DORA requires financial entities to maintain a register of ICT third-party arrangements and to demonstrate that ICT risk is managed end to end, not just documented. Most firms can produce the register. Far fewer can show, process by process, how an ICT incident at a named third party actually propagates through the operations that depend on it. IGX360 Insights connects the register to the operating model it is supposed to describe.
Basic questions require analysts to assemble answers manually. The underlying weakness is the absence of a governed, connected and queryable representation of the operating model.
Compliance gaps remain invisible until assurance activity begins. The underlying weakness is the absence of traceability from obligation through process, owner, system, control, execution and retained evidence.
Single points of failure remain embedded in the operating model. The underlying weakness is the absence of an end-to-end view of critical outcomes, dependencies, concentration, substitution, controls and recovery assumptions.
The organisation cannot see which processes create each risk, which controls operate within them or where coverage is absent. The underlying weakness is the absence of traceability from obligation through process, owner, system, control, execution and retained evidence.
Affected processes, systems, controls, roles and suppliers are identified manually and inconsistently. The underlying weakness is the absence of traceability from obligation through process, owner, system, control, execution and retained evidence.
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.
Governance does not reliably change tasks, decision thresholds, approvals, escalation or evidence capture. The underlying weakness is the absence of traceability from obligation through process, owner, system, control, execution and retained evidence.
Cyber risks, systems, suppliers, incidents and controls are not fully connected to the processes delivering the essential service. The underlying weakness is the absence of traceability from obligation through process, owner, system, control, execution and retained evidence.
The end-to-end concentration and failure dependencies behind each service are not represented or tested as one operating model. The underlying weakness is the absence of an end-to-end view of critical outcomes, dependencies, concentration, substitution, controls and recovery assumptions.
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