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
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:
- ICT Risk Management (Chapter II)
- ICT Incident Management (Chapter III)
- Resilience Testing (Chapter IV)
- ICT Third-Party Management (Chapter V)
- Information Sharing (Chapter VI)
Implementation by Pillar
Maturity Evolution
| Pillar | Initial | Final | DORA Target |
|---|---|---|---|
| ICT Risk Management | 52% | 94% | 90% |
| Incident Management | 48% | 92% | 90% |
| Resilience Testing | 23% | 85% | 80% |
| Third-Party Management | 34% | 88% | 85% |
| Information Sharing | 12% | 78% | 75% |
| Global | 45% | 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