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DORA COMPLIANCE

DORA Implementation: Project Governance, Testing & Third-Party Evidence

DORA sets EU-wide requirements for digital operational resilience across the financial sector. I bring program management discipline to multi-jurisdictional DORA implementations - with evidence frameworks that satisfy EBA, ECB, and local supervisors.

EU-Wide Operational Resilience

The Digital Operational Resilience Act creates a unified framework for ICT risk management across the European Union. For international financial groups, this means:

  • Harmonized ICT Risk: Consistent risk management framework across all EU entities
  • Cross-Border Testing: Coordinated resilience testing including TLPT for entities designated by competent authorities
  • Third-Party Oversight: Group-level management of critical ICT service providers
  • Unified Incident Reporting: Consolidated reporting channels meeting multiple supervisory requirements

Deliverables: EU-Wide Evidence Framework

Multi-entity DORA implementation roadmap with jurisdictional mapping
Unified evidence pack: decision log, risk register, test evidence, vendor controls
ICT third-party risk: contract/service mapping, risk controls, and exit strategies-aligned to DORA's third-party requirements
Stakeholder reporting (senior management, compliance/risk, auditors, supervisors)
Audit-ready documentation aligned with EBA guidance and local supervisory expectations

Structured evidence framework designed for multi-regulator environments - from EBA to national competent authorities.

Cross-Border Third-Party Risk

DORA introduces an EU-level oversight framework for designated critical ICT third-party providers (CTPPs), and it raises the bar for group-wide ICT third-party risk management. I support with:

  • Group-level provider mapping and criticality assessment
  • Control harmonization across jurisdictions
  • Vendor governance: consolidated reporting and exit planning
  • Preparation for ESA oversight of designated CTPPs

Multi-Entity Resilience Testing

DORA mandates coordinated testing across connected entities. I support with planning and evidence coordination:

  • Group-wide test strategy with local entity requirements
  • Cross-border scenario coordination with providers
  • Consolidated evidence management and remediation tracking
  • TLPT preparation for entities designated by competent authorities

Collaboration with Compliance / IT Risk

DORA implementation is not purely an IT topic. I work closely with the second line (Compliance, IT Risk) to:

  • Formulate controls that are both implementable AND auditable
  • Align reporting structures (management, supervisory authorities)
  • Close gaps between interpretation and implementation

Project contexts are anonymized. Roles and results are truthful; details available under NDA.

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Last updated: January 2026