From Panic to Prepared: How To Become DORA Compliant

Following on from our blog post in September, Finding Dora. DORA sets a new standard for how financial institutions and service providers within the EU should handle their digital operations. With the growing threats of cyber-attacks and ICT disruptions, DORA mandates that organisations be capable of withstanding and recovering from cyber security incidents to ensure operational continuity. One of the most critical aspects of DORA’s regulatory framework is the focus on Incident Response (IR) and preparedness. For organisations to meet DORA’s requirements and safeguard their operations, a strong, well-structured IR capability is essential.

Why Incident Response Matters for DORA Compliance

DORA explicitly addresses the importance of having a proactive and responsive approach to ICT-related incidents. Financial entities are required not only to manage and mitigate risks but also to ensure rapid recovery when disruptions occur. This is where IR becomes highly relevant. Organisations need to be able to respond to incidents swiftly and effectively to minimise downtime, protect sensitive data, and maintain business continuity.

Under DORA, financial entities must follow a structured timeline for reporting major ICT related incident occurs in line with Article 19. The process begins with an initial notification, which must be submitted to the competent authorities within 4 hours of identifying the incident as major, but no later than 24 hours from the moment the organisation has become aware of the incident. This notification provides essential details, such as the nature of the incident and its immediate potential impact. Following this, an Intermediate Report must be submitted within 72 hours from the submission of the initial notification. This report should be submitted even where the status of the incident has not changed. Finally, once the incident is resolved, a Final Report is required to be submitted within one month, outlining the root cause, all corrective measures implemented, and any lessons learned from the incident Without an effective IR strategy in place, companies risk failing to meet these tight deadlines, which could result in regulatory penalties, reputational damage, and operational setbacks. Incident response isn’t just a security function but a critical compliance component under DORA.

Preparing Your Incident Response Capability for DORA

To align your incident response capability with DORA’s requirements, organisations should focus on the following five key areas:

• Have a plan. Organisations should begin by creating or reviewing and updating their existing incident response plan. Article 17 emphasises the need for organisations to implement relevant processes and procedures that facilitate consistent and integrated monitoring, management, and follow-up of ICT-related incidents. This plan should detail how the organisation will effectively identify, classify (Article 18), document, and address the root cause of incidents, ensuring a structured approach to incident management.

• Decide how to communicate the incident. Organisations must establish clear protocols for how incidents will be communicated both internally and externally. This includes documenting the reporting process as outlined in Article 19. Having prepared statements or templates in place can significantly aid the organisation’s response, ensuring that key stakeholders are informed promptly and accurately.

• Investigation Capabilities. When organisations lack the in-house capability to conduct digital investigations into the root causes of incidents, it is crucial to seek external expertise. Given the strict timelines mandated by DORA, organisations must be able to respond quickly and efficiently to gather the necessary information that supports their response and recovery efforts. Engaging with specialised partners ensures that investigations are thorough and timely, allowing for a swift resolution. Additionally, any insights gained from these investigations can be shared, as per Article 45, and integrated back into the organisation’s detection capabilities.

• Validate the plan. Organisations must ensure that key stakeholders are fully aware of their roles and responsibilities when a suspected incident is detected. Given the stringent timelines for submitting reports to the competent authority it is crucial for the incident response team to conduct regular exercises at least annually as stated in Article 11. These exercises will reinforce understanding of the organisation’s incident response process, ensuring that all team members are prepared to act swifty and effectively in the event of an incident.

• Detection, Response, and Recovery. Organisations must possess the capability to detect, respond to, and recovery from cyber security incidents effectively. To identify abnormal or malicious behaviours, it is crucial for organisations to first establish a clear understanding of what constitutes normal behaviour and configurations within their systems. Article 10 and Article 11 underscores the necessity for organisations to implement robust detection and response mechanisms, enabling them to swifty address incidents and minimise their impact on both the organisation and any third parties impacted.

Incident Response is at the heart of ensuring compliance with DORA’s requirements. Organisations must not only prepare for inevitable disruptions but also ensure that their IR capabilities are robust, responsive, and compliant with regulatory mandates. By focusing on how the organisation will detect, respond, and recovery from cyber security incidents the business can build the operational resilience needed to meet DORA’s standards and maintain business continuity in the face of digital threats.

How can MDSec Help?

MDSec provides a suite of proactive and reactive IR services designed to help your organisation achieve compliance with DORA. Our experienced IR team will work closely with you to establish the necessary processes and procedures to ensure compliance. Once these documents are in place, we can assess and test your incident response capabilities, ensuring that your team understand their roles and responsibilities when handling cyber security incidents.

Beyond preparation, MDSec are also ready to respond swifty to assist in managing and investigating any suspected or confirmed cyber security threats.

To discuss your DORA requirements, please get in touch.