DORA · EU regulation · financial sector

Implement DORA now — document ICT risks, the RoI and your reporting processes so they stand up to scrutiny

We support financial entities & ICT third-party providers with the gap analysis, ICT risk management, the Register of Information, incident reporting, third-party governance and ongoing DORA documentation.

  • Scope assessment for financial entities & ICT third-party providers
  • Full service 9,000 – 29,900 € depending on company size
  • 4–6 months to auditable DORA documentation
  • Setup of your ISMS platform — subscription separate, also for ongoing compliance
  • 30 minutes assessment
★★★★★ 5.0 from 12+ certified clients · ·
DQS · TÜV NORD · notivia since 2003 · +50 ISMS clients* · +20 Full-service clients* · 100% Audit success* · ★★★★★ 5.0

* Audit success relates to completed full-service certification projects since 2019. Client numbers include ISMS platform licence holders and full-service projects.

Quick check

This page is for you if …

  • … you fall under DORA as a financial entity .
  • … you need a ICT risk management framework .
  • … you need a Register of Information (RoI) under Art. 28.
  • … you want to prepare for TLPT (threat-led penetration testing) .
  • … you want to know what DORA compliance costs and how long it takes.
Our services for DORA

Three building blocks. One route to compliance.

Operational resilience for financial entities — ICT risk, the third-party register, TLPT support and reporting to the supervisor.

Maximum support

Full-service support

The DORA framework built and documented — from the ICT risk policy to the Register of Information.

This suits you if you want DORA compliance with as little internal project load as possible.
  • ICT risk management framework
  • Register of Information (Art. 28)
  • Incident reporting process
  • Third-party governance
from €9,000 one-off · M from 18,000 € · L from 29,900 €
Request a quote
Ongoing

External ICT risk officer

A senior expert for your ICT risk management, facing BaFin and the auditors.

This suits you if you want your DORA compliance maintained and the dealings with the authorities taken off your hands.
  • Support with BaFin reporting
  • Quarterly risk reports
  • Board briefings
  • Support during inspections
from €700 / month
Enquire about consulting
12-month minimum term · 3 months' notice
One-off / yearly

Internal audit

A DORA readiness audit before the supervisor looks at you.

This suits you if you want your DORA measures verified ahead of a supervisory inspection.
  • DORA gap analysis
  • RoI quality review
  • TLPT readiness check
  • Final report for the board
from €6,900 one-off
Enquire about an audit

Additionally for DORA

Standard-specific extras — bookable individually

Register of Information (RoI)

Building and maintaining your DORA register, including the annual update.

from €4,900 + €199/mo

TLPT coordination

Threat-led penetration testing with certified partners.

from €18,000/cycle

Supplier classification

Criticality assessment of your ICT third parties under Art. 28 et seq.

from €3,490
Retainer services (external officer, reporting channel): 12-month minimum term · 3 months' notice to the end of the month · all prices exclude VAT.
Free initial assessment

Clarity on DORA in 30 minutes

We establish whether DORA applies to you, which evidence is missing and what the sensible next steps are. An honest estimate instead of blanket promises, and no sales pressure.

Lead consultant
Lead consultant
Your contact
  • The fastest answer we can give
  • Realistic figures for time and cost
  • No sales pressure, no obligation
  • From notivia GmbH, Stuttgart — since 2019
think why NETFORMIC Animus Intelligence Crest Digital Veoma VERDURE
Book directly — the quickest way
Pick a 30-minute slot yourself
or send us a message

    No spam·No obligation·The fastest answer we can give·GDPR-compliant
    Prefer to call? +49 711 35 15 705
    Start on your own

    Two tools — ready to use right now

    Before you get in touch: work out the cost and explore the platform — free and without obligation.

    Free DORA check · 2 min

    Does DORA apply to you?

    10 questions on sector, size and activity. Know straight away whether DORA is mandatory for you.

    Start the check

    Or do it yourself

    The ISMS platform with its DORA module

    The multi-standard ISMS digitalises ICT risk management, the Register of Information and TLPT preparation — made for internal teams that want to maintain the RoI, ICT risks and evidence digitally.

    Explore the platform
    Guide · PDF

    DORA guide for financial entities

    What the regulation requires, which deadlines apply, what the management board needs to know — explained plainly.

