DORA Readiness and Compliance Audit
From January 2025 the financial sector must comply with DORA - Digital Operational Resilience Act. Check organization readiness, identify gaps and implement requirements before supervisory controls.
What is a DORA compliance audit?
A DORA (Digital Operational Resilience Act) compliance audit is a comprehensive assessment of a financial organization's readiness to meet EU regulation requirements for digital operational resilience. nFlo evaluates ICT risk management, incident response processes, resilience testing, and third-party provider risk management.
DORA is not just IT - it's risk management transformation
From gap analysis to full compliance
Readiness Assessment
Evaluation against DORA's 5 pillars
Gap Analysis
Identifying gaps in each area
Roadmap
Prioritized implementation plan
€2 Million Fine - Inadequate ICT Risk Management
A European bank received a fine from supervisors for inadequate IT vendor risk management. An outage at one cloud provider caused 8-hour downtime of transaction systems. The bank had no exit strategy or resilience tests for critical vendors.
Without DORA compliance:
- Fines up to 1% of annual revenue from supervisors
- No control over third-party ICT provider risk
- Chaotic incident reporting to supervisors
- Inadequate digital resilience testing
Comprehensive Path to DORA Compliance
We guide you through all 5 DORA pillars - from ICT risk management to threat-led penetration testing. Not just audit, but implementation and documentation preparation for supervisors.
What you get:
- Compliance assessment against DORA’s 5 pillars (Readiness Assessment)
- Gap analysis with action prioritization
- ICT risk management framework compliant with DORA Art. 6
- Critical ICT third-party provider register
- Incident reporting procedures (Art. 17-23)
- Digital resilience testing program (Art. 24-25)
- TLPT (Threat-Led Penetration Testing) preparation
- Documentation for supervisory audits
Who Is It For?
This service is for you if you are:
- A bank, credit institution or credit union
- An insurance or reinsurance company
- An investment firm or investment fund
- A payment institution or e-money institution
- A crypto-asset service provider
5 DORA Pillars
1. ICT Risk Management (Art. 5-16)
ICT risk management framework:
- ICT asset identification and classification
- System and service risk assessment
- ICT risk management policies and procedures
- Protection and prevention mechanisms
- Detection, response, recovery capabilities
- Learning and evolving (continuous improvement)
2. ICT-related Incident Management (Art. 17-23)
Incident management system:
- Incident classification (major vs. other)
- Detection and response procedures
- Incident reporting to supervisors (FCA/ESMA/EBA)
- Threat information sharing
- Root cause analysis and remediation actions
3. Digital Operational Resilience Testing (Art. 24-27)
Resilience testing program:
- Vulnerability assessments and scans
- Open source analysis
- Network security assessments
- Gap analysis
- Penetration testing
- TLPT - Threat-Led Penetration Testing (for large institutions)
4. ICT Third-Party Risk Management (Art. 28-44)
ICT vendor management:
- ICT third-party provider register
- Critical or important ICT services identification
- Pre-contract due diligence
- Contractual requirements (exit strategy, audit rights)
- Continuous vendor monitoring
- Exit plans and contingency measures
5. Information Sharing (Art. 45)
Threat information sharing:
- Participation in information sharing arrangements
- Cyber threat intelligence
- Cooperation with other financial entities
Implementation Timeline
Phase 1: Gap Analysis (4-6 weeks)
- DORA compliance assessment
- Gap identification in 5 pillars
- Roadmap with priorities
Phase 2: Quick Wins (2-3 months)
- Incident reporting procedures
- Critical ICT provider register
- Basic testing program
Phase 3: Implementation (6-12 months)
- ICT risk management framework
- Third-party risk management program
- Advanced resilience testing
- TLPT preparation (if applicable)
Phase 4: Continuous Compliance
- Monitoring and reviews
- Documentation updates
- Reports for management and supervisors
Key DORA Requirements
ICT Risk Management Framework
| Requirement | Description |
|---|---|
| Governance | Board responsibility for ICT risk |
| Risk Assessment | Regular ICT risk assessments |
| Protection | Technical and organizational measures |
| Detection | Anomaly and incident detection |
| Response | Incident response procedures |
| Recovery | Business continuity and disaster recovery |
| Communication | Internal and external communication |
Third-Party Risk Requirements
| Requirement | Description |
|---|---|
| Register | Complete third-party provider register |
| Classification | Critical/important function identification |
| Due Diligence | Pre-contract assessment |
| Contracts | Mandatory contractual clauses |
| Monitoring | Ongoing performance monitoring |
| Exit Strategy | Termination and transition plans |
Related Glossary Terms
Learn more about key concepts related to this service:
Contact your account manager
Discuss DORA Readiness and Compliance Audit with your dedicated account manager.
How we work
Our proven service delivery process.
Scoping
Define scope - which entities and systems
Assessment
Compliance assessment against DORA's 5 pillars
Gap Analysis
Detailed gap identification
Implementation
Required mechanism implementation
Documentation
Documentation for supervisors (FCA/EBA)
Benefits for your business
What you gain by choosing this service.
Avoid Fines
Regulatory compliance before supervisor control
Operational Resilience
Better resilience to ICT incidents
Vendor Management
Third-party ICT risk control
Faster Response
Efficient incident reporting to supervisors
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Expand your knowledge with our resources.
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Read more →Frequently Asked Questions
Common questions about DORA Readiness and Compliance Audit.
Who does DORA apply to?
All EU financial sector entities: banks, insurers, investment firms, payment institutions, funds, crypto providers. DORA is effective from January 17, 2025.
How much does DORA implementation cost?
Gap analysis: €12,000-24,000. Full implementation for medium bank: €70,000-190,000. For small payment institution: €35,000-70,000. Depends on organization size and current maturity level.
What are the penalties for DORA non-compliance?
Up to 1% of average daily worldwide turnover for previous fiscal year, or €1 million (whichever is higher). Sanctions imposed by national supervisor.
Does DORA replace NIS2?
No - it complements. Financial sector must comply with DORA (more specific for ICT) and may be subject to NIS2. DORA takes precedence in cybersecurity for finance.
What is TLPT in DORA context?
Threat-Led Penetration Testing - advanced penetration test simulating realistic APT attack. Required for large institutions (banks, exchanges) every 3 years. Must be conducted by certified testers.