DORA: From Regulation to Documentation

The Digital Operational Resilience Act is transforming how financial institutions across the EU approach ICTrisk, resilience, and governance. While the regulation itself is ambitious, one of the most practical challenges is clear: the list of required documents, policies, and procedures that organizations must create and maintain.

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What’s Required Under DORA?

The BaFin overview makes it clear that compliance is documentation-heavy. Entities must produce, maintain, and regularly update:

Strategies: Digital operational resilience strategy (Art. 6 DORA), ICT risk management framework, ICT business continuity strategy.

Policies:

☑️ Information security & ICT risk management policies

☑️ Backup, patching, and vulnerability management policies

☑️ ICT change management, incident management, and encryption policies

☑️ ICT third-party & outsourcing policies

Procedures:

☑️ Incident classification, reporting, and crisis communication plans

☑️ Identity & access management, capacity management, and system monitoring

☑️ Testing and validation methodologies for ICT continuity & resilience

Registers & Inventories:

☑️ ICT assets, critical processes, and third-party providers

☑️ Certificates, incidents, and audit findings

In total, organizations must demonstrate comprehensive governance, linking policies and procedures directly to ICT risk management, incident response, resilience testing, and third party oversight.

This is another great publication for organizations that fall under DORA. The structured list of requirements is invaluable — it shows exactly what needs to be in place. From strategies to policies, from ICT change management to third-party registers, organizations now have a clear view of what must be documented, implemented, and maintained.

Link

Author: Sebastian Burgemejster