Cybersecurity Governance Briefing — January 17, 2025

Executive briefing: Regulation (EU) 2022/2554 on digital operational resilience for the financial sector (DORA) becomes fully applicable on January 17, 2025. Boards at EU financial entities must prove end-to-end governance of information and communication technology (ICT) risk, continuous operational resilience testing, and contractually enforceable controls over critical third-party providers. The regime harmonises incident classification and reporting windows across member states, meaning CISOs and CROs need auditable runbooks, resilience metrics, and supply-chain oversight ready for supervisory review.

Key regulatory signals

Mandatory ICT risk frameworks. Articles 5–15 require entity-wide ICT risk management, from asset inventories and protection baselines to response, recovery, and post-incident lessons learned overseen directly by management bodies.
72-hour major incident reporting. Financial entities must notify competent authorities within tight timelines using the harmonised taxonomy in the accompanying incident reporting RTS.
Threat-led testing cadence. Significant institutions must schedule threat-led penetration testing at least every three years and validate remediation, expanding red-teaming capacity needs.
Third-party oversight. Critical ICT service contracts must embed exit, access, audit, and resilience clauses, with registries of dependencies available for supervisors.

Control alignment

Map DORA to existing frameworks. Crosswalk DORA articles to ISO/IEC 27001 Annex A, NIST CSF 2.0, and EBA ICT Guidelines controls to streamline evidence packages.
Operational resilience metrics. Expand business impact analyses and tolerance thresholds so impact classification ties directly to the Article 18 testing and scenario design requirements.
Vendor lifecycle governance. Update due diligence and monitoring workflows to capture concentration risk, subcontractor chains, and notification obligations for every critical ICT provider.

Detection and response priorities

Build integrated incident intake capable of tiering events against the DORA impact taxonomy and auto-populating supervisory templates.
Instrument war-gaming exercises covering simultaneous ICT disruptions and data integrity events to evidence Board involvement and response readiness.

Enablement moves

Run cross-functional workshops with compliance, risk, procurement, and technology teams to assign accountable owners for each DORA requirement and document timelines.
Invest in resilience testing platforms and purple-team partnerships so threat-led exercises can scale without overloading internal red teams.

Sources

Zeph Tech orchestrates DORA control mapping, incident automation, and resilience testing pipelines so regulated financial entities can pass supervisory scrutiny without slowing product delivery.