DORA evidence is fragmented across ICT, risk and operations
DORA responsibilities are distributed across ICT risk, operational resilience, vendor management, incident response, audit and business operations. This becomes most visible when an audit, regulatory change, incident or assurance request requires the organisation to prove how an obligation operates in practice.
Critical functions, ICT assets, third parties, risks, controls, incidents and testing evidence are not represented end to end. The underlying weakness is the absence of traceability from obligation through process, owner, system, control, execution and retained evidence.
Registers and reports may exist, but dependency gaps and inconsistent evidence weaken resilience and supervisory confidence. At enterprise scale, assurance remains periodic and manual while operational change creates new gaps faster than review cycles can find them.
A connected operating model supports critical-function mapping, third-party traceability, gap analysis and defensible evidence. In practical terms, change and assurance can be managed as connected operational work, with accountable remediation and evidence available by design.
- More defensible DORA mapping and evidence; clearer third-party dependency and resilience gaps; reduced manual assembly
- Faster regulatory impact assessment
- Earlier detection of control and evidence gaps
- Reduced audit and inspection preparation
- Defensible traceability from duty to execution
- Can every critical or important function be traced to its ICT and third-party dependencies?
- Where is DORA evidence assembled today?
- Which resilience gaps remain invisible between organisational silos?
- Which obligation is hardest to trace to a named operational owner and control?
- What evidence would prove implementation rather than policy publication?
The EBA states that in-scope financial entities must maintain comprehensive registers of ICT third-party contractual arrangements.
European Banking Authority: DORA Registers of Information
DORA requires financial entities to maintain a sound, comprehensive and documented ICT risk-management framework and addresses incident management, testing and ICT third-party risk.
EUR-Lex: Regulation (EU) 2022/2554