DORA Compliance for Financial Institutions
Consulting and implementation of the EU regulation on digital operational resilience in the financial sector. ICT risk management, TLPT, third-party register.
What is DORA and why does it matter now?
DORA (Digital Operational Resilience Act, Regulation EU 2022/2554) is the EU regulation on digital operational resilience in the financial sector. It has been applicable since January 17, 2025, across all EU member states and requires financial entities and their ICT third-party service providers to implement comprehensive ICT risk management. The regulation creates a unified framework for digital operational resilience covering over 20 categories of financial entities.
KO‑MO‑TEL GmbH has been supporting financial enterprises with IT services since 1994. As an ICT third-party service provider under Art. 3 No. 19 DORA, we have been meeting the requirements since January 2025 and guide our clients through all phases of implementation.
Who needs to comply with DORA?
DORA applies to two major groups: regulated financial entities and their ICT third-party service providers. The scope is intentionally broad to ensure comprehensive protection of financial stability.
Financial Entities (Art. 2 DORA)
Credit institutions (banks), insurance companies, investment firms, payment service providers, e-money institutions, crypto-asset service providers, fund management companies, and central securities depositories – over 20 categories in total.
ICT Third-Party Providers (Art. 3 No. 19)
Cloud providers for the financial sector, IT service providers with critical functions (like KO‑MO‑TEL), SaaS providers, and data center operators. DORA applies regardless of location when services are provided to EU financial entities.
The 5 Pillars of DORA
DORA defines five core requirement areas for digital operational resilience in the financial sector. Each pillar addresses a specific aspect of ICT security.
ICT Risk Management
Comprehensive governance structures for identification, protection, detection, response, and recovery from ICT-related incidents. Documentation of all ICT systems and processes, business continuity planning with defined RTO and RPO.
ICT Incident Reporting
Structured classification and reporting of major ICT incidents. Reporting deadlines: initial notification within 4 hours, intermediate report 72 hours, final report 1 month. Reporting to competent authorities (BaFin in Germany).
Digital Resilience Testing
Regular testing of digital operational resilience. TLPT (Threat-Led Penetration Testing) for critical entities, vulnerability assessments, and scenario-based testing. Annual penetration tests following OWASP Top 10 and SANS Top 25.
ICT Third-Party Risk
Registration of all critical ICT third-party providers, contractual minimum requirements (audit rights, exit strategies, SLA), concentration risk monitoring. ICT third-party register to be submitted to authorities by March 31, 2026.
Information Sharing
Participation in cyber threat intelligence sharing and industry-wide collaboration. Voluntary exchange of threat information between financial entities to strengthen collective resilience.
Our DORA Consulting Services
KO‑MO‑TEL supports you in all aspects of DORA compliance – from the initial gap analysis to continuous maintenance of requirements.
DORA Gap Assessment
Assessment of your current ICT landscape against DORA requirements (Art. 6-45). Prioritization of action items and development of a roadmap with timeline and budget. Duration: 2-4 weeks.
ICT Risk Management Framework
Implementation of a DORA-compliant risk management framework. Integration with existing ISMS (e.g., ISO 27001), policy development, business impact analyses, and disaster recovery plans. Duration: 3-6 months.
ICT Third-Party Management
Inventory of all ICT third-party providers, risk assessment and classification, contract review and adaptation (audit clauses, exit strategies), and building the ICT third-party register per Art. 28. Duration: 2-4 months.
Incident Response Processes
Definition of ICT incident categories, implementation of incident management processes, technical tools (SIEM, logging, alerting), team training, and tabletop exercises. Integration with BaFin reporting. Duration: 2-3 months.
TLPT - Penetration Testing
Planning and scoping per DORA Art. 26, threat intelligence analysis, red team tests by certified pentesters (OSCP, CEH, GPEN), reporting and remediation planning.
Continuous Compliance
Regular reviews (quarterly or semi-annually), adjustments for regulatory changes, training and awareness measures, audit support for internal and external audits.
Penalties for Non-Compliance
DORA provides for significant sanctions in case of violations. BaFin has announced strict oversight of DORA compliance from 2025 onwards.
EUR 10M
Maximum fine
2%
Or percentage of turnover
Yes
Personal liability
Possible
Operational restrictions
BaFin has announced strict oversight of DORA compliance from 2025 onwards. Fines of up to 10 million euros or 2% of global annual turnover may apply. Board members can be held personally liable. Act now.
Why KO‑MO‑TEL for DORA Compliance?
30+ Years Financial Sector Expertise
Since 1994, we have served IT projects for banks, savings banks, insurance companies, and payment service providers. We understand BaFin requirements and regulatory complexity.
Technical Depth
Certified cybersecurity experts (CISSP, CEH, OSCP), penetration testing and TLPT experience, SIEM/SOC implementations, and cloud security expertise (Azure, AWS, GCP).
Holistic Approach
Integration of DORA with ISO 27001, NIS2, BaIT/VAIT. One point of contact for compliance, implementation, and operations. Leverage synergies instead of duplicating work.
Regional Presence
Based in Munich – on-site when needed. Personal contact and fast response times. Familiar with the Bavarian mid-market.
DORA-Compliant Contracts Since 2025
We have implemented DORA-compliant contract clauses for all financial enterprise clients since January 2025: SLA (99.5% availability), audit rights, exit strategies, incident reporting.
Transparent Pricing
Smaller institutions: EUR 50,000-150,000 (gap analysis + basic implementation). Medium to large institutions: EUR 200,000-1,000,000+ (full implementation incl. TLPT). Custom quote after initial consultation.
Frequently Asked Questions about DORA
Réidh don chéad chéim eile?
Faighimis amach le chéile conas is féidir linn do TF a chur chun cinn.