DORA Regulation: Requirements, Implementation and Strategic Opportunities

DORA Regulation – what you definitely didn't know

Before you read on: In this article, you will not find out whether and, if so, to what extent you are affected by the DORA regulation and what you need to do to be able to tick all the compliance boxes. Here, we are dealing with the question of how you, as a controller, can use the DORA regulation for your company in the financial sector in order to gain real competitive advantages nationally and internationally, in addition to greater security against hacking attacks.

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To answer this question, we look at the legal framework of the DORA directive and, based on our many years of experience as a trusted hacking advisor, provide recommendations on how to implement these requirements not only correctly, but to your advantage. We take a closer look at the role of external service providers in the financial industry when it comes to security and address the often overlooked topic of industrial espionage.


Please read on if you want to turn the legally required measures of the DORA regulation from an annoying necessity into a real asset for the stability and growth of your company!

How the DORA Regulation Changes IT Security

The DORA Regulation (“Digital Operational Resilience Act”) is an EU regulation that came into force on January 15, 2025. Its aim is to strengthen the digital resilience of financial institutions and insurance companies in order to effectively deal with cyberattacks and IT failures. It affects companies along the entire value chain of the financial industry, including third-party providers. In addition to clear technical requirements such as penetration tests, it also focuses on organizational and strategic resilience:

  • Regular penetration tests: According to Article 24 of the DORA Regulation, companies must regularly carry out penetration tests to identify vulnerabilities in IT systems and ensure that they are remedied before potential attacks.
  • Threat-Led Penetration Testing (TLPT): According to Article 26 of the DORA Regulation, critical companies must conduct enhanced penetration tests at least every three years. These tests simulate realistic attack scenarios to uncover both technical vulnerabilities and organizational deficiencies and to test response capacity.
  • Risk management and emergency plans: Article 12 of the DORA Regulation requires companies to mitigate IT outages and cyberattacks with effective recovery plans and to ensure operational continuity.
  • Third-party management: Articles 28 to 31 of the DORA Regulation require financial institutions to monitor the security standards of their service providers and ensure that they comply with the requirements.
  • Awareness measures: Article 13 of the DORA Regulation requires companies to implement mandatory programmes to raise awareness of ICT security risks among employees and management. These programmes must be adapted to the respective areas of responsibility and must also include defence against social engineering attacks.

Collaboration with third parties: Auditing creates trust

An important part of the DORA requirements is the involvement of third parties such as externally managed Security Operations Centers (SOC) in security audits. Why is this crucial? Quite simply: you need to ensure that the services you are already paying for actually deliver what they promise. Our focus is on developing constructive solutions and not on exposing other service providers - it's about strengthening trust and optimizing security holistically.

If we know, for example, that a SOC is in place to detect cyber attacks at an early stage, our penetration testers initially proceed very cautiously with their simulated attacks. If these are not detected, they gradually carry out increasingly "louder" attacks and often find that these are not reliably detected either.

We have had similar experiences with surveillance cameras on company buildings: just because they are installed and running does not mean that the recordings are actually monitored and an alarm is triggered if unauthorized persons find a way into the building (for example, thanks to the door wedge on the back door for smoking breaks, which is notorious in our circles).

Our experience shows that everyone involved benefits from a well-prepared and well-followed penetration test. We bring third-party providers on board early on in our projects and support you in optimizing your collaboration through knowledge transfer and solution-oriented communication.

Whitepaper: Pentest vs. TLPT – What really suits your company?

DORA writes regular penetration testing to identify security gaps and minimize risks. But for some companies, the Threat-Led Penetration Testing (TLPT) in the game.

Does your company really need TLPT – or is a classic, practical penetration test the better choice?

In our white paper you will learn:

  • What DORA requires: For whom is TLPT mandatory? How does TLPT differ from classic pentests?
  • How does TLPT work? What are the steps involved in this formal regulated test and what results do you get?
  • Self-assessment checklist: Determine whether TLPT is necessary or whether a regular, realistic pentest is the right choice.

Read now how to make the right decision:

Behind the Scenes: Interpretation Gaps and Lack of Depth

Behind the scenes, it is clear that in practice, audits by regulatory authorities or associations often remain too superficial. A key reason is the lack of technical know-how, which means that requirements such as vulnerability scans are wrongly classified as penetration tests.

