Why DORA Compliance Should Still be a Top Priority for Financial Institutions

As the financial sector continues to digitise at pace, the risks associated with ICT disruptions have grown exponentially. In response, the European Union introduced the Digital Operational Resilience Act (DORA), which came into full effect in January 2025. For financial institutions, DORA demands a fundamental shift in managing certain digital risk elements.

However, deep into 2025, many financial organisations remain frozen in their DORA compliance efforts, perhaps in large part because of the volume of digital regulation they face.

DORA should be a top compliance priority for financial institutions operating in or serving the EU and critical third parties. The regulation is prescriptive and far-reaching. Unlike voluntary standards like ISO 27001 or directives like NIS2, it is also backed by significant enforcement powers. It also overrides and consolidates fragmented guidelines, such as those from the European Banking Authority, by expanding scope and enforcement, ensuring operational continuity even during severe digital disruptions.

But there’s good news: if your organisation is already aligned with ISO 27001, you’re well on your way to meeting many of DORA’s core requirements.

ISO 27001 is an internationally recognised standard for information security management. It provides a structured approach to risk assessment, incident response, and continuous improvement - principles central to DORA compliance.

While ISO 27001 is voluntary and sector-agnostic, DORA is mandatory and explicitly tailored to the financial sector. Still, the overlap between the two frameworks is substantial.

Organisations that have implemented ISO 27001 will find they already meet many of DORA’s expectations around:

• ICT risk management
• Incident handling
• Third-party oversight
• Governance and accountability

However, ISO 27001 alone is not enough. DORA goes further, especially in its requirements for resilience testing and business continuity planning. Financial institutions must take additional steps to achieve compliance in these areas.

Resilience testing

One of DORA’s most demanding requirements is Resilience Testing. This includes a wide range of assessments, from vulnerability scans and network security reviews to Threat-Led Penetration Testing (TLPT), a rigorous, scenario-based exercise that simulates real-world cyber attacks.

Unlike ISO 27001, which recommends testing but does not prescribe specific methods, DORA mandates that financial entities regularly conduct these tests on live production systems, covering all critical ICT assets. The institution’s risk profile determines the frequency and scope of testing, and in some cases, must be validated by regulators.

For financial institutions, this means moving beyond theoretical preparedness to practical resilience. Testing must be thorough, repeatable, and embedded into the organisation’s operational rhythm.

It’s not just about passing a compliance check - it’s about proving that your systems can withstand and recover from real threats.

Recovery and continuity for operational resilience

DORA also places significant emphasis on business continuity and recovery planning. Financial entities must identify and map critical functions, conduct Business Impact Analyses (BIA), and develop continuity strategies that are tested and refined regularly.

Many organisations face challenges in this area. Continuity planning is often siloed, outdated, or disconnected from ICT operations. DORA requires a holistic approach, integrating business and IT perspectives to ensure that critical services can be maintained during disruptions.

Regular testing of continuity and recovery plans is essential. 

Organisations must simulate disruptions, evaluate response effectiveness, and update plans based on lessons learned. These exercises should be documented, reported to senior leadership, and used to drive continuous improvement.

Compliance experts understand the complex compliance landscape and help financial institutions navigate DORA’s complexities with confidence. With bespoke services across our end-to-end cyber security capabilities, we can help ensure you complement your existing frameworks and close the DORA gap with targeted support, including:

• Resilience testing, including TLPT and scenario-based exercises
• Continuity and recovery planning aligned with DORA’s governance requirements
• Gap analysis and remediation tailored to your operational context

It’s important to remember that DORA isn’t just a regulatory hurdle—it’s an opportunity to build stronger, more resilient organisations. By leveraging their current foundation of regulatory compliance and investing in the proper testing and continuity strategies, financial institutions can meet DORA requirements while simultaneously enhancing their overall security posture.

DORA is here, and while it’s reshaping the compliance landscape for financial services, it doesn’t mean you need to toss your other compliance efforts and start again. If your organisation hasn’t yet prioritised DORA, now is the time.