resilience Testing: Companies need to test their systems regularly, from basic assessments to advanced threat-led penetration testing, to prove they can handle disruptions and continue operating. 

• ICT Third-Party Risk Management: DORA places heavy emphasis on managing the risks that come from third-party providers. Firms must maintain oversight of critical vendors, assess their resilience, and have exit strategies in case things go wrong. 

• Information Sharing Arrangements: Firms are encouraged to share insights and intelligence about cyber threats and digital risks. It’s a way to boost collective resilience across the industry by learning from each other’s experiences. 

What Metrics Matter for DORA Compliance? 

DORA expects financial firms to monitor their operational resilience using meaningful, data-driven indicators. The exact metrics may vary by company size and risk profile, but regulators will want to see that firms can measure how prepared they are, how quickly they respond, and how well they recover. 

These are some of the most commonly used metrics that help demonstrate digital resilience: 

• Mean Time to Recovery (MTTR): Measures how long it takes to restore systems after a disruption. A lower MTTR shows that recovery plans are working and that the business can bounce back quickly. 

• System Availability (or Uptime): Captures the percentage of time critical services remain operational. High uptime helps prove that systems are resilient and downtime is rare. 

• Time to Detect (TTD): Tracks how quickly incidents are identified once they occur. Early detection limits damage and speeds up the response. 

• Number of Significant ICT Incidents: Keeping a record of major incidents – especially those reported to regulators – helps identify patterns and prioritize improvements. 

• Third-Party Performance Metrics: Given how much infrastructure is outsourced, tracking vendor performance is key. This can include response times, adherence to SLAs, or availability rates for critical services. 

Having the right metrics is only one part of the puzzle. The real challenge is in bringing all that data together, interpreting it correctly, and ensuring it aligns with DORA’s expectations. That often requires a central governance framework – a coordinated set of policies, processes, and systems that define how information flows, how decisions are tracked, and how accountability is maintained.  

Data alone doesn’t demonstrate compliance. What matters is being able to present a clear, connected picture of how risk is managed across the organization. 

How Do You Become DORA Compliant? 

DORA compliance is a phased process that builds on existing risk frameworks while filling in critical gaps. Here’s a high-level view of what that process looks like: 

• Run a DORA Gap Assessment: Start by figuring out where you stand. Map current policies, systems, and procedures against DORA’s five pillars. Where are you aligned? Where are the blind spots? This assessment will shape everything that follows. 

• Update and Align Policies: Once the gaps are clear, review internal policies to ensure they reflect DORA’s expectations. That might include refining incident response playbooks, formalizing third-party oversight, or updating your ICT risk management framework. 

• Strengthen Third-Party Governance: Identify which service providers are critical to your operations, and assess how they’re managing their own resilience. Update contracts if needed, establish escalation protocols, and create contingency plans in case a key vendor fails. 

• Test and Simulate Regularly: Firms should schedule regular resilience testing across critical systems, from tabletop exercises to penetration testing. The more realistic, the better. 

• Establish Central Oversight and Accountability: Coordination is key. Assign clear ownership for DORA compliance, ensure teams are trained, and build reporting lines that bring together data from across departments. Regulators will want to see not just controls, but the structure behind them. 

• Document, Measure, Improve: Track key metrics, log incidents thoroughly, and revisit risk assessments regularly. Compliance requires ongoing evaluation and adjustment as systems and threats evolve. Regulators are expected to begin auditing firms more closely in the coming months, so clear documentation and evidence of compliance will be increasingly important. 

DORA Compliance Checklist: Are You Ready? 

Now that DORA is in effect, firms need to regularly evaluate whether their systems, teams, and vendors are truly prepared to meet ongoing compliance demands. This checklist isn’t exhaustive, but it can help highlight where the biggest gaps might be. 

• Do we have a documented ICT risk management framework?
  That includes maintaining an up-to-date risk register, assigning responsibility, and reviewing controls regularly. It should cover everything from system outages and cyberattacks to dependencies on third-party providers. 

