DORA Compliance Policy (EU Digital Operational Resilience Act)
A policy ensuring compliance with the EU Digital Operational Resilience Act (DORA), which mandates ICT risk management, incident reporting, digital operational resilience testing, and third-party ICT provider oversight for financial sector entities.
What is a DORA Compliance Policy (EU Digital Operational Resilience Act)?
A policy ensuring compliance with the EU Digital Operational Resilience Act (DORA), which mandates ICT risk management, incident reporting, digital operational resilience testing, and third-party ICT provider oversight for financial sector entities.
Regulators across EU treat a DORA Compliance Policy (EU Digital Operational Resilience Act) as a baseline legal requirement. Without one, your business is immediately exposed to enforcement action — regardless of size or industry.
Who Needs a DORA Compliance Policy (EU Digital Operational Resilience Act)?
Banks, insurance companies, investment firms, payment institutions, crypto-asset service providers, and their critical ICT third-party providers operating in the EU.
- Any organisation that banks, insurance companies, investment firms, payment institutions, crypto-asset service providers, and their critical ict third-party providers operating in the eu
- Businesses operating in EU
- Anyone using third-party services that process data on your behalf
Legal Framework
Regulation (EU) 2022/2554 (DORA); applicable from 17 January 2025; ESA joint guidelines and RTS/ITS.
EU
EU GDPR — up to €20M or 4% turnover
What Your DORA Compliance Policy (EU Digital Operational Resilience Act) Must Include
- 1
ICT Risk Management Framework
ICT Risk Management Framework — Clearly define ict risk management framework so users and regulators understand its scope and why it matters for your compliance obligations.
- 2
ICT-Related Incident Classification & Reporting
ICT-Related Incident Classification & Reporting — Clearly define ict-related incident classification & reporting so users and regulators understand its scope and why it matters for your compliance obligations.
- 3
Digital Operational Resilience Testing (TLPT)
Digital Operational Resilience Testing (TLPT) — Clearly define digital operational resilience testing (tlpt) so users and regulators understand its scope and why it matters for your compliance obligations.
- 4
Third-Party ICT Provider Risk Management
Third-Party ICT Provider Risk Management — Clearly define third-party ict provider risk management so users and regulators understand its scope and why it matters for your compliance obligations.
- 5
Critical ICT Provider Register
Critical ICT Provider Register — Clearly define critical ict provider register so users and regulators understand its scope and why it matters for your compliance obligations.
- 6
Contractual Requirements with ICT Providers
Contractual Requirements with ICT Providers — Clearly define contractual requirements with ict providers so users and regulators understand its scope and why it matters for your compliance obligations.
- 7
Information Sharing on Cyber Threats
Information Sharing on Cyber Threats — Clearly define information sharing on cyber threats so users and regulators understand its scope and why it matters for your compliance obligations.
- 8
Business Continuity & Disaster Recovery
Business Continuity & Disaster Recovery — Clearly define business continuity & disaster recovery so users and regulators understand its scope and why it matters for your compliance obligations.
- 9
Governance & Board Oversight
Governance & Board Oversight — Clearly define governance & board oversight so users and regulators understand its scope and why it matters for your compliance obligations.
How to Write a DORA Compliance Policy (EU Digital Operational Resilience Act)
Building a compliant DORA Compliance Policy (EU Digital Operational Resilience Act) from scratch takes legal expertise and hours of research. Here is a framework covering the core steps:
- 1Step 1: ICT Risk Management Framework — Document this section completely and accurately. Vague or incomplete disclosures can be treated as violations even if the underlying practice is compliant.
- 2Step 2: ICT-Related Incident Classification & Reporting — Document this section completely and accurately. Vague or incomplete disclosures can be treated as violations even if the underlying practice is compliant.
- 3Step 3: Digital Operational Resilience Testing (TLPT) — Document this section completely and accurately. Vague or incomplete disclosures can be treated as violations even if the underlying practice is compliant.
- 4Step 4: Third-Party ICT Provider Risk Management — Document this section completely and accurately. Vague or incomplete disclosures can be treated as violations even if the underlying practice is compliant.
