Understanding DORA Compliance: What It Means for Financial Firms — And How to Get Compliant in 2025

The Digital Operational Resilience Act (DORA) represents a significant regulatory shift for financial services firms across the European Union. Coming into full effect in January 2025, DORA introduces binding obligations designed to ensure that firms can withstand, respond to, and recover from ICT-related disruptions.

This regulation is not simply a technology update — it marks a transformation in how digital risk is treated within the financial system. For EMIs, PIs, crypto firms, asset managers, and fintech platforms, understanding DORA — and implementing a practical compliance approach — is now essential.

What Is DORA?

DORA is EU Regulation (EU) 2022/2554, passed to improve the digital operational resilience of the financial sector. Unlike previous frameworks, which relied on fragmented national rules or indirect references to ICT risk, DORA creates a harmonised legal framework across all 27 EU member states.

The regulation mandates that all covered firms must have systems and controls in place to identify, protect against, detect, respond to, and recover from ICT disruptions — including cyberattacks, outages, and third-party failures.

Who Does DORA Apply To?

DORA applies to over 22,000 financial entities across the EU, including:

• Electronic Money Institutions (EMIs)

• Payment Institutions (PIs)

• Crypto Asset Service Providers (under MiCA)

• Asset Managers and Investment Firms

• Insurers and Pension Firms

• Credit Institutions (Banks)

• Crowdfunding Platforms and Regtechs

• ICT Third-Party Service Providers (including cloud and SaaS firms)

It also applies indirectly to critical ICT third-party service providers, who will face increased scrutiny and oversight by supervisory authorities.

What Does DORA Require?

DORA introduces specific and detailed obligations across five key areas:

1. ICT Risk Management

Firms must implement a structured framework for managing ICT risks — including governance, incident handling, risk classification, business continuity, and backup systems.

2. Incident Reporting

Significant ICT-related incidents must be reported within strict timelines, including:

• Initial notification (within hours/days)

• Intermediate updates

• Final post-incident analysis

3. Digital Operational Resilience Testing

Firms must regularly test their systems, including:

• Vulnerability assessments

• Penetration testing

• Advanced scenario-based testing (for critical firms)

4. Third-Party Risk Management

DORA introduces strict rules for outsourcing ICT functions:

• All ICT third-party contracts must include specific clauses

• Firms must maintain a register of ICT service providers

• Concentration and systemic risk must be monitored

5. Information Sharing

Firms are encouraged (and in some cases required) to participate in threat intelligence sharing initiatives.

When Does DORA Apply?

DORA entered into force on 16 January 2023 and became fully applicable from 17 January 2025. Supervisors are expected to begin formal audits and enforcement actions from mid-2025 onward.

What Happens If You Don’t Comply?

Failure to comply with DORA could result in:

• Regulatory enforcement actions

• Fines and sanctions

• Increased audit scrutiny

• Loss of confidence from clients and investors

• Reputational damage following unreported or mishandled ICT incidents

For fast-growing firms operating across borders or engaging with EU clients, non-compliance can become a barrier to growth.

How Buckingham Capital Consulting Helps

At Buckingham Capital Consulting, we provide expert-led, fixed-fee DORA compliance support designed for financial firms that need fast, structured, and regulator-aligned solutions.

We help our clients:

• Conduct Gap Assessments to identify deficiencies across all five DORA pillars

• Design and Implement ICT Risk Frameworks with board-level governance

• Develop Incident Playbooks aligned with reporting obligations

• Build Third-Party Registers and Review Contracts for outsourcing compliance

• Prepare for Operational Resilience Testing and supervisory inspections

• Produce Full Documentation Packs ready for internal and external audit

Our team brings 14+ years of regulatory experience and deep knowledge of both EU frameworks and UK financial regulation.

We work with:

• All financial services firms, including, EMIs, PIs, and crypto platforms seeking a structured compliance approach

• Banks, insurers, asset managers and fintechs scaling across multiple EU jurisdictions

• Boards and executive teams seeking to strengthen governance and assurance

Start Your DORA Journey Now

With the enforcement landscape evolving rapidly, the time to act is now. DORA compliance is no longer optional — and regulators are preparing to assess how firms have implemented their frameworks.

Buckingham Capital Consulting is ready to support your transition. Contact us today for a structured review and action plan to ensure full compliance with DORA — before audits begin.