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Governance, Risk & Compliance

Operational resilience, built and proven.

The EU Digital Operational Resilience Act (DORA) sets one standard for how financial entities manage ICT risk, report incidents, test resilience and oversee technology suppliers. Cybergen helps financial entities and their ICT providers get there.

The five pillars of DORA

DORAICT risk managementIncident reportingResilience testingICT third-party riskRegister of information
What is DORA?

One rulebook for financial sector resilience

DORA (Regulation (EU) 2022/2554) has applied since 17 January 2025. As a regulation, it applies directly across the EU to banks, insurers, payment and e-money institutions, investment firms, crypto-asset service providers and many other financial entities.

It also reaches technology suppliers: ICT providers must support their financial customers' obligations, and critical ICT third-party providers can be designated for direct EU oversight. Buying a tool alone does not make anyone compliant.

The five pillars

What DORA asks of you

Select a pillar to see the key requirements and how Cybergen can help.

PILLAR 1

ICT risk management

A comprehensive, documented framework to identify, protect, detect, respond to and recover from ICT risk, owned by the management body.

What it asks of you

  • Governance with clear management body accountability
  • Asset identification and classification
  • Protection, detection and recovery capabilities
  • Backup, restoration and continuity plans

How Cybergen helps

ICT risk framework gap assessments, policy development and vCISO support for governance.

Virtual CISO
PILLAR 2

Incident management and reporting

Detect, classify and manage ICT-related incidents, and report major incidents to the competent authority within set timeframes.

What it asks of you

  • Incident management process
  • Classification against DORA criteria
  • Initial, intermediate and final reports
  • Root cause analysis and lessons learned

How Cybergen helps

Incident response planning, classification playbooks and 24x7x365 detection and response.

24x7x365 MDR
PILLAR 3

Digital operational resilience testing

A risk-based testing programme, with advanced threat-led penetration testing (TLPT) at least every three years for entities identified by their authorities.

What it asks of you

  • Annual testing of critical systems
  • Vulnerability assessments and scenario tests
  • Threat-led penetration testing where required
  • Remediation of findings

How Cybergen helps

CREST penetration testing, red teaming, threat intelligence and testing programme design.

Red and purple teaming
PILLAR 4

ICT third-party risk

Manage the risk of ICT service providers throughout the relationship, with mandatory contract provisions and a register of information.

What it asks of you

  • ICT third-party risk strategy
  • Register of information on ICT arrangements
  • Due diligence and contract provisions
  • Exit strategies for critical services

How Cybergen helps

Supplier risk assessments, register of information support and contract requirement reviews.

Third-party risk
PILLAR 5

Information sharing

Voluntary arrangements to share cyber threat information and intelligence within trusted communities of financial entities.

What it asks of you

  • Participation in trusted sharing arrangements
  • Rules for protecting shared information
  • Use of intelligence in defences

How Cybergen helps

Cyber threat intelligence services that turn shared and external intelligence into action.

Cyber threat intelligence
Register of information

Know every ICT arrangement you depend on

DORA requires financial entities to keep a register of information covering all contractual arrangements for ICT services. We help you identify arrangements, assess which support critical or important functions and keep the register accurate.

Resilience testing

Testing that rises with your risk

Threat-led penetration testingAt least every three years, for entities identified by their competent authority
Advanced scenario-based testingScenario tests, end-to-end tests and red team exercises
Baseline testingVulnerability assessments, network security and source code reviews, at least yearly for critical systems
For ICT providers

Supplying financial services? Be DORA-ready.

Financial entities must include specific provisions in ICT contracts and assess their providers. If you supply technology to the financial sector, you will be asked to prove your resilience.

  • Answer DORA due diligence questionnaires with confidence
  • Understand the contract provisions your customers need
  • Evidence incident management, testing and continuity
  • Support customer audits and exit planning
How we help

DORA services, clearly scoped

01

DORA gap assessment

Identify what is in place and what needs attention across all five pillars.

02

ICT third-party risk review

Assess supplier governance, due diligence, contracts and evidence.

03

Register of information support

Identify and document relevant ICT arrangements and critical functions.

04

Incident response and resilience testing

Review and exercise processes, and deliver testing from vulnerability assessment to red teaming.

05

Supplier readiness

Help ICT providers respond to DORA questions and contractual requirements.

06

Ongoing remediation support

Help your teams deliver the agreed improvement plan.

DORA FAQ

Your questions, answered

Can't see your question? Ask our team.

When did DORA start to apply?

DORA has applied since 17 January 2025 to in-scope EU financial entities.

Does DORA apply to ICT providers?

ICT providers are affected through their financial customers' obligations and contract requirements. Critical ICT third-party providers can be designated for direct oversight by the European Supervisory Authorities.

What is threat-led penetration testing (TLPT)?

Advanced testing based on real threat intelligence that simulates the tactics of actual attackers against live production systems. DORA requires it at least every three years for entities identified by their competent authority.

What is the register of information?

A register that financial entities must maintain covering all their contractual arrangements for ICT services, including those supporting critical or important functions.

Does DORA apply to UK firms?

DORA is EU law. UK firms with EU-regulated entities, or that supply ICT services to EU financial entities, may be affected. The UK has its own operational resilience regime.

Book a consultation

Strengthen your operational resilience.

Tell us whether you are a financial entity or an ICT provider, and where you are on your DORA journey.

  1. Scoping callWe understand your entity, services and suppliers.
  2. Gap assessmentWe assess all five pillars.
  3. RoadmapWe agree priorities and support.
Prefer to talk? Call +44 (0) 1865 950 828 Or email [email protected]

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