Turning Policy Into Practice: Activating Governance Under DORA
Turning Policy Into Practice: Activating Governance Under DORA
Moving from Passive Governance to Active Compliance
In many financial institutions, governance has become little more than a formality. Policies and procedures are drafted, approved, and archived to fulfill regulatory obligations. But in practice, they often remain disconnected from the actual controls and behaviors they are meant to guide.
Under the Digital Operational Resilience Act (DORA), that passive approach is no longer enough. The regulation raises the bar by requiring financial entities to demonstrate how their governance documents translate into tangible operational resilience. DORA does not just ask whether you have a policy. It asks whether your policies drive action.
The Problem with Policy in Isolation
Too often, compliance and legal teams operate on separate tracks from operational and technical stakeholders. A policy may outline how to manage ICT continuity or vendor risk, but without integration into everyday workflows, those policies rarely shape decisions or outcomes.
The result is a range of governance challenges that weaken the effectiveness of compliance programs. Policies often become outdated or lack clear ownership, leaving them vulnerable to neglect. Governance documents may fall out of alignment with evolving regulatory frameworks, creating gaps in coverage. Internal controls are frequently poorly documented or applied inconsistently, which makes oversight difficult. Additionally, many organizations struggle with limited visibility into how policy language translates into actual operational practices.
DORA challenges this model by requiring traceability from regulatory requirements to internal controls. Policies must evolve from static artifacts to living documents with real accountability and operational impact.
Governance as a Foundation of DORA Compliance
One of DORA’s key pillars is robust ICT risk management and governance is central to that. The regulation emphasizes not only the existence of policies, but also their implementation, periodic review, and alignment with the organization’s risk profile.
This includes:
Documenting roles and responsibilities
Defining control objectives
Establishing review cycles
Updating documents based on regulatory or operational changes
Governance under DORA is about connection, specifically how your policies link to controls, systems, owners, and outcomes.
Connecting Policy to Actionable Oversight
Regulators do not just want to know that policies exist. They want to see:
Who owns each policy
When it was last reviewed
How it maps to DORA’s Articles
What controls support its implementation
How those controls are tested and monitored
This level of visibility requires more than a shared folder or spreadsheet. It demands systems and processes that tie governance to compliance execution.
Organizations must be able to demonstrate, at any time, how their policies align with regulatory expectations and how they are being implemented in practice.
From Governance as a Formality to Governance as a System
Too often, policy documents are treated as shelfware. They exist to pass an audit, not to inform real decision-making. But under DORA, governance must become a living part of your risk and compliance operations.
True governance requires:
Living policies with clear ownership
Regular review and accountability
Direct connections to DORA Articles and internal controls
Audit-ready documentation at every stage
This shift allows organizations to respond faster to regulatory changes, close gaps in control coverage, and strengthen operational resilience.
Make Governance Work for You
Policies are only as valuable as the actions they inspire. Under DORA, governance must be proactive, tested, and traceable. Financial entities that fail to operationalize their policies will struggle to meet compliance expectations and expose themselves to avoidable risks.
By investing in structured policy governance, organizations can transform documentation into a tool for oversight, accountability, and resilience.