There are still significant gaps in interpretation when it comes to key terms such as “early reporting” or “holistic monitoring”. Experts estimate that it will take at least two years for these ambiguities to be fully clarified.

Especially the area Threat-Led Penetration Testing (TLPT) represents a specific challenge, as its relevance depends heavily on the size and complexity of the respective financial institution. Smaller banks in particular are faced with the question of whether the additional effort is justified compared to a classic penetration test or whether regulatory requirements entail an obligation.

Our recommendation: Don’t wait, act
Regardless of the existing ambiguities, we advise companies to take action early. The reason: cyber threats are evolving rapidly, and waiting for full clarification from regulators carries the risk of avoidable security gaps. The DORA regulation is ultimately only a formal response to very real threats.

A well-conducted penetration test – whether classic or TLPT – not only strengthens the security posture of your company, but also provides a solid basis for meeting future regulatory requirements without time pressure. As Trusted Hacking Advisors, we ensure that your tests are practical, future-proof and immediately implementable.

Cyberattacks and the relevance of the DORA regulation

The increasing frequency and complexity of cyberattacks shows how urgently regulatory measures such as DORA are needed:

  • More cyber attacks: In 2023, 3.348 cyber incidents were reported in the financial sector worldwide – an 83% increase compared to 2022.
  • Data leaks are becoming more frequent: Between November 2022 and October 2023, there were 1.115 confirmed data leak incidents, an increase of 133% over the previous year.
  • Europe in focus: In Europe alone, the financial sector recorded around 2023 cyber incidents between July 2024 and June 900, making it the third most targeted sector.
  • Main attack vectors: Malware accounted for 40% of all attacks, followed by network and anomaly attacks (23%) and system anomalies (20%).

These figures make it clear that the financial sector remains a prime target for cybercriminals. The sensitive data and the industry's central role in the global economy make comprehensive security measures essential.

Use DORA as an opportunity

Description: Make IT security a strategic strength of your company. With our penetration tests, TLPTs and awareness programs, you not only meet the key points of the DORA regulation, you also gain a decisive competitive advantage.

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Industrial espionage and economic crime: DORA as a protective shield

Industrial espionage and economic crime are no longer marginal phenomena. The financial sector in particular is a preferred target for cyber criminals who are after sensitive data, payment information and strategic information. This is exactly where DORA comes in: It creates a framework that enables companies to protect their IT systems not just reactively, but proactively.

A real-life example: A leading financial institution fell victim to a targeted spear phishing attack in which access data was stolen and strategically sensitive information was extracted. The analysis revealed that basic security measures such as penetration testing and employee training were lacking. In this case, DORA would not only have created the legal requirements, but also provided concrete measures for prevention.

Is your conclusion regarding the DORA regulation now different?

If we have done our job right, you will hopefully now be less worried and more motivated about the tasks and opportunities that DORA brings for your company.

It is clear that an article cannot answer all open questions. The circumstances in every company are too individual for that. Personal, free and non-binding advice is of course a given for us at the beginning of every inquiry from responsible persons like you. Simply briefly describe your requirements and questions in the contact form or call us directly - we will find the right contact person internally and arrange a suitable appointment for a needs analysis!

Increase the security of your IT system now!
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FAQ on the DORA Regulation

1. What is the DORA regulation? The DORA Regulation (“Digital Operational Resilience Act”) is an EU regulation that came into force on January 15, 2025. Its aim is to strengthen the digital resilience of financial institutions and insurance companies in order to effectively deal with cyberattacks and IT failures.

2. Who is affected by the DORA regulation? All companies in the financial sector as well as critical third-party providers such as IT service providers and cloud providers.

3. What are the requirements of the DORA regulation? The regulation prescribes, among other things, the following measures:

  • Regular penetration tests (Article 24)
  • IT risk management and emergency plans (Article 12)
  • Third-party management (Articles 28–31)
  • Awareness measures for employees (Article 13)

 

4. Why is the DORA regulation important? The regulation offers companies the opportunity to approach IT security strategically instead of just reacting to attacks. It not only protects individual organizations, but also increases the stability of the entire financial system.

5. How can ProSec help with implementation? ProSec offers practical solutions such as penetration testing, threat-led penetration testing (TLPT), awareness training and audit-ready documentation to effectively and sustainably meet the requirements of the DORA regulation.

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