Six months into the Digital Operational Resilience Act (DORA), financial institutions discovered that building resilience isn’t just about ticking regulatory boxes—it’s about driving organizational transformation. The regulation is reshaping how firms manage ICT risks, strengthen operational risk management, respond to incidents, and oversee third-party providers, making resilience a strategic priority rather than a compliance exercise.
For CISOs, risk officers, and governance professionals, this moment marks a turning point. Governance is no longer a background function—it is the backbone of digital resilience. For many, achieving regulatory compliance in banking now depends on how governance structures adapt. This blog explores why governance has taken centre stage under DORA and how institutions can adapt their strategies to not only comply but thrive in the new resilience-driven era.
Why Governance Has Taken Center Stage
Governance has rapidly become the cornerstone of digital resilience under DORA. The regulation requires financial institutions to establish robust oversight across five key pillars—ICT risk management, incident reporting requirements, resilience testing frameworks such as threat-led penetration testing (TLPT), third-party risk, and threat intelligence sharing—placing governance at the heart of compliance and operational resilience (EIOPA).
At the same time, the burden of implementation is significant: studies reveal that nearly half of financial institutions are investing over €1 million in compliance efforts, while 79% of employees report higher stress levels tied to these cyber resilience mandates (TechRadar). ogether, these pressures underscore why governance structures must evolve—not just to meet regulatory deadlines, but to sustain efficiency, morale, and long-term resilience.
How to Implement DORA Governance in Financial Institutions
DORA positions governance as the backbone of digital resilience, requiring institutions to strengthen oversight across these five domains:
-
-
ICT Risk Oversight
-
Governance ensures ICT risk frameworks are board-approved, regularly updated, and continuously monitored (digital-operational-resilience-act.com, ESMA).
-
-
Incident Reporting Accountability
-
Clear protocols, roles, and classification structures are essential to meet DORA’s strict incident reporting requirements (EIOPA).
-
-
Operational Resilience Testing (TLPT)
-
Governance guarantees that test simulations are executed, documented, reviewed, and followed by corrective actions (EIOPA).
-
-
Third-Party Vendor Oversight for DORA Compliance
-
Oversight includes vendor due diligence, contractual safeguards, and ongoing monitoring to reduce exposure from external providers (Skadden).
-
-
Information Sharing & Regulatory Coordination
-
Governance enables structured cyber threat intelligence exchange with regulators and peers, reinforcing collective defense (EIOPA).
Early Lessons—Six Months into DORA
Six months into enforcement, financial institutions have shifted from preparation to the day-to-day execution of DORA requirements. Organizations are reevaluating ICT risk frameworks, fine-tuning incident reporting protocols, and conducting TLPT drills to validate resilience under real-world conditions. What was once a compliance project has now become an operational routine, embedding cyber resilience in the financial sector into the fabric of services.
However, the journey comes with significant challenges. Compliance has proven costly, with firms investing millions in governance, technology, and training. At the same time, the heightened pace of reporting and oversight has placed pressure on employees, with many reporting elevated stress levels. These realities underline the importance of thoughtful governance—not only to meet European cybersecurity mandates but also to ensure that resilience strategies remain sustainable for both organizations and their people.
Key Governance Best Practices in the New Era
-
-
Embed Resilience into Governance Structures
-
Assign accountability at the board and executive level for resilience metrics, risk dashboards, and testing roadmaps.
-
-
Document and Automate Reporting Flows
-
Use automated workflows and dashboards to ensure incident reporting is accurate, consistent, and aligned with DORA timelines.
-
-
Formalize TLPT Governance
-
Track test execution, findings, remediation steps, and board-level reviews to turn TLPT into a structured governance process.
-
-
Strengthen Third-Party Oversight Governance
-
Establish formal governance of vendor risk through regular assessments, contract clauses, and ongoing monitoring dashboards.
-
-
Facilitate Intelligence Exchange
-
Implement structured governance for sharing cyber intelligence with regulators and peers, building readiness for expanded mandates like NIS2 compliance and the Cyber Resilience Act (CRA).
Governance Models to Consider
-
Resilience Governance Committee
- Comprises Risk, IT, Compliance, and Legal stakeholders.
- Centralizes decision-making and ensures consistent operationalization of DORA mandates.
- Provides a forum for cross-functional accountability and alignment.
-
Cyber Resilience Dashboard
- Tracks key metrics such as TLPT readiness, incident reporting uptime, third-party risk ratings, and stress test outcomes.
- Provides real-time visibility for boards and executives to make data-driven governance decisions.
- Enhances transparency and regulatory reporting accuracy.
-
Governance-Driven Training & Culture
- Aligns policies, awareness programs, and role-based training with resilience objectives.
- Reinforces a resilience-first culture, ensuring staff understand their responsibilities.
- Builds organizational readiness to adapt to evolving mandates like NIS2 and CRA.
Looking Ahead: Governance Meets Multi-Mandate Reality
-
-
Regulatory Convergence
-
DORA is only one part of the broader picture. Organizations must prepare for overlapping mandates such as NIS2 compliance, the Cyber Resilience Act (CRA), and wider EU financial regulations. This requires governance models that are scalable, adaptable, and harmonized across multiple European cybersecurity mandates.
-
-
AI & Automation Amplify Governance
-
Future-proof governance relies on automation and AI-driven tools, enabling continuous monitoring, automated alert orchestration, and proactive policy enforcement. These innovations help institutions shift from reactive compliance to proactive resilience, reducing both operational risks and compliance costs.
Conclusion
DORA has redefined governance from being a supporting function to becoming the strategic backbone of digital resilience. Institutions that proactively embed resilience into their governance structures—through accountability, automation, third-party oversight, and intelligence sharing—will not only achieve compliance but also strengthen trust, agility, and long-term competitiveness. The real opportunity lies in moving beyond a “check-the-box” approach and embracing governance as a driver of resilience, innovation, and growth.
How are you adapting your governance practices to meet DORA or similar mandates? Could a governance readiness assessment help kick-start your journey toward stronger resilience?
