The 5 pillars of DORA: A detailed breakdown

The Digital Operational Resilience Act (DORA) is a mandatory EU regulation that aims to unify various information and communications technology (ICT) risk management frameworks into one comprehensive set of guidelines and requirements.

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The regulation is built around five pillars that strengthen and facilitate the digital and operational resilience of entities in the finance and insurance sectors. If your organization operates in these industries, you should familiarize yourself with DORA’s key requirements to ensure seamless compliance.

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This guide will cover DORA’s five pillars on a granular level and discuss the key activities you should perform to meet your obligations. You’ll also learn about the best practices for structuring those activities into a streamlined compliance workflow.

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What are the 5 pillars of DORA?

DORA’s five pillars are the regulation’s foundational principles. Their overarching goal is to help organizations in the finance sector improve their cybersecurity and resilience by mitigating ICT risks and boosting the overall stability of the financial ecosystem in the EU.

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The pillars are as follows:

1. ICT risk management
2. ICT-related incident management and reporting
3. Digital operational resilience testing
4. ICT third-party risk management
5. Information sharing

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Let’s explore a detailed breakdown of each.

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1. ICT risk management

Besides microenterprises, all financial entities operating in the EU must develop a dedicated control function for managing ICT risks. The function’s primary goal is to ensure effective ICT risk management and increase the organization's overall operational resilience.

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Some of the key steps you need to take to adhere to this pillar include:

• Developing and maintaining a comprehensive framework to identify, assess, and mitigate ICT risks
• Implementing robust systems and tools to support secure and resilient ICT operations
• Continuously identifying and assessing ICT risks and vulnerabilities
• Deploying measures to protect ICT systems and prevent incidents
• Establishing mechanisms to promptly detect anomalous activities and ICT-related incidents

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You may want to take an all-encompassing approach to risk management here that helps develop a culture of ICT risk awareness. By doing so, you’ll ensure that all relevant team members understand their obligations toward DORA and can fulfill them effectively.

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2. ICT-related incident management and reporting

DORA’s Article 17 requires financial entities to develop and implement incident management processes to effectively detect, mitigate, and provide notifications of ICT-related incidents. This aims to ensure quick responses to security concerns while enhancing transparency through detailed reports.

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To meet the requirements of this pillar, your organization must:

• Classify incidents based on impact and severity
• Report significant incidents to relevant authorities promptly
• Standardize reporting formats for consistency
• Streamline reporting processes to a central authority 

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DORA’s incident management pillar emphasizes the importance of open communication channels. You must set up an effective incident detection and communication process that encompasses all relevant departments.

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DORA also requires financial entities to develop crisis communication plans to promptly notify clients and other affected parties of “at least major incidents or vulnerabilities.” Ideally, you should assign this function to dedicated personnel or define the person or team responsible for the communication.

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If your incident reporting workflow is still heavily manual or inefficient (e.g., you use asynchronous communication that can cause delays), you can consider automation to streamline repetitive tasks like evidence collection. Some automation solutions can also help you update your incident management and other policies to align with DORA’s requirements.

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3. Digital operational resilience testing

DORA requires organizations to set up, implement, and regularly review a comprehensive digital operational testing program that serves several purposes, most notably:

• Addressing an organization’s readiness related to managing ICT-related incidents
• Identifying gaps, weaknesses, and deficiencies in an organization’s digital operational resilience
• Identifying and implementing adequate corrective measures that strengthen an organization’s resilience

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Your testing program should include various tests, tools, and methodologies to evaluate your organization’s digital operational resilience. DORA also mandates that the program takes a risk-based approach to ensure the organization understands and manages its ICT risk profile.

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This pillar has various requirements you must meet, such as:

• Conducting regular testing to assess digital operational resilience
• Evaluating the effectiveness of ICT tools and systems through testing
• Performing advanced testing to simulate real-world cyber threats

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Testing should be performed by an independent party, which can be internal or external, depending on your available resources. If you decide to conduct testing in-house, you must ensure the assigned team does that independently so there’s no conflict of interest.

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Digital operational resilience testing must be conducted at least annually. To ensure long-term DORA compliance, you may want to set up a recurring testing process that automates as many activities as possible.

