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

Introduction to DORA Compliance

The Digital Operational Resilience Act (DORA) is a landmark regulation from the European Union, designed to ensure that financial entities can withstand and recover from digital disruptions. DORA compliance is now a critical requirement for financial institutions and their technology partners, including SaaS and software vendors. By following a structured DORA compliance checklist, organizations can systematically address their obligations—ranging from ICT risk management and incident reporting to digital operational resilience testing and third party risk management.

Achieving DORA compliance means more than just ticking boxes; it’s about building true operational resilience. This involves identifying and mitigating ICT risks, preparing for potential incidents, and ensuring that both internal systems and third-party providers are robust and secure. For financial entities, operational resilience is not only a regulatory expectation but also a competitive advantage, helping to maintain trust with clients and partners in an increasingly digital financial sector. The operational resilience act DORA sets a new standard for how financial institutions approach risk management, resilience testing, and ongoing compliance in the digital age.

Understanding DORA Requirements

To achieve DORA compliance, financial entities must understand and implement the regulation’s core requirements. DORA is built on five key pillars: ICT risk management, incident reporting, digital operational resilience testing, third-party risk management, and governance. Each pillar is essential for building a comprehensive approach to digital operational resilience.

A robust ICT risk management framework is at the heart of DORA, requiring organizations to identify, assess, and mitigate ICT risks across all systems and processes. Incident reporting protocols must be established to ensure timely communication with regulators and stakeholders in the event of ICT-related incidents. Regular operational resilience testing—including threat led penetration testing (TLPT)—is mandated to validate the effectiveness of security controls and response capabilities. Third party risk management is also a major focus, with financial institutions expected to assess and monitor the resilience of all third party ICT providers. By aligning ICT systems, governance structures, and risk management processes with DORA’s requirements, financial entities can ensure they are prepared for both regulatory scrutiny and real-world digital threats.

With the  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 also applies to financial organizations and ICT service providers operating in or serving the EU, extending its regulatory reach beyond traditional banks and insurers.

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.

Information and communication technology (ICT), including communication technology, plays a critical role in ensuring operational resilience and regulatory compliance under DORA. Effective management of communication technology ICT is essential for meeting legal requirements and supporting robust risk management frameworks.

European Supervisory Authorities, such as the European Banking Authority, the European Insurance and Occupational Pensions Authority, and other ESAs, are responsible for overseeing DORA compliance and setting regulatory standards for ICT risk management and operational resilience in the EU financial sector.

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. It highlights the importance of maintaining compliance with DORA compliance requirements and establishing a robust compliance process to ensure ongoing adherence.

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 in a comprehensive DORA compliance checklist that covers all key areas:

It is also crucial to stay informed about DORA compliance dates to ensure your organization meets all regulatory deadlines on time.

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?
• Does our organization qualify as a financial institution under DORA?

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

This step helps identify gaps in your current compliance posture.

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, as mapping dependencies is crucial for anticipating and managing potential ICT disruptions.

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)
• Conducting regular risk assessments to evaluate vendor compliance and overall risk posture

Developing robust risk management strategies and adopting such a framework are essential for meeting DORA compliance requirements and ensuring operational resilience in the financial sector.

📄 Use templates to fast-track this step.

Step 4: Prepare an Incident Response Plan

Your plan must cover:

• Detection and classification of incidents, including ICT incidents and procedures for responding to a data breach
• Internal escalation procedures
• 24-hour external reporting obligations
• Recovery and resolution processes
• Communication flows with clients, regulators, and key stakeholders to ensure coordinated response during incident management
• Establishing protocols for reporting ICT related incidents, including major ICT related incidents, to ensure regulatory compliance and timely notification

💡 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
• Resilience tests to evaluate your organization's ability to recover from disruptions
• Red teaming (or TLPT) for high-risk services

Resilience testing helps assess and improve your overall security posture, ensuring your organization is better prepared for real-world incidents.

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
• Regular vendor risk assessments to ensure ongoing compliance and operational resilience

It is also important to monitor your vendors to prevent data breaches and other security incidents. Performing a DORA gap analysis on your vendor management processes can help identify and address any compliance gaps with DORA requirements, strengthening your ICT resilience.

🛠️ 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
• Compliance teams supporting governance activities, automating workflows, and ensuring ongoing regulatory adherence

The board is also responsible for approving and overseeing digital resilience strategies to ensure effective implementation and top-level buy-in.

📋 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
• Conduct a DORA gap analysis to assess your organization’s alignment with DORA compliance requirements
• Simulate a mock audit with internal or external reviewers

This process helps you identify gaps, address DORA compliance requirements, and achieve and maintain compliance.

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

Continuous Monitoring for Ongoing Compliance

Maintaining DORA compliance is not a one-time effort—it requires continuous monitoring and adaptation. Financial entities must regularly assess their ICT systems, processes, and governance to identify new risks and vulnerabilities. This includes conducting regular ICT risk assessments, monitoring the performance and security of third party ICT providers, and reviewing incident response plans to ensure they remain effective.

Leveraging technology, such as Enterprise Architecture tools, can help automate ongoing monitoring and reporting, making it easier to stay aligned with DORA requirements. Continuous monitoring enables financial institutions to quickly detect and respond to emerging cyber threats, adapt to regulatory changes, and address operational disruptions before they escalate. By embedding regular ICT risk assessments and third party ICT reviews into their compliance processes, organizations can ensure sustained operational resilience and ongoing compliance with the digital operational resilience act.

Intelligence Sharing: Collaborating for Resilience

DORA recognizes that operational resilience is strengthened through collaboration and intelligence sharing across the financial sector. By sharing threat intelligence and best practices, financial entities can collectively identify emerging digital threats and enhance their incident response capabilities. Participation in industry-wide platforms and regulatory forums allows financial institutions to stay informed about the latest risks and mitigation strategies, while also contributing to the broader financial system’s resilience.

This collaborative approach not only improves individual security postures but also helps maintain trust with clients and partners. By working together, financial entities can better anticipate and respond to disruptions, ensuring the stability and security of the financial sector as a whole.

Maintenance and Review: Keeping Your DORA Program Current

Ongoing maintenance and regular review are essential for keeping your DORA compliance program effective and up to date. Financial entities should periodically review and update their ICT risk management frameworks, incident response plans, and third party risk management processes to reflect changes in technology, business operations, and regulatory requirements.

Regular gap analyses help identify areas where compliance may be lacking, while assessments of vendor risk and business continuity plans ensure that all aspects of operational resilience are covered. Investing in employee education and training is also crucial, as it ensures that staff understand DORA requirements and their individual roles in maintaining compliance. By fostering a culture of security and resilience, financial institutions can proactively address vulnerabilities, adapt to new challenges, and maintain a robust digital operational resilience framework that stands the test of time.

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.