Beyond the Register: Building True Resilience Under DORA

The Misconception of the Register

In the wake of the Digital Operational Resilience Act (DORA), many financial entities and ICT providers rushed to meet its requirements. For some, compliance seemed straightforward: maintain a Register of Information, submit it annually, and tick the regulatory box. But this surface-level approach overlooks the true intent of DORA. The Register is not the heart of compliance; it's merely the tip of the iceberg.

Treating DORA as a once-a-year documentation exercise is a strategic misstep. The regulation is designed to ensure robust, systemic operational resilience across the European financial sector. It spans five major pillars: ICT risk management, incident reporting, resilience testing, third-party oversight, and information sharing. Understanding and embracing these pillars is key to building long-term compliance and resilience.

The Five Pillars of DORA: A Strategic Blueprint

1. ICT Risk Management

At its core, DORA mandates that organizations manage ICT risk with the same rigor as financial and operational risks. This includes identifying critical ICT systems, assessing vulnerabilities, applying security controls, and maintaining governance frameworks.

Effective ICT risk management requires continuous monitoring, scenario analysis, and proactive mitigation. Organizations must also embed these practices into their enterprise-wide risk strategies, ensuring that resilience is not siloed within IT but championed at the executive level.

2. Incident Reporting

DORA introduced strict timelines and standardized procedures for reporting major ICT-related incidents to competent authorities. This shift from ad hoc incident response to structured reporting demands that firms have well-defined escalation workflows, clear accountability, and consistent communication protocols.

The ability to report is not enough. Firms must also be able to detect, assess, and document incidents in real time. Without a solid operational framework in place, reporting becomes reactive rather than strategic.

3. Digital Resilience Testing

Annual testing of digital operational resilience is no longer optional under DORA. This includes advanced testing such as threat-led penetration testing (TLPT) for critical systems. These exercises aim to simulate real-world attacks and uncover weaknesses before adversaries do.

Resilience testing must evolve from occasional audits to an integrated practice within the risk management lifecycle. Organizations that treat testing as a one-off task risk falling short of DORA's expectations.

4. Third-Party Risk Oversight

Third-party ICT providers are a vital part of the digital ecosystem and a potential point of failure. DORA requires firms to establish contracts that ensure service continuity, monitor providers' performance, and maintain exit strategies in case of disruption.

More importantly, organizations must link third-party services to their critical functions. This mapping enables firms to assess the impact of vendor failures and enforce proportional oversight based on risk exposure.

5. Information Sharing

DORA encourages trusted information-sharing arrangements between firms, regulators, and critical infrastructure providers. By sharing threat intelligence and lessons learned, organizations can build collective resilience against cyber threats and systemic risks.

However, information sharing must be more than a compliance formality. It requires a culture of transparency, shared responsibility, and secure collaboration mechanisms.

Why Most Firms Get Stuck

Despite DORA's comprehensive framework, many firms fall into the trap of compliance minimalism. They focus on outputs such as registers, reports, and policies rather than building the systems and processes that make these outputs meaningful.

This approach is not only shortsighted but risky. Without integrated systems for tracking risk, documenting governance, and responding to incidents, compliance efforts will crumble under scrutiny. Reporting becomes unreliable, testing superficial, and third-party oversight fragmented.

Operationalizing Compliance with DORAedge

DORAedge was built to help organizations overcome these challenges. It helps you fill out the Register of Information while also enabling you to build the infrastructure that supports it.

Here's how:

• Mapping Providers to Critical Functions: Automatically link services and vendors to the core operations they support, enabling proportional oversight and risk evaluation.

• Real-Time Risk Tracking: Monitor ICT risks continuously, flag emerging threats, and prioritize mitigations using AI-driven insights.

• Governance Documentation: Centralize your policies, procedures, and roles so governance can be demonstrated and audited at any time.

• Integrated Incident Management: Log, escalate, and resolve ICT incidents from a single dashboard, complete with compliance-ready reporting tools.

• Automation and Intelligence: Use smart templates, pre-filled fields, and embedded guidance to streamline compliance tasks and reduce manual errors.

With DORAedge, compliance becomes part of your operating rhythm, not an annual scramble.

From Checklist to Strategy

The message is clear: compliance is not a checklist. It is a continuous system of controls, reviews, and improvements. And resilience? That does not come from submitting a document once a year. It comes from embedding DORA into your operations, your culture, and your strategy.

The Digital Operational Resilience Act is comprehensive for a reason. The threat landscape is evolving, and financial entities must evolve with it. Treating DORA as a strategic imperative, rather than a bureaucratic hurdle, is the first step toward true operational resilience.

Step Into Full-Spectrum Compliance

The Register of Information is just one output of a much larger process. True compliance under DORA requires a system of interconnected practices, technologies, and mindsets. With the right tools and approach, organizations can not only meet regulatory expectations but enhance their resilience and competitive edge.

DORAedge empowers you to do just that.

Book a demo today to see how full-spectrum compliance can be operationalized for your organization.