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4. ICT third-party risk management

DORA’s Article 28 mandates the development of a robust third-party risk management (TPRM) framework as an essential part of your organization's ICT risk management program. The framework should be documented and built to simplify the detection and mitigation of third-party risk.

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Some key requirements of this pillar include:

• Evaluating risks arising from reliance on specific third-party providers
• Including essential clauses in contracts with ICT third-party service providers
• Identifying and overseeing critical third-party providers
• Establishing a framework for overseeing critical third-party providers
• Defining responsibilities for the primary authority overseeing critical providers 

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Security teams often consider this pillar the most challenging to comply with, mainly because of the number and complexity of their third-party relationships. DORA requires all third-party dependencies to be identified and mapped, which can require an in-depth overview of an organization’s supply chain and broader third-party network.

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To simplify the mapping process and ensure effective third-party risk management, you should maintain a robust inventory of third parties that includes all the essential information about their impact on your operations. Using capable TPRM software to build such an inventory may be a good idea because it can simplify the process significantly.

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5. Information sharing

Under DORA, financial entities have the option to exchange cyber threat information like:

• Indicators of security compromise
• Cybersecurity alerts
• Configuration tools

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While this pillar isn’t mandatory for DORA compliance, it’s still a good idea to follow it because doing so increases the overall transparency of the finance sector and may contribute to a more secure environment.

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Specifically, transparent information sharing can increase an organization's agility when it comes to adapting to emerging threats. According to DORA, sharing can happen in trusted communities of financial entities, so being a part of such a community can help your organization prepare for notable threats proactively.

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If you decide to participate in information sharing, you should formalize it through dedicated agreements. Some of the key details an agreement should encompass include:

• Participation conditions
• Involvement of public authorities
• Operational elements (e.g., the use of dedicated IT platforms)

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Best practices for adhering to DORA’s requirements

Despite the extensive requirements, complying with DORA's pillars doesn't need to be challenging—you can simplify compliance by following these best practices:

• Review your third-party relationships: Identify and list all your ICT service providers and other notable partners that impact your operations (particularly those that expose you to cybersecurity risks). Review all the corresponding contracts to identify dependencies and adjust the terms as needed.
• Scan your supply chain for vulnerabilities: Use security questionnaires to review the cybersecurity posture of upstream and downstream supply chain partners. The goal is to identify vulnerabilities that must be addressed to fortify the security posture of the entire supply chain.
• Build or adopt a TPRM framework: If you have the bandwidth and resources, you can develop a TPRM framework from scratch after understanding your risk profile. Alternatively, you can borrow from established TPRM frameworks like the NIST 800-161.
• Get guidance from compliance experts: As one of the newer EU regulations, DORA may not be as well-understood as long-standing standards. Seek expert guidance to minimize any friction or ambiguity in the compliance process.
• Support risk and compliance management with the right software: You can streamline your DORA compliance efforts better with a dedicated automation solution. Such tools typically expedite tasks such as evidence collection, policy management, and compliance tracking, which can free up more time and resources for your team.

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Vanta: Your trustworthy DORA compliance partner

Vanta is a comprehensive compliance and trust management platform that automates complex DORA compliance workflows, helping you implement the necessary controls without extensive legwork. It also reduces the compliance preparation timeframe—with Vanta, you can achieve DORA compliance in six to ten weeks, depending on the gaps you need to fill.

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The platform offers a dedicated DORA product that is designed to reduce the ambiguous elements from your compliance process. Some notable functionalities include:

• Centralized compliance program management
• Continuous visibility of your compliance status
• Pre-configured templates and policies specific to DORA’s requirements
• Expert guidance from accredited auditors throughout the compliance process
• Over 375 integrations that simplify evidence collection and make it easy to demonstrate adherence to DORA

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Additionally, you can also find compliance experts within Vanta’s service partner network to support your specific compliance ecosystem.

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Schedule a custom demo to explore how the DORA product can simplify workflows for your organization.

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A note from Vanta: Vanta is not a law firm, and this article does not constitute or contain legal advice or create an attorney-client relationship. When determining your obligations and compliance with respect to relevant laws and regulations, you should consult a licensed attorney.