    Download the guide
    THE 5 PILLARS

    The DORA framework at a glance

    DORA rests on five central pillars of digital operational resilience.

    1

    ICT risk­ management

    A comprehensive framework for managing all ICT risks, including governance and controls.

    2

    Incident­ reporting

    Classifying and reporting major ICT incidents to the supervisor.

    3

    Resilience­ testing

    Regular testing of digital operational stability, including threat-led penetration testing (TLPT).

    4

    ICT third­ parties

    Managing and monitoring ICT third-party risk along the whole supply chain.

    5

    Information­ sharing

    Voluntary sharing of threat intelligence between financial entities.

    CORE REQUIREMENTS

    What DORA asks of you

    The main duties under Regulation (EU) 2022/2554

    ICT risk management framework

    The management body must define, approve and oversee an ICT risk management framework (Art. 5–16).

    ICT incident management & reporting duties

    Classifying ICT incidents, reporting them to the supervisory authorities and documenting them (Art. 17–23).

    Digital operational resilience testing

    Regular resilience testing, penetration testing and threat-led testing (TLPT) (Art. 24–27).

    ICT third-party risk management

    Contractual arrangements, the register, concentration risk and exit strategies for ICT outsourcing (Art. 28–44).

    ICT information register

    A complete register of every contractual ICT arrangement with third parties (Art. 28(3)).

    Governance & management responsibility

    The management body carries overall responsibility for ICT risk and must be trained regularly (Art. 5).

    REPORTING DUTIES

    Reporting ICT incidents under DORA

    1
    Within 4 hours (of classification)

    Initial report to the supervisor

    Immediate notification of a major ICT incident — at the latest 24 hours after becoming aware of it.

    2
    Within 72 hours

    Interim report with analysis

    A detailed analysis of the incident, an impact assessment and the status of the countermeasures.

    3
    Within 1 month

    Final report

    A complete report with root cause analysis, the measures taken and proposed improvements.

    Heavy fines

    The EU supervisory authorities can impose substantial sanctions — including daily penalty payments of up to 1 % of average daily turnover.

    Personal responsibility

    The management body is personally responsible for implementing and overseeing ICT risk management.

    WHO IS IN SCOPE?

    Does your company fall under DORA?

    DORA covers almost the entire financial sector — from banks through insurers to crypto service providers and their critical ICT suppliers.

    Directly in scope financial entity

    • Credit institutions & payment providers
    • Insurers & reinsurers
    • Investment firms & trading venues
    • Crypto service providers & e-money institutions
    • Fund managers & pension funds

    Indirectly in scope ICT third-party providers

    • Cloud providers (IaaS, PaaS, SaaS)
    • Software and platform providers
    • Data analytics and reporting services
    • IT security service providers
    • Managed service providers (MSPs)

    21 categories of financial entity

    Credit institutions Payment institutions Account information service providers E-money institutions Investment firms Crypto service providers Central securities depositories Trading venues Trade repositories AIFMs & UCITS Insurers Reinsurers Insurance intermediaries Pension funds Rating agencies Statutory auditors Securitisation special purpose entities ICT third-party providers
    The regulation in brief

    What has to be in place for ISO 27001?

    Eight building blocks — the mandatory set for DORA compliance.

    1. ICT risk management framework (Art. 5–15)
    2. Incident management & reporting (Art. 17–23)
    3. Digital resilience testing (Art. 24–27)
    4. ICT third-party risk management (Art. 28–44)
    5. Register of Information (Art. 28)
    6. Threat-Led Penetration Testing (TLPT)
    7. Board duties & training
    8. Communication with authorities & reporting (Art. 19)

    In the initial call we show you which points you already meet.

    Book a free initial assessment
    OVERLAP

    ISO 27001 as the a strong basis for DORA

    ISO 27001 is a strong basis for DORA — but it does not replace it. Many building blocks such as risk management, incident management, supplier management, business continuity and internal audit can be reused. DORA adds specific requirements for the Register of Information, ICT third parties, reporting processes, resilience testing and supervisory documentation.

