The Digital Operational Resilience Act

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The Digital Operational Resilience Act (DORA), enacted by the European Union, establishes a comprehensive regulatory framework aimed at enhancing the operational resilience of financial entities by strengthening their information and communication technology (ICT) systems and processes

Our unique knowledge of DORA, its origins and objectives means that Phoenix Resilience can be a key partner for financial institutions navigating these new regulatory requirements

A comprehensive DORA strategy and programme needs to cover all the aspects listed below.  We can engage with you to  build a strategy and a programme covering these areas.

• Initial Compliance Gap Analysis: Perform a thorough assessment of your organisations current ICT risk management and resilience framework against DORA’s requirements. This would include an evaluation of:
  
• ICT governance and risk management practices.
  
• Incident management and reporting capabilities.
  
• Third-party risk management and outsourcing arrangements.
  
• Testing and resilience measures for critical systems.
  
• DORA Readiness Report: Provide a detailed report outlining gaps in compliance and recommendations for achieving full DORA alignment, prioritised by risk and regulatory deadlines.

• ICT Risk Management Policy Development: Assist you in developing and formalising ICT risk management policies that meet DORA’s stringent requirements. This includes:
  
• A robust framework for managing ICT risks across the organisation.
  
• Procedures for identifying, assessing, mitigating, and monitoring ICT risks on an ongoing basis.
  
• Risk Appetite Definition: Help you establish clear risk appetites specific to ICT-related risks and ensure alignment with overall enterprise risk management.

• ICT Governance Structure Design: Help financial entities establish or optimise  governance structures to ensure proper oversight of ICT risk management and operational resilience.
• Board and Senior Management Advisory: Provide advisory services to your boards and senior management on their responsibilities under DORA, ensuring that they are adequately informed and involved in ICT risk governance and strategic decision-making.

• Incident Response Plan Development: Design or enhance ICT incident management and response plans, ensuring that they meet DORA’s requirements for identifying, managing, and reporting incidents in a timely manner.

• Incident Reporting Compliance: Implement processes to ensure compliance with DORA’s requirements for reporting major ICT-related incidents to relevant authorities (e.g., the European Supervisory Authorities (ESAs)) within specified timelines.

• Crisis Management and Communication Protocols: Develop comprehensive protocols for managing internal and external communications during ICT incidents, ensuring transparency with regulators, stakeholders, and customers.

• Third-Party Risk Assessment Framework: Assist in developing and implementing a framework for assessing and monitoring third-party ICT risks, including cloud service providers, data centres, and other technology vendors.

• Outsourcing Contract Review and Due Diligence: Offer services to review existing contracts with critical ICT third parties and service providers to ensure they meet DORA’s outsourcing and third-party risk management requirements.

• Third-Party Audit and Monitoring Services: Provide continuous monitoring and audit services to ensure third-party compliance with DORA, including real-time assessments of vendor performance and resilience.

• Resilience Stress Testing Programs: Design and implement scenario-based stress testing programs for ICT systems in line with DORA’s requirements, ensuring that financial entities can withstand and recover from operational disruptions.

• Systematic Testing and Penetration Testing: Support and coordinate regular penetration testing and vulnerability assessments to identify weaknesses in ICT infrastructure and ensure robust defences against cyber threats.

• Cyber-Physical Testing Solutions: Support with other partners advanced testing that integrates both cyber and physical resilience measures to ensure that organisations are prepared for blended attacks that could impact both digital and operational infrastructure.

• Regulatory Reporting Frameworks: Help you set up systems and processes to meet DORA’s extensive regulatory reporting requirements. This would include:

• Automated ICT incident reporting workflows to meet deadlines and accuracy standards.

• Regular resilience and risk management reporting to relevant supervisory authorities.

• DORA-Compliant Continuity Plans: Assist in the development of ICT continuity plans that ensure critical ICT systems and services remain operational during and after disruptions.

• Disaster Recovery Planning for ICT Systems: Provide disaster recovery planning services that focus on restoring ICT services after major failures, breaches, or disruptions, ensuring alignment with DORA’s recovery time objectives (RTOs).

• Backup and Data Recovery Services: Advise on the implementation of robust data backup and recovery solutions that meet DORA’s resilience and redundancy requirements.

• DORA Training and Awareness Programs: Develop and deliver tailored training programs for employees, management, and the board to ensure all levels of the organisation understand their roles and responsibilities under DORA.

• Operational Resilience Culture Programs: Promote a culture of resilience by embedding operational resilience practices into daily operations, ensuring a proactive approach to ICT risk management and incident response.

• Advanced Cyber Resilience Solutions: Help you implement cutting-edge cybersecurity tools and systems that align with DORA’s ICT risk management and resilience standards, including:
• Advanced threat detection and response capabilities.
• Continuous vulnerability scanning and patch management.

• Cybersecurity and ICT Resilience Assessments: Holistic assessments of cybersecurity and ICT systems to ensure they meet the resilience requirements laid out in DORA.

• Cross-Functional Resilience Planning: Ensure the integration of ICT operational resilience with broader business continuity and disaster recovery plans, aligning with DORA’s requirements.

• Regulatory Alignment with Other Resilience Frameworks: Provide guidance on aligning DORA compliance with other international resilience and cybersecurity frameworks (e.g., ISO 22301, NIST, GDPR).

• Managed DORA Compliance Services: Continuous compliance monitoring and management services to ensure financial institutions remain compliant as DORA evolves and regulatory expectations change.

• Annual Compliance Audits: Conduct annual or periodic audits to ensure that organizations maintain compliance with DORA’s requirements, identifying potential issues and providing remediation strategies before regulatory scrutiny.

• Regulator Liaison Services: Support you in your engagements with European regulators, providing advice and support in regulatory interactions related to DORA compliance, incident reporting, and audits.

• DORA Regulatory Updates and Guidance: Provide regular updates on regulatory developments related to DORA and ensure that clients are prepared to meet evolving regulatory expectations.