The Illusion of Compliance

The Digital Operational Resilience Act (DORA) is a game-changer for financial institutions operating in the EU. It demands a heightened focus on ICT risk management, incident reporting, and third-party risk oversight. Yet, many enterprises are fixated on compliance rather than resilience. Regulatory adherence does not guarantee security as DORA sets the floor, not the ceiling. Organisations that mistake compliance for true operational resilience risk severe disruptions when real crisises emerge.

Firms rushing to meet regulatory deadlines often implement check-the-box measures, overlooking long-term resilience strategies. The regulatory framework provides structure, but the responsibility of building sustainable cyber resilience rests with the enterprise. Those who focus solely on avoiding fines are setting themselves up for failure in the face of evolving threats.

The Complexity of Third-Party Risk Management

DORA’s stringent requirements around third-party ICT providers introduce a critical challenge: true risk visibility. Modern enterprises rely on a web of vendors, cloud providers, and SaaS platforms, yet most fail to account for deep dependencies beyond direct suppliers. 3rd party risks are often overlooked, creating blind spots in resilience planning.

Without clear remediation frameworks, organiaations may find themselves in a blame game when an upstream provider suffers an outage. Holding suppliers accountable requires more than contractual obligations, it demands continuous oversight, real-time risk monitoring, and the ability to pivot when a critical provider fails to meet security expectations.

Incident Reporting: The Double-Edged Sword

DORA enforces strict timelines for reporting ICT-related incidents, bringing much-needed transparency to the financial sector. However, rushed reporting can lead to incomplete disclosures, reputational damage, and potential legal exposure. Many firms lack the forensic capabilities to diagnose incidents within the mandated timeframe, leading to premature or misleading reports that fail to capture the full extent of the breach.

The obligation to report must be met with investments in real-time incident detection and response. Security teams must go beyond compliance checklists and build forensic capabilities that allow them to report accurately and mitigate risks before they escalate. Reporting an incident should not be the end of a process it must be the start of a comprehensive resilience response.

Testing for Resilience or Just Checking a Box?

Cyber resilience testing is at the core of DORA, requiring enterprises to validate their ability to withstand operational disruptions. Yet, many organisations approach testing as a compliance exercise rather than a means to uncover real vulnerabilities. Pre-scripted penetration tests and surface-level audits do little to prepare for actual cyber threats.

Effective resilience testing must go beyond simple pass/fail exercises. It should challenge real-world response capabilities, simulate cross-border disruptions, and assess how internal teams respond under pressure. Organisations that invest in adaptive testing strategies will be prepared for emerging threats, while those treating resilience testing as a formality will be caught off guard in moments of crisis.

Rethinking Resilience Beyond Compliance

DORA is not just another regulation - it is a catalyst for transformation. Enterprises that embrace resilience-first thinking will outpace those that focus on minimum compliance requirements. Investing in security talent, real-time risk intelligence, and continuous adaptation to evolving threats will separate those who truly understand resilience from those who merely follow regulations.

Those who treat DORA as an opportunity to fortify their operational foundations will gain a competitive advantage. In a landscape where digital disruptions are inevitable, survival depends not on meeting compliance deadlines, but on building an adaptive, robust security culture that can withstand the unexpected.