    DORA requirementCovered by ISO 27001
    Art. 5–16 ICT risk management ISO 27001 cl. 6.1 + A.5–A.8
    Art. 17–23 incident reporting ISO 27001 A.5.24–A.5.28
    Art. 24–27 resilience testing ISO 27001 A.8.8 + cl. 9.2
    Art. 28–44 third parties ISO 27001 A.5.19–A.5.23
    Art. 5 governance ISO 27001 cl. 5 leadership
    Art. 13 business continuity ISO 27001 A.5.29–A.5.30
    up to ~60 %
    overlap between ISO 27001 and DORA — depending on scope and what you already have in place
    OUR SOLUTION

    Implementing DORA with iso-easy

    1

    Gap analysis

    Comparing your existing measures against every DORA requirement and identifying the gaps.

    2

    Build the ICT framework

    Implementing the risk management framework and setting up the ICT third-party register.

    3

    Integrate the ISMS

    Using ISO 27001 as the base and adding the DORA-specific extensions.

    4

    Compliant for the long run

    Ongoing monitoring, resilience testing and reporting in a PDCA operating mode.

    ICT risk management Incident reporting Third-party register Resilience testing Business continuity Exit strategies
    DORA Art. 28 · the duty that hurts

    Build the Register of Information

    We structure ICT third parties, contracts, critical functions, outsourcing and the upkeep processes into one auditable DORA register.

    • A structured record of every ICT service provider
    • Classification by criticality (Art. 28)
    • Contract mapping and outsourcing documentation
    • Ongoing upkeep processes for reports to the authorities
    Have your RoI reviewed
    FAQ

    Frequently asked questions about DORA

    What is DORA?
    DORA (the Digital Operational Resilience Act) is an EU regulation (2022/2554) that sets uniform requirements for the digital operational stability of the financial sector. It has applied directly in all EU member states since 17 January 2025, without national transposition.
    Who does DORA apply to?
    DORA covers 21 categories of financial entity — from credit institutions and insurers through investment firms to crypto service providers. On top of that, critical ICT third-party providers (cloud providers, software vendors and so on) come under supervision.
    What is the difference between DORA and NIS-2?
    DORA is a regulation written specifically for the financial sector and applies directly. NIS-2 is a directive for all critical sectors and has to be transposed into national law. For financial entities DORA takes precedence as the more specific law (lex specialis).
    Do I need ISO 27001 for DORA?
    ISO 27001 is not compulsory, but it is a recognised basis for evidencing many security, risk, supplier and incident management requirements in a structured way. A certified ISMS is usually the most efficient way into DORA compliance.
    What are the DORA deadlines?
    DORA has been binding since 17 January 2025. Entities in scope should review and document their implementation status, gaps and evidence promptly, so they are ready for supervisory questions.
    Can I implement DORA and ISO 27001 at the same time?
    Yes — we recommend it. Our multi-standard ISMS covers both in one integrated system. You build the ISMS once and satisfy ISO 27001 and DORA together — without doing the work twice.
    How much internal work does this really mean for us?
    A conventional DORA project swallows 50–80 person-days of internal time (the third-party inventory above all). With our approach plus the ISMS platform we bring that down to 20–30 person-days. We take on most of the RoI structuring, the risk analyses and the third-party assessments for you.
    What happens after DORA is implemented? Inspections?
    Yes. Financial supervisors (BaFin, ECB, ESMA) can inspect actively and request evidence. With our ISMS platform the Register of Information, the risk analyses and the incident documentation are available at any time — which reduces the risk of gaps when evidence is asked for.
    What is threat-led penetration testing (TLPT), and who needs it?
    TLPT is an advanced, threat-intelligence-led penetration testing method under DORA Art. 26–27. It is mandatory for significant financial entities (banks above certain thresholds, for example). TLPT is considerably more demanding than conventional pen testing and must be carried out by accredited testers. Our preparation covers scope definition, the threat profile and coordination.
    Is ISO 27001 enough for us, or do we still need DORA?
    ISO 27001 covers around 60 % of the DORA requirements — a very good base. But DORA additionally requires the Register of Information, threat-led penetration testing, formalised third-party contracts, official reporting channels and board reporting. With ISO 27001 in place, expect 30–40 % additional effort for full DORA compliance.
    How high are the penalties for breaching DORA?
    It depends on the country and the severity of the breach. For financial entities fines of up to 1 % of average worldwide daily turnover are possible (cumulative). On top of that come supervisory measures, public disclosure and, in the extreme, a ban on senior managers holding office.