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We supply banks, does DORA hit us?

DORA has applied since 17 January 2025. It targets financial entities, but via the critical ICT third-party regime and contract terms it cascades to suppliers.

Try this first

  1. 1Confirm whether your customer is a financial entity under DORA: bank, insurer, investment firm, payment institution, credit institution. Then DORA reaches you contractually.
  2. 2Expect contract updates: incident reporting within fixed windows, supervisor audit rights, exit strategy, transfer requirements.
  3. 3Build incident detection and logging at a level where you can produce facts in hours, not days. SLA reporting alone is too slow.
  4. 4Document concentration risk. If you use sub-suppliers for core function, your customer needs to know.
  5. 5Keep test evidence. Pen tests, scenario tests, business-continuity drills will be requested.

When to bring us in

Designated as a "critical ICT third party" by the ESAs? You are directly supervised. Different game; bring in legal and compliance specialists.

See also

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