The DORA compliance journey begins with a technology and service inventory. Organisations should identify which applications, infrastructure components, data, and providers support critical or important functions. The inventory should include dependencies, data flows, privileged access, recovery options, and concentration risks rather than simply listing purchased software.
The second step is an ICT risk-management framework. Risk appetite, responsibilities, control objectives, monitoring metrics, and exception handling should be documented. Single points of failure, insufficient redundancy, incomplete asset records, weak access controls, and excessive supplier dependency are common priority areas.
The third step is incident management and reporting. Organisations should define how an incident is detected, classified, escalated, communicated, and closed. Incident records should include the affected service, customer impact, decisions, communications, root cause, and corrective actions, not only technical logs.
The fourth step is testing and improvement. Recovery exercises, scenario tests, and technical security tests reveal whether documented plans work in practice. Findings should be assigned to accountable owners, given target dates, and retested. The Commission’s DORA materials show that implementing and delegated acts add detail to the obligations [3]; organisations should therefore monitor current secondary rules and supervisory communications alongside the main regulation.