No phone test, no BCP
If an authorised responder cannot find, activate and follow the continuity plan from an approved phone in ten minutes, the plan is not operational. What DORA Article 11 and RTS 2024/1774 expect from a real test.
Read moreExpert DORA consultancy helping financial institutions across the UK and Europe navigate the EU Digital Operational Resilience Act with confidence.
DORA identifies five critical areas and helps organisations focus attention where the potential impact is high.
Overarching frameworks to standardise identification of critical assets and their dependencies, allocate priorities and quantify ICT risks using various scenarios and models.
Learn moreNavigate complex regulatory landscapes with expert guidance on DORA compliance, helping your organisation meet all requirements and evidence its compliance effectively.
Learn moreComprehensive audit services for ICT suppliers, from dedicated theme audits to end-to-end reviews and independent reports for third-party service providers.
Learn moreRecently published ESA guidelines, which various central banks have also echoed, create a tight timeline for showing evidence of compliance.
Most central banks expect to receive the information registers by early April 2025, which aligns with the next steps of register consolidation, evaluation, and use for Critical ICT third-party service providers (CTPPs), aiming to designate the CTPPs and start the oversight engagement this year.
Your organisation register must include the required details, which are typically unavailable; therefore, it takes time to compile and validate it. This includes mapping all ICT assets, documenting dependencies, and classifying services according to their criticality to your business operations.
DORA compliance is not a one-off exercise. It requires an ongoing programme of risk management, incident reporting, resilience testing, and third-party oversight that must be embedded into your organisation's governance structure.
In our workshops, we will help you evaluate your current level of ICT compliance and provide a relevant structure to manage it efficiently. We can also support your organisation by outsourcing various compliance processes to us.
It can be tedious since small to medium-sized financial entities use between 15 and 60 ICT suppliers. While not all of those suppliers are critical, and we assume that your organisation could identify those correctly, even for those that are critical, the audit will take, on average, 7 to 10 days to complete. The larger entities can expect a more significant number of critical suppliers with associated efforts.
The ESA regulatory technical standards on third-party risk set out specific requirements for the content of contracts with ICT service providers, sub-outsourcing arrangements, and the information register that financial entities must maintain. Understanding these requirements early allows you to plan your audit programme effectively.
We can help with our audit services, from dedicated theme audits to comprehensive end-to-end reviews. Let's have a chat about your DORA challenges.
In a world of constant change, you need to serve your customers and markets continuously in the best possible way. Your stability is essential — therefore, being well prepared is crucial.
The EU Digital Operational Resilience Act (DORA) is a complex regulation that requires significant attention across your entire organisation. From board-level governance to day-to-day ICT operations, every layer of your business must understand its role in maintaining digital operational resilience.
Our training programmes are designed to give your teams the knowledge they need, while our expert workshops provide hands-on guidance for building a compliant and resilient operation.
DORA doesn't apply to you directly, but it does apply to your client. The DORA addenda you're receiving are drafted by European lawyers who are over-indexing to protect their organisations. Simply signing what's put in front of you is commercially reckless, while refusing to engage is existentially reckless. From incident notification windows and subcontractor chain responsibility to audit rights, business continuity testing, and exit strategies — the new requirements demand a significant effort. Read more about IT suppliers' legal obligations under DORA and how to pragmatically address them.
Fifteen months into DORA, the Register of Information has been submitted by most firms — and forgotten by most of them. The dry-run produced a 6.5% data-quality pass rate among 1,039 voluntary early adopters. The analytical fields on substitutability, alternatives, and sub-outsourcing chain were systematically left blank, and the register that was meant to be an internal risk artefact has been treated as an annual filing. Meanwhile, the 19 designated Critical ICT Third-Party Providers represent 0.13% of the financial sector's ICT supply — and incidents like ION Group and ICBC FS keep originating in the other 99.87%. Read our two-part analysis: the DORA Register of Information trap and what the Critical 19 CCTP list actually tells us, including the subcontracting chain, the on-prem/co-location segment the cloud-native framing misses, and the sovereignty profile of EU financial-sector ICT.
Procurement teams across Europe are collecting ISO 27001 certificates and SOC 2 Type II reports from suppliers and filing them as DORA evidence. They answer a different question. ISO 27001 attests that a management system exists at a point in time, SOC 2 is a use-restricted US attestation that never touches concentration risk, exit strategies or the Register of Information, and HIPAA is a healthcare privacy regime. None of them tells you whether a critical supplier can keep operating through a severe-but-plausible disruption and prove it with evidence a regulator can verify. Our analysis sets out what DORA actually demands of third-party risk management, and why the “send me your SOC 2 and we are done” workflow is now a liability rather than a control: Caught in the middle: why DORA means tough times for Procurement.
Give an authorised responder an approved phone, take away the laptop and start a ten-minute timer. Can they find the current plan, see who activates it, read the first actions and reach the response team? If not, the plan sits behind the same identity provider, email and document store that just failed. DORA Article 11 and RTS 2024/1774 require continuity tests built on severe but plausible scenarios that challenge the assumptions the plans rest on, and ISO 22301 requires plans to be available at the time and place they are needed. Our analysis covers what breaks in a real test, from circular dependencies and expired break-glass secrets to RTO figures the architecture cannot deliver, and why frequent automated recovery is the only durable answer: If you can’t test your BCP right now, from your phone, you don’t have a BCP.
Regulatory updates, ESA guidance and analysis from the DORA implementation frontline.
If an authorised responder cannot find, activate and follow the continuity plan from an approved phone in ten minutes, the plan is not operational. What DORA Article 11 and RTS 2024/1774 expect from a real test.
Read moreHM Treasury designated AWS, Google Cloud, Microsoft and Oracle from 13 July 2026. All four are also EU CTPPs, the first practical test of joint UK and EU oversight.
Read moreNational entry points replace the proposed ENISA single entry point for incident reports. DORA reporting obligations and timelines stay as they are, and the text is not final.
Read moreOur team of experienced consultants is here to help.
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