What is the Digital Operational Resilience Act (DORA) and How It Affects Tech Vendors

Introduction

Starting January 17, 2025, the Digital Operational Resilience Act (DORA) becomes legally binding across the European Union. Unlike many previous financial regulations, DORA doesn’t just affect banks and insurers — it directly impacts technology vendors, SaaS providers, cloud platforms, analytics firms, and software houses that support the financial sector.

If you're part of the digital supply chain for a bank, insurer, fintech, or any regulated financial entity in the EU, then DORA compliance isn't optional. It’s a contractual necessity. And failing to meet its requirements could mean losing valuable clients, failing audits, or being excluded from procurement processes.

In this article, we’ll break down what DORA is, who it applies to, what it requires, and what tech vendors need to do to become compliant.

What is the Digital Operational Resilience Act (DORA)?

DORA is an EU regulation designed to ensure that all participants in the financial sector — including their ICT (Information and Communication Technology) partners — can withstand, respond to, and recover from operational disruptions like cyberattacks, outages, and supply chain failures.

DORA was adopted as part of the EU Digital Finance Package and is part of a broader strategy to make the EU financial system more resilient in an increasingly digital world.

Core Goal

To standardize how financial institutions and their ICT providers manage risks related to digital operations and technology dependencies.

Enforcement Date

January 17, 2025 — from this date, all organizations in scope must be fully compliant.

Who Needs to Comply with DORA?

DORA applies to both financial institutions and their third-party and fourth-party ICT providers. That includes:

Financial Entities:

• Banks, insurers, investment firms, credit institutions
• Payment and e-money institutions
• Crypto-asset service providers (under MiCA)
• Pension funds and asset managers

ICT Providers:

• Software houses building tools for financial firms
• SaaS vendors serving the finance industry
• Cloud infrastructure and hosting providers
• Analytics and AI firms offering financial services
• API integration or middleware platforms

If your software, infrastructure, or service is part of a regulated entity's operational chain, then you fall under DORA.

This includes subcontractors or subcontractors of subcontractors (i.e., fourth-party providers).

Why DORA Matters for Tech Vendors

Until now, many software providers assumed that regulations like GDPR or PSD2 applied only to their clients. DORA changes the game: now technology providers themselves are accountable.

Here’s why it matters:

• Clients are legally obligated to audit your DORA readiness
• Non-compliant vendors can be disqualified from RFPs and contract renewals
• Procurement processes will include ICT risk and resilience reviews
• DORA compliance is no longer a competitive advantage — it’s the baseline

In short: If you build for finance, you must prove that your technology and processes meet DORA standards.

What Does DORA Require?

DORA outlines five key areas of compliance for ICT providers:

1. ICT Risk Management

You must implement and document processes to identify, assess, mitigate, and monitor ICT-related risks.

• Threat detection and prevention
• Business continuity planning
• Backup and restore procedures

2. Incident Response & Reporting

DORA mandates structured workflows for handling incidents, including:

• 24-hour breach reporting to clients
• Root-cause analysis and lessons learned
• Clear escalation and communication channels

3. Digital Resilience Testing

You’re expected to run regular resilience testing, which may include:

• Penetration testing
• Red teaming (threat-led simulations)
• Tabletop or scenario-based exercises

4. Third-Party Risk Management

You must maintain visibility over your own vendors, including:

• Vendor risk registers
• SLA reviews and controls
• Cloud dependency assessments

5. Governance & Accountability

Senior management or board members must:

• Own the risk management strategy
• Review key ICT decisions
• Ensure resources and reporting are in place

What Happens If You Don’t Comply?

While DORA doesn’t impose direct fines on vendors (it targets regulated financial institutions), non-compliance will have commercial consequences.

• You may be removed from preferred vendor lists
• Your clients may fail audits because of you
• You might lose key accounts or fail to qualify for new ones

Being DORA-compliant is rapidly becoming a procurement filter.

How Long Does DORA Compliance Take?

From experience working with SaaS providers, cloud vendors, and software teams, the typical timeline looks like this:

• Week 1: Onboarding, risk mapping, gap analysis
• Weeks 2–4: Deploying policies, incident plans, and governance templates
• Weeks 5–8: Internal reviews, simulation testing, audit readiness

Most vendors can achieve readiness in 30–60 days, depending on complexity.

How Can SH Help?

We provide plug-and-play DORA compliance kits for lean tech teams:

• Editable policy templates (risk, incident, business continuity)
• Vendor risk registers, audit logs, escalation workflows
• DevOps-friendly mapping templates for cloud and integration layers
• Sample board governance documents

Our kits are field-tested, customizable, and ready to deploy in less than a week.

Additional Support

• TLPT (threat-led penetration testing) planning
• Red teaming guidance
• Simulation workshop facilitation

Siemens Financial Services: A Proven Use Case

We helped Siemens Financial Services building cloud based financial platforms with:

• Audit-proof architecture
• Secure access control
• Built-in business continuity

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

Summary: DORA Compliance in 5 Takeaways

1. DORA applies to tech vendors, not just banks.
2. Compliance is mandatory from January 17, 2025.
3. Risk management, incident workflows, and resilience testing are core pillars.
4. Non-compliance can result in lost deals and failed audits.
5. Startup House offers fast, tailored, audit-ready solutions.

Check out:

• How to Become DORA Compliant as a SaaS or Software Vendor (2025 Guide)
• Why DORA Compliance Is a Competitive Advantage for Software Vendors in 2025