Editor’s Note: The Digital Operational Resilience Act (DORA) represents a monumental shift for the financial sector across Europe, moving organizations beyond traditional cybersecurity frameworks toward more integrated resilience strategies. With a looming compliance deadline in January 2025, DORA compels financial institutions to rethink their risk management approaches, encouraging cross-functional cooperation to mitigate the growing complexity of digital threats. This article explores how financial professionals are navigating DORA’s broad mandates, from enhancing ICT risk management to building a culture of resilience, underscoring the importance of collaboration in addressing systemic vulnerabilities. As cybersecurity threats evolve, DORA’s focus on holistic risk management offers essential insights for professionals in cybersecurity, information governance, and eDiscovery.


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Industry News – Cybersecurity Beat

The Path to Operational Resilience: DORA’s Implications for the Financial Sector

ComplexDiscovery Staff

The landscape of cybersecurity and operational resilience is undergoing significant revision as regulations such as the Digital Operational Resilience Act (DORA) loom on the horizon, bringing substantial implications for financial sectors across Europe. Enacted by the European Union (EU) on January 16, 2023, with a compliance deadline looming in January 2025, DORA is poised to enhance the digital operational resilience of the EU financial sector by compelling organizations to adopt robust cross-organizational strategies. This regulation is a response to the burgeoning complexity of digital threats, necessitating a shift from traditional defensive postures to more integrated, resilience-focused frameworks.

DORA aims to break down traditional silos within corporations by requiring risk managers to scrutinize everything from ICT contractual risks to incident management protocols and resilience testing. Despite its sweeping mandates, experts such as Michael Bratton, a principle managed services consultant at Riskonnect, emphasize the variance in implementation practices, underlining the diverse approaches financial institutions need to standardize their resilience strategies. The European Supervisory Authorities, however, maintain that the implementation deadline is immutable, with no additional transitional period expected.

Kairi Ilison, the deputy of the DORA program at Nordea, likens the act to enhancing a house’s structure—adding pieces to an already complex system while ensuring operational continuity. Ilison highlights the act’s increased coordination demands across silos, noting, “The financial services sector is extremely mature and very alert to risk.” The blending of data privacy, legal, compliance, and IT underscores the need for a holistic resilience strategy. “For much of DORA, there isn’t an ‘owner’ as such – and so what becomes key is how different units work together,” Ilison explains.

The necessity for a cooperative approach is echoed by Daniel Domingos Rodrigues of Capgemini, who identifies the act as a stimulus for business continuity teams to expand their skill sets into operational resilience. He notes that cross-disciplinary cooperation is crucial for DORA’s execution, as each department holds portions of the solution to resilience challenges. Establishing protocols and governance criteria is a continuing priority, with new skills deemed essential for effective risk management and the dismantling of corporate silos.

Despite the forthcoming deadline, firms are wary that the primary goal of DORA – enhancing operational resilience – is being overshadowed by compliance burdens. “Organizations are probably not yet at the stage where they are feeling the benefits of knowing how critical systems might be susceptible to failure,” Bratton cautions. Real-world scenario testing is advocated as a means to better anticipate systemic vulnerabilities, a vital component in cultivating resilience culture within organizations. The sentiment is reinforced by Rodrigues, who urges entities to establish end-to-end control of their value chains, acknowledging the persistent difficulties organizations face in firmly grasping the risk mitigation expectations embedded within DORA.

Furthermore, while some criticize DORA for its lack of prescriptive guidance, Ilison is more positive about the suite of Regulatory Technical Standards (RTS) that provide methodological frameworks to accomplish DORA’s principles. Still, all stakeholders recognize the act’s transformational potential, urging practitioners to go beyond compliance by fostering a comprehensive risk understanding and setting clear resilience objectives. “Running a company is never without risk,” Ilison reflects. “Regulators have put us in a tough spot, and ideally, we would like more time, but there is room for applying proportionality to prioritize realistically.”

The challenges of operational resilience are not unique to Europe. In the United Kingdom, the necessity for stringent cybersecurity measures is equally urgent. Supply chain vulnerabilities have been spotlighted by ongoing cyber threats, as highlighted by Simon J. McMenemy of Ogletree Deakins. Their firm points to recent legislative initiatives, such as the UK’s Cyber Security and Resilience Bill, anticipated to introduce mandatory security requirements across industries. These measures are in parallel with the EU’s emphasis on enhanced digital security through the NIS2 directive, a reflection of the broader push for coordinated cyber defense protocols across the continent.

The cautionary tale within these measures is vividly illustrated by the pervasive data loss issues experienced by UK organizations, where research from Assurestor reveals over three-quarters have lost data to system failures, human errors, or cyberattacks in the past year. This underscores the criticality of a reliable data recovery system, a sentiment forcefully expressed by Stephen Young, executive director at Assurestor, who warns of the prevailing ‘Titanic mindset’ of assumed invulnerability.

Ultimately, DORA and its counterparts reflect an evolving regulatory environment intent on fortifying financial systems against ever-complex digital threats. By focusing on inter-organizational cooperation and comprehensive risk management, these initiatives are striving to establish a resilient financial landscape capable of adapting to the dynamic challenges of today’s digital age.

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