DORA (Digital Operational Resilience Act) is now in full effect. If you work in financial services in the EU, or support companies that do, you’re expected to prove you can handle IT disruptions without missing a beat. That means more than just having a plan. You need working systems, clear processes, and full documentation ready today.
This article breaks down what DORA requires, what’s at stake if you fall short, and how tools such as Flosum can help you stay compliant and keep your operations running smoothly.
What Is DORA and Why It Matters for Financial Services
DORA is the EU’s most comprehensive regulation to date for safeguarding the financial system from IT-related risks. It sets unified standards for how financial entities must prevent, withstand, and recover from IT-related disruptions.
It aims to unify resilience standards across all EU countries and applies to a broad range of institutions:
- Banks and credit institutions
- Insurance and reinsurance companies
- Investment firms and fund managers
- Payment service providers and e-money institutions
- Crypto-asset service providers
- Central securities depositories
- Critical third-party ICT providers
If you provide financial services within the EU, handle EU customer data, or support EU-based institutions as a vendor, DORA likely applies to you.
The stakes for non-compliance are high. Fines, restrictions, or even regulatory shutdowns are on the table. Beyond the legal risks, failing to recover quickly from an incident can result in the loss of customer trust overnight.
Given these complexities, consult with your compliance and legal teams to determine your specific requirements under DORA.
DORA's Five Compliance Pillars
DORA compliance stands on five pillars:
1. ICT Risk Management
Your ICT risk management framework must identify, assess, and mitigate technology risks organization-wide. This requires comprehensive governance structures and documented assessment methodologies.
Essential Components:
- Risk appetite statements defining acceptable technology risk levels
- Asset inventories covering all ICT systems, data, and personnel
- Risk assessment procedures updated at least annually
- Incident escalation procedures with defined roles and responsibilities
- Board-level oversight with quarterly risk reporting
Implementation Steps:
- Begin by cataloging every ICT asset and system your organization depends on.
- Establish risk assessment criteria aligned with business criticality.
- Document clear escalation paths from technical teams to senior management.
Your framework must include both preventive controls and response procedures for DORA compliance.
Your risk management approach should match your organization's size and complexity. Smaller institutions can implement streamlined processes, while larger entities need comprehensive enterprise-wide programs.
2. Incident Reporting Under DORA Compliance
DORA sets strict timeframes for reporting ICT incidents to authorities. Your process must capture incidents quickly and accurately while maintaining detailed records for regulatory review.
Critical Timeframes:
- Initial notification within 4 hours for major incidents
- Intermediate reports within 72 hours with detailed impact assessment
- Final reports within 2 weeks including root cause analysis and remediation plans
Required Documentation:
- Incident classification procedures based on business impact
- Communication templates for different incident severity levels
- Contact lists for internal teams and external authorities
- Post-incident review processes including lessons learned
Your incident response team needs predefined triggers that automatically start reporting procedures. Train your teams to recognize reportable incidents, such as cyberattacks, system outages, data corruption, and third-party service failures affecting operations.
3. Digital Operational Resilience Testing
DORA expects you to go beyond simple scans and run realistic tests that simulate serious threats and disruptions.
Testing Requirements:
- Vulnerability assessments conducted quarterly
- Penetration testing performed annually by independent third parties
- Threat-led penetration testing (TLPT) for larger institutions every three years
- Business continuity exercises testing recovery procedures
Documentation Standards:
- Detailed test plans approved by senior management
- Test results with remediation timelines for identified vulnerabilities
- Evidence of remediation completion before next testing cycle
- Regular board reporting on testing outcomes and risk posture
4. Third-Party Risk Management
Third-party dependencies create some of your highest compliance risks. DORA requires rigorous vendor assessment and ongoing monitoring, especially for ICT service providers.
Vendor Assessment Framework:
- Pre-contract due diligence including financial stability and security controls
- Contractual provisions requiring vendor compliance with your resilience standards
- Regular audits and performance monitoring throughout the relationship
- Exit strategies and data recovery plans for contract termination
Critical Vendor Oversight:
If a vendor supports a critical function, DORA holds them to a higher standard. You’ll need detailed risk assessments, ongoing performance monitoring, and clear rules for incident reporting. Make sure your contracts include right-to-audit clauses and measurable resilience benchmarks.
Ongoing Management:
- Quarterly vendor risk reviews with documented findings
- Annual contract assessments ensuring alignment with evolving regulations
- Vendor incident reporting integration with your internal procedures
- Regular testing of vendor backup and recovery capabilities
5. Information Sharing Under DORA Compliance
DORA encourages financial institutions to build collective resilience by sharing information in a structured way. Your organization needs to take part in threat intelligence exchanges while still keeping sensitive data protected.
Mandatory Sharing Requirements:
- Incident reporting to designated authorities within prescribed timeframes
- Participation in sector-wide threat intelligence initiatives
- Cooperation with regulatory examinations and industry assessments
- Anonymous data sharing for systemic risk analysis
Voluntary Sharing Benefits:
Join industry threat-sharing platforms to get early warnings about new threats. Many financial organizations use information sharing and analysis centers (ISACs) to access real-time threat data and practical defense tips.
Privacy and Confidentiality:
Your information sharing procedures must balance transparency with data protection requirements. Establish clear guidelines for what information can be shared, with whom, and under what circumstances. Document all sharing activities for compliance audit trails.
