Compliance 2024 Spanish Financial Institution

EBA/DORA Validation for Financial Institution

Validation and compliance process with EBA guidelines on ICT risk management and preparation for DORA Digital Operational Resilience regulation.

Category

Compliance

Year

2024

Team size

5 people

Timeline

10 months

project.preview
DORA compliance dashboard with operational resilience indicators

Challenge

With DORA coming into force in January 2025, the financial institution needed to assess its compliance level with EBA guidelines on ICT risks and prepare for the stricter requirements of the new European regulation. The gap was significant: only 45% of requirements covered.

Solution

Exhaustive assessment of current compliance status, identification of critical gaps and development of prioritized compliance roadmap. Implementation of controls for ICT risk management, incident management, resilience testing and ICT third-party provider management.

Regulatory Context: EBA and DORA

The New Digital Resilience Framework

The European financial sector faces significant regulatory transformation in technology risk matters. DORA (Digital Operational Resilience Act) establishes a harmonized framework that goes beyond previous EBA guidelines.

Key DORA Requirements

5 Fundamental Pillars:

  1. ICT Risk Management (Chapter II)
  2. ICT Incident Management (Chapter III)
  3. Resilience Testing (Chapter IV)
  4. ICT Third-Party Management (Chapter V)
  5. Information Sharing (Chapter VI)

Implementation by Pillar

Maturity Evolution

PillarInitialFinalDORA Target
ICT Risk Management52%94%90%
Incident Management48%92%90%
Resilience Testing23%85%80%
Third-Party Management34%88%85%
Information Sharing12%78%75%
Global45%87%85%

ICT Third-Party Management

Provider Classification:

provider_classification:
  critical:
    criteria:
      - supports_critical_functions: true
      - difficult_substitution: true
      - high_operational_impact: true
    controls:
      - enhanced_due_diligence
      - annual_audits
      - detailed_exit_plans
      - continuous_monitoring

  important:
    criteria:
      - supports_important_functions: true
    controls:
      - standard_due_diligence
      - periodic_reviews
      - contingency_plans

Updated Contracts:

  • 34 contracts with DORA clauses
  • Audit rights included
  • Documented exit plans
  • Formalized security SLAs

Project Results

Tangible Benefits

Risk Reduction:

  • Residual ICT risk: -45%
  • Detection time: -67%
  • Response time: -58%
  • High-risk third parties: -67%

Operational Efficiency:

  • Automated processes: +340%
  • Manual reporting eliminated: 90%
  • Eliminated duplications: 23 processes

This project positioned the institution not just to comply with DORA, but to turn digital operational resilience into a competitive advantage, demonstrating to customers and regulators its commitment to security and service continuity.

Results

  • EBA ICT Guidelines compliance: 94% (from 45% initial)
  • DORA readiness: 87% before deadline
  • 67% reduction in identified ICT third-party risks
  • Resilience testing framework implemented
  • 0 critical findings in supervisory review

Technologies

🔧 GRC Platform
☁️ Azure
🔧 BCP/DRP
🔧 Third-Party Risk
🔧 Incident Management

Project Information

Category Compliance
Year 2024
Client Spanish Financial Institution
Timeline 10 months
Team size 5 people