The Digital Operational Resilience Act (DORA) will be enforced across all European Union Member States from January 2025. Introduced by the European Parliament, DORA is designed to enhance the cyber resilience of financial institutions such as banks, insurance firms, and investment managers, ensuring they can withstand and swiftly recover from cyber threats.
The financial sector increasingly relies on digital platforms, yet many organizations still depend on legacy systems vulnerable to modern cyber threats. Existing regulations like the PCI DSS standard and the NIS2 Directive offer some protection but primarily target tier-one banks, leaving smaller institutions exposed. DORA aims to close this gap by creating a unified framework that applies consistent standards across all financial entities and their critical ICT providers, ensuring a comprehensive approach to managing and mitigating ICT risk. This harmonized regulation seeks to fortify the entire EU financial ecosystem against disruptions.
ServiceNow provides a centralized platform to house and manage all the documents, processes, and audit trails required under DORA. This platform delivers a complete risk overview, mapping out critical functions, assets, and dependencies, including a specialized module for managing vendor risk. By moving away from spreadsheet-based management, firms gain access to a dynamic dashboard that highlights risks, mitigation plans, and resource allocations in real time—across both DORA and other relevant regulatory requirements. DXC, leveraging its proven track record, offers expert advisory services, implementation, and configuration of ServiceNow to meet specific client needs.
Let’s explore five key DORA compliance areas and how DXC and ServiceNow can support financial institutions in meeting them:
Under DORA, executives are no longer mere signatories of cybersecurity policies; they must be actively involved in strategy, resource allocation, and the execution of ICT risk management. The legislation mandates cybersecurity training for management, ensuring they understand and can effectively implement a firm's cybersecurity framework. This goes beyond the standard ICT security training required for all employees.
DORA’s requirements for accountability come with severe penalties. For instance, if a C-suite or board-level executive fails to report a technical vulnerability or breach promptly, they can face fines of up to €1 million. Similarly, if an incident occurs and is not reported, management could face fines of up to €500,000.
ServiceNow offers a single, transparent platform where firms can manage all aspects of risk, compliance, audits, SOC, and business continuity. Executives can monitor compliance status through real-time dashboards, which include metrics for incident likelihood, impact, and compliance scores. This ensures that all necessary data is visible and actionable, promoting a culture of continuous engagement and accountability at the executive level.
DORA requires a comprehensive risk-assessment framework that goes beyond traditional methods. Simply storing data in spreadsheets is insufficient; firms must identify risks, establish structured mitigation plans, and implement concrete follow-ups. DORA also mandates firms to classify critical functions and map dependencies throughout their financial systems, ensuring a robust approach to risk management.
ServiceNow provides a full overview of a firm's critical functions, assets, and dependencies, enabling firms to identify and mitigate risks efficiently. The platform’s automation and AI capabilities enhance IT resilience by leveraging existing data to optimize risk management strategies. By integrating this information into a centralized dashboard, ServiceNow offers firms a significant advantage, turning compliance into a competitive edge.
Financial institutions must be prepared to detect and respond to cyber threats instantly. DORA emphasizes the need for “pull-the-plug” infrastructure, allowing firms to disconnect affected branches or systems immediately when compromised. It also requires firms to have detailed incident management procedures that go beyond hiring quality SOC analysts; they must document compromise indicators, incident timelines, and lessons learned to continually enhance cybersecurity measures. Recovery plans must ensure operational continuity, necessitating an in-depth understanding of the firm's IT infrastructure.
ServiceNow facilitates structured crisis management by standardizing incident response procedures, such as those based on the NIS2 framework. Firms can perform tasks like isolating compromised hosts, disabling users, and conducting investigations directly within the platform. Additionally, ServiceNow supports the maintenance and update of business continuity and disaster recovery plans, ensuring that firms remain prepared for unexpected incidents. If key personnel leave, ServiceNow prompts firms to assign replacements, ensuring continuity in their response capabilities.
DORA places significant emphasis on managing risks associated with third-party vendors. Any financial institution outsourcing work for backend infrastructure, website integrations, or other critical services must ensure these vendors comply with DORA’s regulations, and they can expect more frequent audits as a result.
ServiceNow’s vendor risk management module automates the audit process, providing customizable workflows for managing third-party engagements—from due diligence and onboarding to offboarding. The dedicated third-party portal allows firms to co-manage risk-tiering assessments and request documentation like SOC reports and ISO certifications directly through the platform. By centralizing this information, ServiceNow eliminates the need for manual processes, reducing uncertainties and ensuring full compliance across all vendor relationships.
Existing regulations already require firms to manage vulnerabilities and apply fixes, but DORA raises the bar. Companies must build resilient infrastructures capable of withstanding cybersecurity breaches and quickly restoring services. This includes conducting annual penetration testing and, every three years, a more advanced threat-led penetration test.
ServiceNow centralizes risk assessments and mitigation strategies across all departments, providing a unified view of compliance activities. The platform enables firms to schedule and manage resilience tests, document outcomes, and track necessary follow-up actions. With this centralized approach, firms can effectively manage their testing routines, enhancing their overall security posture and ensuring that they meet DORA’s rigorous requirements.
The DORA deadline is rapidly approaching, and financial institutions must act now to ensure they have robust systems and processes in place. ServiceNow’s comprehensive platform, supported by DXC’s expertise, provides all the tools necessary for firms to achieve DORA compliance efficiently. From managing third-party risks to enhancing operational resilience through proactive testing, DXC and ServiceNow are ready to support your journey.
Get in touch with our team today to learn more about how DXC and ServiceNow can help your organization navigate the complexities of DORA compliance and secure a competitive advantage in the evolving financial landscape.