- 5Step 5: Critical ICT Provider Register — Document this section completely and accurately. Vague or incomplete disclosures can be treated as violations even if the underlying practice is compliant.
- 6Step 6: Contractual Requirements with ICT Providers — Document this section completely and accurately. Vague or incomplete disclosures can be treated as violations even if the underlying practice is compliant.
- 7Final step: Legal review — Review with qualified legal counsel before publishing, especially if operating in high-risk jurisdictions.
Common Mistakes to Avoid
Copying another website's DORA Compliance Policy (EU Digital Operational Resilience Act) verbatim — Every business has different data flows. A generic copy may fail to disclose what you actually do, creating false statements that are worse than no policy at all.
Using vague or ambiguous language — Regulators and courts expect plain, specific language. Phrases like "we may share your data with partners" are too vague and regularly cited in enforcement actions.
Forgetting to update after product changes — Your DORA Compliance Policy (EU Digital Operational Resilience Act) must reflect current practice. Outdated policies are a compliance liability — some regulators treat an outdated policy as a violation in itself.
Not making your DORA Compliance Policy (EU Digital Operational Resilience Act) easy to find — Buried in a footer or behind multiple clicks, your policy may not meet the "easily accessible" standard required by most regulations.
Missing jurisdiction-specific requirements — A policy compliant in one jurisdiction may still fail in another. If you operate across EU, you need to address each framework's specific requirements.
How Often Should You Update Your DORA Compliance Policy (EU Digital Operational Resilience Act)?
At minimum, review your DORA Compliance Policy (EU Digital Operational Resilience Act) once a year — and immediately whenever you: change the data you collect, add new third-party tools, enter new jurisdictions, or experience a data incident.
Consequences of Non-Compliance
Beyond financial penalties, non-compliance with DORA Compliance Policy (EU Digital Operational Resilience Act) requirements can result in: reputational damage and loss of customer trust, app store removal (for mobile apps), inability to process payments (for ecommerce), and difficulty attracting enterprise customers who require compliance evidence.
Frequently Asked Questions
Is a DORA Compliance Policy (EU Digital Operational Resilience Act) legally required?
Yes. A DORA Compliance Policy (EU Digital Operational Resilience Act) is a legal requirement under Regulation (EU) 2022/2554 (DORA); applicable from 17 January 2025; ESA joint guidelines and RTS/ITS.. Operating without one puts your business at risk of regulatory enforcement action.
How long should a DORA Compliance Policy (EU Digital Operational Resilience Act) be?
A typical DORA Compliance Policy (EU Digital Operational Resilience Act) runs 10 pages. Length matters less than completeness — every required disclosure must be present, written in plain language that users can understand.
How often should I update my DORA Compliance Policy (EU Digital Operational Resilience Act)?
At minimum, review your DORA Compliance Policy (EU Digital Operational Resilience Act) once a year — and immediately after any business change.
What are the penalties for not having a DORA Compliance Policy (EU Digital Operational Resilience Act)?
National competent authority fines; periodic penalty payments of up to 1% of average daily worldwide turnover for ongoing breaches.
Can I use a free DORA Compliance Policy (EU Digital Operational Resilience Act) template?
Free templates are a starting point, not a solution. A template that was not drafted for your specific business, jurisdiction, and data practices may create false statements — which is legally worse than having no policy at all. Always customise any template and have it reviewed by qualified counsel.
Related Policies
GDPR Compliance Policy
A comprehensive internal and external framework documenting how your organisatio…
Read guide 💬Community Guidelines
The behavioral standards for users in social or collaborative spaces, focusing o…
Read guide 📣Forum Rules
Highly specific technical and behavioral rules for message boards and bulletin b…
Read guide 🔗Affiliate Disclosure
A legally required statement disclosing that you may earn a commission when read…
Read guidePolicifyAI is a technology provider, not a law firm. The information on this page is for orientation only and is not legal advice. Generated templates are intended as a structured starting point for review by qualified counsel before publication.