The DORA Compliance Checklist

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As of January 17, 2025, all financial entities and their information and communication technology (ICT) service providers catering to EU entities must comply with the Digital Operational Resilience Act (DORA).
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If you’re new to the regulation, you can reduce the potential overwhelm caused by its various requirements by using a concise compliance checklist. To help, we created this guide that covers everything you should know, including:
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DORA applicability criteria
The regulation’s key requirements
An actionable DORA compliance checklist with the key steps you need to take

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Who needs DORA compliance?

DORA is aimed specifically at EU-based financial entities and ICT service providers. The following table provides examples of both:
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Entity	Examples
Financial entities	Payment and credit institutions Electronic money institutions Investment firms Insurance companies Trade repositories
ICT service providers	Cloud providers Network security companies IT consulting firms Managed IT service providers Help desk service providers

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While financial entities affected by DORA are limited to those operating in the EU or serving EU customers, ICTs must comply with the regulation regardless of location if they provide services to EU-based financial organizations.

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5 key compliance requirements of DORA

While DORA mandates various security controls and procedures, the most important requirements are the regulation’s five pillars:
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ICT risk management
ICT-related incident management
Digital operational resilience testing
ICT third-party risk management
Information sharing
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Out of the five, information sharing is the only voluntary aspect. You are required to comply with the requirements outlined in the other four pillars. As all of them are comprehensive and call for specific actions, a reliable checklist can help you streamline the compliance process and keep you focused on the main deliverables.

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Your DORA compliance checklist: 9 key steps

Before starting the DORA compliance process, you should determine the regulation’s scope and applicability to your organization. The best way to do this is to refer to DORA’s Article 2 to check whether your organization is impacted by it based on your services and location.
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If your organization must adhere to DORA, here are the baseline steps you can follow to get closer to full compliance:

Access Review Stage	Content / Functionality
Across all stages	Easily create and save a new access review at a point in time View detailed audit evidence of historical access reviews
Setup access review procedures	Define a global access review procedure that stakeholders can follow, ensuring consistency and mitigation of human error in reviews Set your access review frequency (monthly, quarterly, etc.) and working period/deadlines
Consolidate account access data from systems	Integrate systems using dozens of pre-built integrations, or “connectors”. System account and HRIS data is pulled into Vanta. Upcoming integrations include Zoom and Intercom (account access), and Personio (HRIS) Upload access files from non-integrated systems View and select systems in-scope for the review
Review, approve, and deny user access	Select the appropriate systems reviewer and due date Get automatic notifications and reminders to systems reviewer of deadlines Automatic flagging of “risky” employee accounts that have been terminated or switched departments Intuitive interface to see all accounts with access, account accept/deny buttons, and notes section Track progress of individual systems access reviews and see accounts that need to be removed or have access modified Bulk sort, filter, and alter accounts based on account roles and employee title
Assign remediation tasks to system owners	Built-in remediation workflow for reviewers to request access changes and for admin to view and manage requests Optional task tracker integration to create tickets for any access changes and provide visibility to the status of tickets and remediation
Verify changes to access	Focused view of accounts flagged for access changes for easy tracking and management Automated evidence of remediation completion displayed for integrated systems Manual evidence of remediation can be uploaded for non-integrated systems
Report and re-evaluate results	Auditor can log into Vanta to see history of all completed access reviews Internals can see status of reviews in progress and also historical review detail