DORA for Technology Professionals

The EU Digital Operational Resilience Act (DORA) is a regulatory framework aimed at strengthening the digital operational resilience of financial entities and certain ICT providers. This page is a high-level educational primer for technology professionals who collaborate with risk, compliance, and business stakeholders.

It is not:

• Legal advice
• A determination of whether your organisation is in scope
• A claim that following these notes achieves compliance or regulatory approval
• A substitute for official text, supervisory guidance, or qualified counsel

Always verify obligations with authoritative sources and your organisation’s compliance function.

Why technology professionals should care

Even when you are not the compliance owner, engineers and architects usually own the systems DORA-style resilience programmes depend on:

• Inventory of critical ICT services and data flows
• Access control and change management evidence
• Monitoring, logging, and incident timelines
• Third-party and concentration risk (including cloud and AI APIs)
• Testing that actually exercises failure modes

Thinking in these themes improves reliability for any serious product — regulated or not.

Core themes (practical lens)

1. ICT risk management

Idea: Know which systems matter, what can go wrong, and who owns the response.

Engineering habits that help:

• Maintain a living inventory of services, owners, and data classifications
• Tie risks to concrete controls (backups, auth, rate limits), not only slide decks
• Separate “nice to have” tooling from services that stop the business when they fail
• For AI features, include model providers and prompt/log stores in the inventory (AI risk checklist)

2. Incident management and learning

Idea: Detect, classify, respond, communicate, and learn — with timelines you can reconstruct.

Engineering habits that help:

• Structured severity definitions that engineers can apply under pressure
• Runbooks that name systems, dashboards, and decision makers
• Clock-friendly logging (what happened, when, blast radius)
• Post-incident reviews that produce backlog items, not blame

3. Digital operational resilience testing

Idea: Do not wait for production to discover that failover was theoretical.

Engineering habits that help:

• Game days and failure injection for critical paths
• Restore tests for backups (restore, not only “backup job succeeded”)
• Dependency tests: what happens when identity, payments, or the model API is unavailable?
• Document scenarios, results, and remediations

4. ICT third-party risk

Idea: Critical functions often run on someone else’s platform.

Engineering habits that help:

• Map concentration (one cloud region, one identity provider, one LLM API)
• Prefer designs with degraded modes and exit options
• Keep contractual and technical exit artefacts (exports, IaC, runbooks) current
• Use structured vendor questions for AI providers (vendor guide)

5. Information sharing (where applicable)

Idea: Sector learning can reduce repeated incidents.

Engineering habits that help:

• Prepare factual technical summaries suitable for sharing through approved channels
• Avoid leaking credentials, personal data, or exploit details inappropriately
• Align with your organisation’s disclosure process — do not freelance public statements

How DORA themes interact with AI systems

AI capabilities introduce familiar ICT risks with new textures:

| Theme | AI-specific angle | | --- | --- | | Inventory | Model endpoints, vector stores, agent tools, evaluation datasets | | Incidents | Harmful output, data leakage via prompts, cost/abuse spikes, provider outages | | Testing | Eval suites, prompt-injection cases, kill-switch drills | | Third party | Foundation model hosts, safety filters, plugin ecosystems | | Access | Service accounts for automation, break-glass for AI admin consoles (IAM checklist) |

A lightweight working session for tech + risk

Use a 60–90 minute workshop per critical AI-enabled service:

1. Map — users, data, systems, vendors, regions
2. Fail — top five failure and misuse scenarios
3. Detect — which signals exist today vs missing
4. Respond — who decides to disable AI, rotate keys, or communicate
5. Test — one exercise you will run in the next quarter
6. Exit — how painful is vendor replacement on paper vs in the repo

Capture owners and dates. Revisit after major architecture changes.

What this guide deliberately omits

To stay accurate and humble:

• Entity scoping and exemption analysis
• Supervisory reporting templates and timelines
• Detailed mapping to articles/recitals
• Audit programmes or “DORA compliance checklists” that imply certification

If you need those, engage your compliance team and qualified advisors, and read the official materials.

Related RemoteGeek Hub resources

• AI Risk Assessment Checklist
• AI Vendor Risk Assessment Guide
• Identity & Access Management Risk Checklist

Treat resilience as a product property: measurable, testable, and owned — whether or not a regulator is watching this quarter.