Fast-Track Your Cyber Resilience: Power Moves Towards DORA Compliance

Analysis

• Managing ICT risks
• Responding to incidents
• Testing operational resilience
• Overseeing third-party dependencies and
• Meeting regulatory requirements.

Figure 2: DORA Pillars for Compliance

1. Secure Executive Sponsorship:
   It is critical that senior executives and the board understand and prioritize operational resilience. Draft and deliver regular, targeted briefings that clearly articulate the strategic business risks, operational, regulatory implications, and financial impact of resilience failures. Communicate the benefits of a cyber resilience program and include elements such as enabling the continued delivery of the corporate objectives and revenue-generating activities. Advocate for resilience as a strategic priority, not a one-time compliance project that is run as a program similar to existing Cybersecurity or Privacy programs with executive buy-in.
2. Form a Cross-Functional Resilience Team:
   DORA’s requirements span multiple functions: IT, cybersecurity, enterprise risk management, procurement, legal and compliance, and business operations. Gartner sees that overarching Organizational resilience should ideally be owned by the CRO, Chief Risk Officer, or CFO Chief Financial Officer as the Executive Sponsor. Overarching organizational resilience should therefore be sponsored at the executive level by the Chief Risk Officer (CRO) or Chief Financial Officer (CFO). Organizations should establish a cross-functional resilience team with clear mandates and representation from all relevant risk areas. This team must be empowered to drive integrated decision making and ensure accountability for resilience outcomes, but also bring the various risk areas together. Gartner has observed that where this has been done successfully, organizations have established a transformational resilience team to drive not only DORA compliance but also Operational Resilience. (Figure 3) DORA or Resilience is not the sole responsibility of the Cybersecurity leader or IT. However, they would feed into the requirements for compliance within the scope of their functional services.
3. Define and Communicate Roles and Responsibilities:
   A RASCI for DORA needs to be developed, even if a cross-functional team or transformational team cannot be created. Cybersecurity leaders should develop and implement a DORA-specific RASCI matrix to avoid fragmented or siloed risk management. This tool should clarify who is responsible, accountable, supporting, consulted, and informed for every aspect of resilience, ensuring transparency and collaboration across the organization. Gartner clients can leverage the Gartner RASCI tool and customize it to meet DORA Requirements: Tool: Cybersecurity Program RASCI Matrix.

Figure 3: DORA/Resilience Needs to Be a Program, Not a Project

1. Conduct a Gap Assessment Against DORA Requirements:
   Begin by mapping existing documentation, such as risk management policies, cybersecurity policies, incident response plans, business continuity, and disaster recovery frameworks, against DORA’s specific mandates. Identify gaps, particularly around new artifacts like the DORA Strategy, ICT Risk Management Framework, Register of Information, and ICT Reference Architecture. If you align with an industry-recognised framework such as ISO 27001:2022 or NIST CSF 2.0, a lot of the policies and standards under the ICT Risk Management, Incident Management, and Third Party Risk pillars should already be in existence and may only require cross-checking and light updates.
2. Update Information Register and reporting of Incidents: Proactively lead the update of the Information Register by coordinating with Legal, Compliance, and Enterprise Risk Management teams. Ensure all required data is accurately captured and ready for timely submission to regulators. In the event of a security incident, take ownership of providing complete, DORA-compliant reporting to the designated European Supervisory Authority (ESA). If you are not responsible for submitting the report, ensure you deliver all necessary information promptly to the report owner to maintain regulatory compliance.
3. Enhance Existing Documentation Rather Than Create From Scratch:
   Where gaps exist, update and expand current documents to address DORA’s requirements. Avoid creating stand-alone documents solely for audit purposes; instead, integrate DORA expectations into existing governance and operational processes to ensure ongoing compliance and operational value.
4. Establish Clear Ownership and Accountability:
   Ensure that the relevant teams or individuals are assigned responsibility for each required artifact or framework. Ensure that updates and maintenance are part of routine governance, not ad hoc compliance exercises. If required, escalate accordingly to ensure accountability and responsibility are taken. This is where a RASCI outlined in the previous section will really support governance.
5. Regularly Review and Validate Documentation:
   Implement a schedule for periodic review and validation of all DORA-related documents. This ensures that documentation remains current, actionable, and aligned with evolving regulatory expectations.

1. Evaluate and Deploy Cyber and GRC Management Platforms:
   Cybersecurity leaders should assess solutions that offer continuous risk assessment and real-time vulnerability monitoring. Before considering going to the external market, assess current tools and platforms and work with ERM to understand if there is existing technology that they are using that can be leveraged. Current integrated asset inventory or risk management platforms may provide additional modules with integration capabilities. Platforms with built-in automation capabilities can provide holistic visibility across IT, business operations, and third-party dependencies, supporting compliance and resilience objectives. Cybersecurity leaders could consider technologies from a Cyber and GRC Perspective:

2. Automate Incident Reporting and Response Workflows:
   Implement tools that enable automated incident detection, reporting, and escalation. This reduces manual intervention, accelerates response times, and ensures consistent regulatory reporting requirements.
3. Enable Seamless Integration With IT Service Management (ITSM):
   Select platforms that integrate natively with existing ITSM systems, allowing for streamlined workflows, centralized data management, and enhanced collaboration between cybersecurity, IT operations, and business stakeholders. Cybersecurity leaders could consider How to Integrate Cybersecurity in Your ITSM Practice.
4. Establish Real-Time Dashboards for Executive and Board Oversight:
   Provide senior leadership and key stakeholders with real-time dashboards that visualize risk posture, incident status, and compliance metrics. This will facilitate informed decision making and foster a culture of resilience and accountability.
5. Regularly Test and Validate Monitoring Capabilities:
   Schedule routine assessments to ensure monitoring tools and processes are functioning as intended. Validate that visibility extends to all critical business functions and that automated reporting mechanisms align with DORA requirements.