regulation

DORA

ICT resilience for finance, applying directly since 17 January 2025. If you sell software to a bank, it arrives on your desk as contract terms.

last checked 2 November 2026not legal advice
what it is
A regulation. It applies directly, with no national act in between.
who it covers
20 types of financial entity, plus their ICT third-party providers.
the size line
None for coming into scope. The work scales with size and risk.
fine ceilings
No EU figure. Member states set them.
who answers
The management body bears ultimate responsibility for ICT risk.
status
Applying. A proposal would change how incidents are filed, and is still in committee.

basis DORA Art. 2(1), 4(1), 5(2), 50(3), 64

01

two ways in

You are a financial entity. Banks, payment and e-money institutions, investment firms, insurers and intermediaries, crypto-asset service providers, fund managers and others. A few very small schemes are excluded, so read the list before you assume.

You sell ICT services to one. For a software company this usually arrives as contract changes from a bank customer, because the regulation lists what those contracts must contain.

how DORA reaches a software company

financial entitykeeps a register of all ICT contracts and stays fully responsible
  • mandatory contract terms
  • locations, data return, security
  • help in an incident
ICT provideryou, if you sell software or IT to finance
  • conditions on subcontracting
subcontractorallowed only on the terms the contract sets

basis DORA Art. 2(1), 28(1), 28(3), 30(2)

Finance sits in NIS2 too, but NIS2 steps aside where a sector law is at least equivalent, and DORA is that law for the entities it covers.

basis DORA Art. 2(1), 2(3), 30(2); NIS2 Art. 4(1)

02

what it asks for

Five groups of duty: a documented ICT risk framework with an asset inventory; incident classification and three stages of reporting; a resilience testing programme, unless you are a microenterprise; a register of all ICT contracts with mandatory terms; and a management body that defines, approves, funds and oversees all of it.

The reporting clocks are the tightest on this site.

one event, three clocks

4 hours24 hours72 hours1 month
NIS2
early warning, from becoming aware of a significant incident
incident notification with a first assessment
final report, one month after the notification
DORA
initial notification, 4 hours after classifying as major
that same notification, 24 hours after awareness at the latest
intermediate report, 72 hours after the initial one
final report, one month after the last intermediate
GDPR
tell the authority, where feasible, unless a risk to people is unlikely
The clocks start at different moments and go to different authorities. GDPR also asks you to tell the people affected without undue delay when the risk to them is high. Poland counts the NIS2 hours from detecting the incident.

basis NIS2 Art. 23(4); RTS 2025/301 Art. 5(1); GDPR Art. 33(1), 34(1); KSC Art. 11

basis DORA Art. 5(2), 6(1), 8(1), 17(1), 19(1), 24(1), 28(3), 30(2)

03

where small firms get room

Proportionality is the rule across the risk management chapter. A named set of firms, including small and non-interconnected investment firms and exempted payment and e-money institutions, get a simplified framework. Check you are on the list before relying on it. Your supervisor reads this with you, and it is worth asking early.

basis DORA Art. 4(1), 16(1)

04

where it overlaps

Most of this is the work NIS2 and GDPR ask for: the map shows it row by row. One breach of ICT systems holding personal data can start the DORA clock and the GDPR clock from the same event.

basis DORA Art. 19(1); GDPR Art. 33(1)

05

what may change

The Digital Omnibus, proposed in November 2025, lists DORA among the acts it would amend, mainly around where incidents are reported. It awaits a committee decision in Parliament, and your duty to report has not changed.

basis procedure 2025/0360(COD)

the work under DORA

check it yourself

fyi Last checked 2 November 2026. This is not legal advice. It is a plain reading of the texts listed on this page, and national law can add to them. Before you rely on it in front of a regulator, an auditor or your board, have a lawyer confirm it for your company. What this means.

your next step

Open your list of ICT contracts and mark which ones support a critical or important function.