How to Become DORA Compliant as a SaaS or Software Vendor (2025 Guide)

Introduction

With the Digital Operational Resilience Act (DORA) coming into effect on January 17, 2025, software vendors, cloud providers, and SaaS companies that support financial institutions across the EU must now meet strict compliance requirements.

DORA introduces a new baseline for operational resilience, risk management, and ICT oversight — and that baseline applies not only to banks and insurers, but also to third-party ICT providers. This includes your infrastructure, processes, documentation, and even your subcontractors.

This guide walks you through exactly how to prepare your business for DORA compliance step by step, whether you're a SaaS platform, API provider, cloud vendor, or software development partner.

Who Should Read This Guide?

• CTOs and Heads of DevOps in software vendors
• Compliance officers in B2B SaaS companies
• CEOs/founders of tech companies selling into financial institutions
• Product or platform teams preparing for audits or RFPs

If your clients are banks, investment firms, insurers, or fintechs operating in the EU, this guide is for you.

DORA Compliance Checklist: Overview

Here’s a high-level view of what’s expected:

Step-by-Step Plan for DORA Compliance

Step 1: Identify Whether You're In Scope

Ask yourself:

• Do we build, host, or support systems used by regulated financial entities?
• Is our SaaS/platform integrated into any bank or insurer workflow?
• Do procurement or renewal documents ask about ICT risk?

If yes to any of the above: you are in scope.

Step 2: Map Your ICT Assets and Dependencies

Create a complete inventory of:

• Core systems and data flows
• Cloud and hosting infrastructure (AWS, GCP, Azure)
• APIs and third-party integrations
• Subcontracted tech partners or vendors

Use a visual map or dependency diagram to document relationships and failure points.

Step 3: Build or Adapt a Risk Management Framework

You need a documented system for:

• Identifying and categorizing ICT risks
• Defining mitigation actions and owners
• Monitoring risk exposure and controls
• Reviewing risks periodically (e.g. quarterly)

📄 Use templates to fast-track this step.

Step 4: Prepare an Incident Response Plan

Your plan must cover:

• Detection and classification of incidents
• Internal escalation procedures
• 24-hour external reporting obligations
• Recovery and resolution processes
• Communication flows with clients and regulators

💡 Include incident response testing simulations at least annually.

Step 5: Plan for Resilience Testing

DORA expects operational resilience to be tested, not just theorized. That means:

• Penetration testing of exposed systems
• Tabletop exercises simulating outages
• Red teaming (or TLPT) for high-risk services

TLPT = Threat-Led Penetration Testing, often required by large financial clients.

You may not need to run a TLPT yourself, but you must be prepared to participate.

Step 6: Create a Vendor Risk Management System

This step is often overlooked. You must document:

• Who your tech vendors are (cloud, CI/CD, logging, etc.)
• What services they provide
• SLAs and availability/recovery terms
• Risk classification and substitution plans

🛠️ Tools like vendor scorecards or risk registers help make this scalable.

Step 7: Establish Governance and Ownership

DORA requires board-level accountability. That means:

• C-level oversight for ICT risk and continuity
• Documented responsibilities and escalation points
• Annual reviews and strategic alignment

📋 Create board presentation templates or dashboards to communicate risk posture.

Step 8: Run a Gap Analysis Against DORA

Before declaring readiness:

• Review all the documentation you’ve created
• Compare your stack and processes with the DORA baseline
• Simulate a mock audit with internal or external reviewers

✅ Use a checklist to ensure no area has been skipped.

How Long Does It Take to Become Compliant?

Depending on your current maturity:

Factors that affect the timeline:

• Complexity of your stack (microservices, multi-cloud, etc.)
• Number of clients or integrations
• Availability of internal resources

What You Can (and Can’t) Outsource

You can outsource:

• Templates and policy frameworks
• Risk and dependency mapping
• Simulation workshops and audit support
• TLPT planning and compliance strategy

You cannot outsource:

• Executive responsibility
• Actual internal processes (e.g., detection, escalation, comms)

Use partners to accelerate — but retain core accountability.

How SH Can Help

We provide end-to-end DORA compliance kits and advisory services:

• Editable policy templates (incident, risk, business continuity)
• DevOps-aligned dependency mapping tools
• Incident notification flows and register templates
• Board documentation and ownership maps

Optional Add-ons

• TLPT and red team planning
• Audit simulation workshops
• Stakeholder onboarding checklists

🎯 Designed for SaaS and cloud-native vendors.

Real-World Example: Siemens Financial Services

We helped Siemens Financial Services roll out cloud based platforms with:

• Audit-proof architecture
• Secure access control
• Business continuity and compliance-by-design

"Startup House is our trusted software development partner, with whom we have worked for many years." — Piotr Stępień, Senior Project Manager, Siemens Financial Services

Final Checklist: Are You DORA-Ready?

If not, now’s the time to act.

Let’s Build Your DORA Playbook

We're helping SaaS and cloud vendors across Europe become DORA-compliant — fast. Let us help you prepare before the deadline.