DORA (Digital Operational Resilience Act)
Five pillars of DORA
DORA is structured around five core requirements:
- ICT risk management – financial entities must establish and maintain a comprehensive ICT risk management framework, including identification, protection, detection, response, and recovery capabilities
- ICT-related incident reporting – significant incidents must be reported to the relevant competent authority using standardised templates and timelines
- Digital operational resilience testing – regular testing of ICT systems, including threat-led penetration testing (TLPT) for significant entities, aligned with the TIBER-EU framework
- ICT third-party risk management – contractual and operational oversight of ICT service providers, with specific requirements for critical third-party providers subject to direct EU oversight
- Information sharing – voluntary arrangements for financial entities to exchange cyber threat intelligence within trusted communities
DORA and the UK
The UK is not bound by DORA post-Brexit. However, the FCA and PRA have their own operational resilience requirements (PS21/3 and SS1/21) that share significant common ground with DORA. UK financial institutions are affected where they have subsidiaries or branches operating within the EU, they provide ICT services to EU financial entities, or EU-regulated clients require DORA-aligned assurance from their UK service providers.
The Bank of England’s CBEST framework for threat-led penetration testing aligns closely with DORA’s TLPT requirements and the TIBER-EU methodology it references.
Cyberfort Group and DORA
We support financial services organisations with ICT risk assessments, resilience testing, and third-party risk management aligned with both DORA requirements and UK PRA/FCA operational resilience rules. Our CHECK & CREST-qualified testers deliver the threat-led penetration testing that DORA mandates for significant entities. [Learn more about our cyber security review →](/services/cyber-security-review/)
Related terms
- [NIS2 Directive](/glossary/nis2-directive/) – the EU’s cross-sector cybersecurity legislation, complementary to DORA for financial services
- [Red teaming](/glossary/red-teaming/) – the adversarial simulation methodology underlying DORA’s threat-led penetration testing requirements
- [NCSC CAF](/glossary/ncsc-caf/) – the UK’s Cyber Assessment Framework, used alongside PRA/FCA rules for UK financial sector assessments
External references
- [Wikipedia: Digital Operational Resilience Act](https://en.wikipedia.org/wiki/Digital_Operational_Resilience_Act) – legislative overview
- [EUR-Lex: Regulation (EU) 2022/2554](https://eur-lex.europa.eu/eli/reg/2022/2554) – full legislative text
- [EBA: DORA Implementation](https://www.eba.europa.eu/regulation-and-policy/operational-resilience) – regulatory technical standards
- [Wikidata: Q115407702](https://www.wikidata.org/wiki/Q115407702) – canonical entity identifier
Frequently asked questions
Does DORA apply to UK financial institutions?
DORA does not directly apply in the UK post-Brexit. However, UK firms with EU subsidiaries, EU-regulated clients, or that provide ICT services to EU financial entities will face DORA compliance requirements through contractual obligations or local subsidiary regulations.
What is the difference between DORA and NIS2?
DORA is sector-specific to financial services and focuses on ICT operational resilience, including detailed requirements for third-party provider oversight and threat-led penetration testing. NIS2 is a cross-sector cybersecurity directive with broader but less granular requirements. Financial entities in scope for DORA are also subject to NIS2, but DORA’s specific requirements take precedence.
What testing does DORA require?
DORA requires regular digital operational resilience testing for all in-scope entities, and advanced threat-led penetration testing (TLPT) at least every three years for significant financial entities. TLPT must follow the TIBER-EU framework and be conducted by qualified, independent testers.
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Greenham Business Park, Thatcham,
Berkshire,
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