DORA is not over!

How to ensure compliance and turn it into a competitive advantage

The Digital Operational Resilience Act (DORA) is redefining how financial institutions manage digital and operational risk across the EU.  What began as a regulatory mandate has now evolved into a continuous resilience journey, and for those prepared, a strategic advantage. 

Understanding DORA: The Shift from Compliance to Continuous Resilience 

The Digital Operational Resilience Act (DORA) is one of the most ambitious regulatory frameworks the EU has ever implemented for the financial sector. Its goal is simple yet profound: ensure every financial entity, from established banks to agile fintechs - can withstand, respond to, and recover from digital disruptions of any kind. 

DORA acknowledges that cyber threats and ICT dependencies have become central to financial stability. Resilience is no longer an IT issue — it’s a board-level responsibility that directly affects continuity, investor confidence, and market integrity. 

As of January 2025, DORA is fully in force. The time for preparation is over; now begins the era of sustained execution. 

Why should organizations pay attention?  

Because DORA goes beyond traditional compliance. It doesn’t just define what firms must do; it enforces how effectively they must do it. It spans governance, technology, operations, and supply-chain risk, creating a new baseline for resilience across Europe’s financial ecosystem. 

Here are four foundational imperatives that every financial institution must now embed into its DNA: 

1. Mandatory Resilience & Board Accountability 

DORA places ultimate accountability for ICT risk directly on the Management Body (Board). Leadership must approve, oversee, and ensure the continuous effectiveness of the digital resilience framework - marking a shift from technical compliance to strategic governance. 

2. Deep Supply Chain Oversight 

DORA introduces unprecedented N-Level third-party risk management. Institutions must maintain visibility and control not only over their direct critical providers but also across subcontractors down the chain, to mitigate systemic concentration risks that could threaten the wider market. 

3. Harmonized Incident Reporting 

No more fragmented national processes. DORA standardizes incident classification, timelines, and reporting templates across the EU, ensuring faster and clearer communication with supervisory authorities. 

4. Mandatory Resilience Testing 

Critical entities are required to conduct Threat-Led Penetration Testing (TLPT) and other resilience assessments. This ensures that resilience isn’t theoretical - it’s proven and measurable under real-world conditions. 

Lessons Learned: ESA Dry Runs & Regulatory Feedback 

To assess readiness ahead of full enforcement, the European Supervisory Authorities (ESAs) conducted early DORA “dry runs”. These exercises revealed that while most financial institutions had begun preparing, few were ready for the depth and operational complexity of the regulation. 

The 2024 dry run exposed key gaps. Even large, mature institutions struggled to assemble an accurate Register of Information (ROI) - the foundational dataset of DORA compliance. Far from a static reporting task, the ROI demands granular visibility across every ICT service, contract, and dependency, including those managed by external and subcontracted providers. 

The lessons were clear: 

• DORA requires deep data integration, not documentation. 

• Governance and technology must work hand in hand. 

• Continuous monitoring replaces annual checklists. 

Compounding the challenge, supervisory templates and validation rules evolved in real time, creating a moving target for compliance teams. The outcome: widespread rework, inconsistent submissions, and high rates of data quality rejections. 

Key Findings from Early Supervision 

• Data Quality Issues: Inconsistent classification and missing details in the ROI led to failed validations. 

• Lack of Harmonisation: Different interpretations among National Competent Authorities (NCAs) caused redundant efforts. 

• Identifier Confusion: Unclear use of LEI vs. EUID identifiers created friction. 

• Complex Subcontracting Rules: Debate between the European Commission and ESAs over scope exposed the legal and operational difficulty of managing subcontractor chains. 

• Operational Burden: Maintaining the ROI manually proved resource-intensive and unsustainable. 

The biggest takeaway?  DORA compliance isn’t a one-off exercise; it’s a living process. Institutions that embrace automation, centralisation, and continuous oversight will not only stay compliant but also gain a decisive competitive edge. 

Regulat.io: Simplifying and De-Risking DORA Compliance 

To help clients navigate this new regulatory landscape, MAQIT developed Regulat.io, a proprietary platform built as part of our broader strategy to simplify complex compliance processes and transform regulatory challenges into business advantages. 

Grounded in MAQIT’s expertise in regulatory technology, cybersecurity, and risk management, Regulat.io delivers a streamlined, intelligent approach to digital resilience that aligns with the highest supervisory standards. 

1. Automated Compliance 

Regulat.io automatically builds and maintains your DORA Register of Information, ensuring that every data point aligns with the latest ESA and NCA specifications. No manual updates, no last-minute validation surprises. 

2. Multi-Tier Contract Oversight 

The platform delivers end-to-end visibility across all contractual relationships, including N-Level subcontractors, helping firms manage systemic concentration risks with confidence. 

3. AI-Driven Contractual Gap Assessment 

Using a blend of AI-powered analysis and expert review, Regulat.io identifies contractual and control gaps instantly - accelerating time-to-compliance and reducing human error. 

4. Proven Implementation Success 

With 15+ successful DORA ROI implementations already delivered for major financial institutions in Luxembourg and across Europe, Regulat.io’s track record speaks for itself. 

5. Audit-Ready Confidence 

Every element of your compliance process is traceable, verifiable, and ready for supervisory inspection, giving CISOs and compliance teams peace of mind. 

Turning Compliance into Strategic Advantage 

Forward-thinking firms understand that resilience is the new differentiator. With Regulat.io, compliance becomes more than a regulatory obligation, it becomes a strategic capability. 

From Cost Center to Intelligence Hub 

Regulat.io transforms compliance from a reactive function into a data-driven intelligence hub, enabling proactive decision-making and operational efficiency. 

Complete Risk Visibility 

A powerful dashboard provides real-time oversight of: 

• Data storage and processing locations 

• Critical service provider distribution 

• Emerging concentration risk “hotspots” 

Efficiency and Return on Investment  

Automation saves hundreds of man-hours annually, turning compliance costs into measurable performance improvements. 

Investor and Partner Confidence 

Transparent resilience management boosts market credibility and demonstrates a strong governance culture to investors, partners, and regulators. 

Continuous Regulatory Alignment 

Regulat.io continuously adapts to the latest ESA and NCA requirements, ensuring your submissions remain audit-ready, compliant, and future-proof. 

Conclusion: A Resilient Future Starts with Smart Compliance 

DORA marks the start of a new era in financial resilience, one defined by governance, transparency, and technological agility.  With MAQIT’s Regulat.io, institutions can stay ahead of regulation, simplify complexity, and turn compliance into competitive advantage. 

Ready to Transform Compliance? 

MAQIT helps financial institutions build the resilience of tomorrow, today. Contact us to discover how Regulat.io can future-proof your DORA compliance strategy. 

Get a snapshot of DORA, the Shift and how we can help you here

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