by Panagiota Lagou, ADACOM GRC Director
The Digital Operational Resilience Act (DORA) is a game-changer for financial institutions, creating a unified regulatory framework to ensure operational resilience in the face of evolving threats. While DORA sets a clear path for digital resilience, its implementation presents unique challenges for banking and financial services institutions (BFSI).
Every newly emerged initiative brings new challenges, and DORA is no exception. These are key challenges that every BFSI professional and security leader must prepare for to navigate their businesses securely and effectively and leverage DORA's advantages.
Information Security and Digital Resilience Governance
Governance is at the heart of DORA compliance. Effective governance frameworks must prioritize information security (IS) and digital resilience as board-level responsibilities. This goes beyond a compliance checklist to embedding resilience into the organization’s culture.
One of the primary challenges lies in ensuring strategic alignment between IS and digital resilience strategies and overarching business objectives. This alignment can become particularly complex in large organizations with extensive supply chains and varied operations.
Additionally, establishing accountability and oversight at leadership levels remains a persistent difficulty. Clear lines of accountability for digital resilience, often spread across various departments, require consistent coordination and communication to be effective.
To address these challenges, organizations should develop governance frameworks that integrate resilience metrics into enterprise risk management processes. Regular board-level training sessions on DORA obligations can ensure that leadership remains informed and proactive. Furthermore, leveraging tools that enable real-time reporting and monitoring of resilience metrics can provide the transparency needed to uphold accountability and oversight.
Ongoing Maintenance of IS and Digital Resilience Posture
Setting up controls is only the beginning. DORA emphasizes the need to continuously improve IS and digital resilience to adapt to a dynamic threat landscape.
Organizations frequently face resource constraints that hinder their ability to maintain and improve resilience postures over time. Allocating adequate resources, including personnel and technology, can be challenging, given competing priorities. Moreover, continuous monitoring and timely updates to resilience controls demand specialized expertise and robust tools, often in short supply.
Automation can play a critical role in alleviating these challenges. Implementing advanced threat intelligence platforms can streamline monitoring processes and reduce the burden on human resources. Embedding resilience into organizational workflows—through periodic updates, simulations, and exercises—fosters a culture of preparedness and adaptability. For organizations facing significant resource constraints, outsourcing periodic assessments to trusted partners specializing in resilience audits can provide a viable alternative.
Expertise and Workload Management
The expertise required to support DORA's compliance internally, combined with the additional workload, can stretch even the most robust teams, creating a significant bottleneck that businesses shall address. The shortage of skilled IS and resilience management professionals presents a significant hurdle. As the demand for expertise outpaces supply, organizations may struggle to recruit and retain qualified talent. Concurrently, the added workload from compliance efforts risks overburdening existing teams, leading to burnout and a potential increase in errors that could compromise resilience.
Organizations can invest in upskilling their workforce to address talent shortages with targeted training programs focusing on DORA requirements. Leveraging managed services can supplement internal teams by providing specialized expertise as needed.
Finally, implementing a strategic workforce plan that balances internal capabilities with external resources ensures workloads are distributed effectively, reducing the risk of burnout.
Threat Led Penetration Testing (TLPT)
DORA mandates advanced methodologies for conducting Threat Led Penetration Testing (TLPT), a critical compliance requirement for BFSI entities.
Simulating real-world advanced threats through TLPT requires high expertise and access to sophisticated tools. Organizations may find it challenging to effectively replicate real-world attacks' complexity and unpredictability. Furthermore, TLPT is resource-intensive and demands meticulous planning to ensure minimal disruption to ongoing operations, which adds to its complexity.
Partnering with cybersecurity providers experienced in TLPT effectively ensures that simulations are tailored to an organization's unique threat landscape. Establishing a clear TLPT roadmap aligned with organizational risk assessments and compliance milestones helps streamline the process. Integrating insights from TLPT into broader risk mitigation strategies ensures that the findings drive meaningful improvements to the resilience posture.
Management of ICT Providers
DORA introduces stringent requirements for managing ICT critical providers and ensuring robust exit strategies. This is crucial for minimizing operational disruptions in the event of provider failures.
Managing contracts with ICT providers to include compliance clauses and exit strategies can be highly complex, particularly for organizations with numerous or global vendors. Enforcing these contracts—ensuring providers adhere to agreed-upon resilience and compliance standards—often requires expertise that many organizations lack. Moreover, crafting and implementing effective exit strategies can be daunting, given the need to address factors such as data migration and service continuity.
Organizations should conduct thorough due diligence when selecting ICT providers, focusing on their DORA readiness and operational resilience capabilities. Developing standardized exit strategy templates can simplify the process and address key considerations, such as liability and continuity planning. Monitoring providers' adherence to resilience standards through audits and performance reviews ensures that contractual obligations are met and compliance is maintained.
Ensure Seamless DORA Compliance with ADACOM
Navigating DORA compliance challenges requires a trusted partner with expertise in IS, resilience, and regulatory framework. ADACOM offers comprehensive governance and consulting solutions tailored to BFSI needs:
- Governance Framework Development: Deploy robust governance frameworks tailored to the organization’s needs and risk environment, prioritizing digital resilience across all operations layers.
- Resilience Support: Managed security services provide continuous support to monitor, maintain, and improve resilience posture and assist BFSI enterprises in responding to a changing threat landscape with proactive threat information, updates, and real-time analytics.
- Workforce Augmentation: Customized training programs and outsourced expertise to meet DORA regulations and equip teams with the necessary skills.
- TLPT Services: Threat-led penetration testing services to replicate real-world attacks using modern approaches, help teams identify and mitigate vulnerabilities, and improve security according to DORA's strict criteria.
- ICT Provider Management: Assistance in contract negotiations, exit strategy planning, and provision of ongoing monitoring to ensure compliance.
DORA is an opportunity to enhance your organization's resilience and build stakeholder trust. Partnering with ADACOM ensures you meet DORA requirements and gain a competitive edge in operational resilience.
Contact us today at: https://www.adacom.com/contact-us to learn how we can support your journey toward seamless DORA compliance.