What Lies Beneath: Uncovering Hidden Risk in Your ICT Supply Chain
The Importance of Full-Spectrum Supply Chain Insight
When it comes to compliance with the Digital Operational Resilience Act (DORA), simply knowing your direct vendors is not enough. The regulation is clear: financial entities are accountable not only for their first-tier providers, but also for the full supply chain that supports critical functions.
A third-party ICT provider might appear compliant on paper, but what about the subcontractors behind them? What if a core vendor relies on another service to deliver uptime or cybersecurity support? If any one of those layers fails, your business could suffer. And under DORA, your organization bears the responsibility for ensuring continuity and resilience throughout the entire chain.
From Vendor Risk to Supply Chain Resilience
DORA reframes third-party risk. It does not stop at reviewing contracts or monitoring SLAs. Instead, it calls for structured oversight of how digital services are delivered end to end.
Let’s consider a common scenario:
Your organization uses a mission-critical trading platform for order execution.
That platform is hosted by a major cloud provider.
The cloud provider, in turn, outsources cybersecurity monitoring to another specialized organization.
If any link in this chain is compromised, the operational fallout lands with you. Whether the risk stems from a direct vendor or a subcontractor two levels deep, DORA expects financial institutions to manage and account for it.
What many organizations underestimate is the complexity of these relationships. With increasing specialization in the tech landscape, most digital services are not delivered in isolation. Behind every SaaS platform or managed service, there may be multiple dependencies including hosting services, API integrations, and data analytics platforms, all of which contribute to the delivery of a critical function.
Understanding the Regulation’s Intent
DORA emphasizes three principles when it comes to supply chain management:
End-to-End Visibility: Financial entities must map out their ICT dependencies beyond primary providers.
Proportional Oversight: The level of scrutiny should match the criticality of the service delivered.
Risk Attribution: Even when services are outsourced, the regulated entity remains accountable.
This means identifying where essential functions rely on shared infrastructure, overlapping vendors, or subcontracted specialists. It also requires understanding the impact that failures at any of these levels could have on operations.
Organizations must also be prepared to demonstrate this visibility to regulators, including the ability to link each vendor and sub-provider to specific services, locations, and risk levels. Proactive documentation and readiness become essential.
Turning Oversight into Preparedness
Supply chain resilience is a strategic necessity. Without integrated oversight, organizations risk being blindsided by a failure that originated two or three layers removed from their direct contracts.
The challenge lies in mapping and maintaining an accurate picture of how services are delivered, especially in fast-evolving digital environments. Vendors may change their subcontractors, relocate infrastructure, or shift service models, any of which can introduce new risks.
Organizations must be able to:
Identify and monitor single points of failure
Proactively assess fourth-party risk
Align risk ratings with the criticality of services
Build response protocols that include subcontractor dependencies
Maintain an audit trail for all vendor-related changes and reviews
This allows for faster incident resolution and stronger assurance when reporting to regulators.
From Static Lists to Dynamic Ecosystems
Many institutions still manage third-party risk using outdated spreadsheets or fragmented systems. These tools provide a list of vendors, but they rarely show who supports whom, what services depend on what infrastructure, or how disruption in one area might ripple outward.
This lack of depth can lead to incomplete reporting, regulatory penalties, or operational blind spots. Worse, it undermines confidence in the institution’s overall resilience posture.
To address this, financial entities need a more integrated model:
Every provider should be tied to a function
Every subcontractor should be visible and mapped
Every risk should be documented with context
Changes in service delivery should be tracked and logged
This transformation helps compliance and procurement teams move from a passive stance to a proactive one. It also supports cross-functional collaboration, enabling legal, IT, and risk teams to work from the same source of truth.
Owning the Risk Starts with Knowing It
Under DORA, resilience is a shared goal, but the responsibility for it starts with the regulated financial entity. That means building transparency across your ICT landscape, especially in complex vendor ecosystems.
Financial institutions that embrace this responsibility and invest in continuous supply chain oversight will not only reduce their compliance burden, but also enhance their readiness to respond to disruptions.
By making multi-tier vendor risk part of your operational strategy, you can strengthen both compliance and resilience.