• Have we established clear incident response and reporting processes?
  Firms need a structured process for identifying when an incident is significant, how to escalate it internally, and when and how to notify regulators. Under DORA, serious incidents must be reported within tight deadlines, and vague or incomplete reporting won’t cut it. 

• Are we testing the resilience of our critical systems regularly?
  DORA requires firms to prove their systems can hold up under pressure. That might involve resilience simulations, red-teaming, disaster recovery drills, or tabletop exercises. These tests should be proportionate to the size and importance of the systems in question, and the results should feed back into planning. 

• Do we have oversight mechanisms for our ICT third-party providers?
  Firms need to monitor service levels, understand the provider’s resilience posture, and have exit strategies if things go wrong. If a key vendor went down tomorrow, could you switch quickly? Could you still serve your clients? 

• Are business communications – especially on mobile or messaging apps- governed and archived?
  When something goes wrong, decisions happen fast, and often over informal channels like chat or mobile messaging. If those conversations can’t be captured, it’s hard to reconstruct what happened, who made which call, or whether the right processes were followed. DORA expects firms to treat these communications as part of the operational record. 

• Do we have a governance framework that brings everything together?
  Individual controls aren’t enough – there has to be a central structure that ties it all together. This means consistent reporting lines, integrated dashboards, and oversight structures that span departments. 

How LeapXpert Supports DORA Compliance   

The LeapXpert Communications Platform is a vital partner in helping organizations achieve DORA compliance.  

LeapXpert offers a robust communications platform designed to manage and secure digital conversations effectively. The platform ensures comprehensive recordkeeping of all work-related communications, crucial for meeting DORA’s stringent record retention requirements.  

With advanced security features, LeapXpert employs end-to-end encryption to protect data during transmission, while secure data storage and strict access controls safeguard stored information from unauthorized access.  

Additionally, the platform incorporates antivirus, antimalware, and Content Disarm and Reconstruction (CDR) technologies to prevent and address potential threats, and Data Loss Prevention (DLP) policies to mitigate risks of data breaches.    

Book a demo now.    

FAQs 

Who must follow DORA compliance requirements?
DORA applies to a broad range of financial entities operating in or with the EU. This includes banks, insurance companies, investment firms, crypto-asset service providers, and ICT third-party service providers that work with them. If your organization supports the stability of the financial system, DORA likely applies to you. 

What are the main DORA compliance requirements for financial institutions?
Firms must build and maintain robust frameworks for ICT risk management, incident reporting, operational resilience testing, third-party oversight, and information sharing. These requirements aim to ensure that firms can continue operating through digital disruptions and provide clear, auditable records of how they manage risks. 

How can financial institutions achieve DORA compliance?
Achieving compliance involves assessing current systems against DORA’s five pillars, updating policies, improving incident and vendor management, and implementing regular resilience testing. Crucially, firms also need central governance frameworks that tie everything together, ensuring data is accessible, decisions are documented, and oversight is consistent. 

How do I measure DORA metrics in my firm?
Start by identifying key performance indicators like mean time to recovery (MTTR), system uptime, time to detect incidents (TTD), and vendor service levels. These metrics are typically gathered from monitoring tools, ticketing systems, and incident logs. What matters most is being able to centralize, interpret, and report them clearly. 

What are the penalties for failing to meet DORA compliance?
While each EU member state may apply enforcement differently, penalties can include regulatory fines, reputational damage, and, in severe cases, restrictions on business operations. Regulators are expected to begin audits and enforcement now that the compliance date has passed, so the risks of non-compliance are very real. 

How often should financial institutions conduct stress testing for DORA compliance?
DORA doesn’t specify an exact frequency, but testing must be regular and proportionate to the firm’s size and risk profile. Critical systems may require annual advanced testing, while less critical areas might follow a multi-year cycle. What’s important is that tests are realistic, documented, and used to improve resilience planning.