How Data Backup and Archiving Help with DORA Compliance
Data backup and archiving are the foundation of DORA's ICT risk management pillar. These systems determine whether you recover quickly from cyber incidents or face extended downtime that attracts regulatory scrutiny.
Backup and archiving have different compliance roles. Backup handles short-term operational recovery needs. Archiving addresses long-term regulatory retention requirements that may span years or decades depending on your jurisdiction and business type.
Technical Requirements for DORA Compliance
Your backup system needs to use immutable storage so ransomware can’t tamper with recovery data, even if admin accounts are compromised. Keeping backups logically separated from production ensures that even if your main systems are breached, your backups stay safe. Data protection strategies, such as data masking, can help.
You need full audit trails that log every backup, access attempt, and restore. Just as important, regular recovery tests prove your backups actually work. In the eyes of regulators, documentation is just as important as the tech behind it.
Vulnerabilities That Compromise Compliance
Poor encryption implementation, inadequate testing procedures, insufficient access controls, and incomplete audit trails represent the most common compliance failures during regulatory examinations.
Industry frameworks like ISO 27001 and NIST Cybersecurity Framework provide structured approaches that align with DORA's digital operational resilience objectives.
Why Your Backup Strategy Directly Impacts DORA Compliance
Your backup system isn’t just about protecting against data loss. It's also a part of DORA compliance.
ICT Risk Management Integration
Backup systems function as primary risk mitigation controls within DORA's ICT risk framework. Immutable copies of critical data create safeguards against system failures and cyberattacks.
The compliance advantage comes from granular recovery capabilities that restore specific records or fields without full system rollbacks. This minimizes operational impact during incidents.
Incident Response Acceleration
DORA's incident reporting requirements demand rapid data recovery with point-in-time restoration capabilities. You need systems that quickly restore to known good states while preserving evidence for mandatory incident analysis. This supports both operational continuity and the detailed documentation DORA requires.
Resilience Testing Framework
Digital operational resilience testing under DORA requires comprehensive recovery testing scenarios. Your backup solution must simulate failure conditions and validate recovery procedures without impacting production systems. Regular restoration testing becomes compliance evidence demonstrating operational resilience capabilities to regulators.
Security Architecture Requirements
DORA-compliant backup systems require enterprise-level security solutions such as encryption, role-based access controls, and audit logging. These features protect backup data from unauthorized access while creating audit trails for compliance reporting. Bring-your-own-key encryption provides additional control over data protection standards.
Third-Party Risk Management
Flexible deployment—cloud, on-prem, or hybrid—lets organizations control where backup data lives and how it’s protected. This control is key to managing third-party risk.
On-prem and self-hosted setups keep infrastructure under internal policies, reducing reliance on vendors. Teams can apply their own encryption, access controls, and monitoring to meet compliance without compromise.
Regulators expect clear ownership of data and security. Flexible deployment supports that by limiting data exposure and simplifying audits. It helps meet data residency rules and narrows the scope of vendor risk reviews.
Compliance Documentation
Backup systems generate the audit trails, recovery time documentation, and testing evidence required for DORA compliance reporting. Comprehensive logging capabilities track data access, recovery operations, and system changes, creating the paper trail regulators expect during examinations.
How to Use Flosum to Meet DORA Compliance Requirements
Implementing Flosum’s Backup & Archive for DORA compliance requires coordination across compliance, IT security, and Salesforce administration teams.
1. Assess Current Backup and Compliance Gaps
Start with an audit of your current backup infrastructure against DORA's ICT risk management requirements. Your compliance team, IT security officers, and Salesforce admins should block 2–3 weeks for this assessment.
Build a gap analysis framework that covers:
- Backup frequency and retention policies
- Recovery testing and audit trail capabilities
- Immutable backup support and logical separation from production
- Granular restore functionality
- Vendor risk management for third-party backup tools
Document all findings in a formal compliance gap assessment. This becomes your baseline evidence during regulatory audits. Include specific deficiencies, risk scores, and remediation timelines.
2. Deploy Flosum’s Backup and Archive Infrastructure
Choose your deployment model based on your risk appetite and compliance needs:
- On-premises deployment gives you complete data sovereignty, ideal for highly regulated entities
- Cloud deployment reduces infrastructure overhead and accelerates setup
- Hybrid models work well for organizations with mixed data sensitivity levels
Use Flosum’s Composite Backup technology to back up only changed data. This shortens backup windows and reduces storage costs.
3. Set Policies for Retention, Access Control, and Testing
Develop retention policies that meet both business and compliance requirements. Financial organizations generally need 7–10 years of retention, depending on local laws and regulatory guidance. Confirm specifics with your legal and compliance teams.
Implement role-based access controls (RBAC) following the principle of least privilege. Limit backup access to authorized personnel only and require multi-factor authentication (MFA) for all admin-level actions. Ensure all access activity is logged, with visibility into who accessed what data and when.
Schedule routine testing:
- Monthly backup verification
- Quarterly restore tests
- Annual disaster recovery drills
Log all testing results, issues discovered, and corrective actions taken. This documentation is just as important as the technical tools and will be reviewed closely in a DORA audit.
Meet DORA Compliance Standards with Confidence
DORA is active and enforced. Financial institutions are now required to prove they can withstand, respond to, and recover from ICT disruptions in real time. That means systems, processes, and documentation must be fully operational.
Flosum gives you the foundation to stay ahead. With native Salesforce integration, immutable backups, granular recovery, and complete audit trails, Flosum supports every pillar of DORA compliance while strengthening your broader operational resilience.
