//DORA
EU Regulation 2022/2554For US ICT providers

DORA readiness for US firms serving EU financial services.

The Digital Operational Resilience Act applies to EU banks, insurers, investment firms and payment providers — and to the ICT providers they depend on. Verigo helps US technology and service companies meet the DORA requirements their EU financial customers now flow down, using the ISO 27001 and SOC 2 controls you already have.

At a glance
Applies in
European Union
In application since
17 January 2025
Who feels it
EU financial entities & their ICT providers
Structure
5 pillars of resilience
Jan 2025DORA applies across the EU
5Pillars of digital resilience
20+Types of financial entity in scope
Art. 30Mandatory ICT contract provisions
What DORA is

Resilience, regulated.

DORA is an EU regulation, directly applicable in every member state, that requires financial entities to withstand, respond to and recover from ICT disruption — and to manage the risk created by their technology providers.

You may not be a regulated EU entity yourself, but if you sell software, cloud, data or managed services to one, your customer must assess you, put specific clauses in your contract, record you in its register of information, and monitor you over time. Being ready for that scrutiny is now a condition of winning and keeping EU financial-services business.

Your EU customers must include DORA Article 30 provisions in ICT contracts
Expect due diligence, audit rights, incident notification and exit-plan requirements
Providers designated as critical (CTPPs) face direct EU oversight
The five DORA pillars

What DORA asks for.

ICT risk management

Governance, a documented ICT risk framework, protection, detection, response and recovery.

Incident management & reporting

Classifying ICT-related incidents and reporting major ones to regulators on strict timelines.

Resilience testing

A risk-based testing programme, including threat-led penetration testing for significant entities.

ICT third-party risk

Due diligence, contract provisions, register of information, concentration risk and exit strategies.

Information sharing

Voluntary exchange of cyber threat intelligence within trusted communities.

How Verigo delivers DORA

Four steps, one accountable team.

Engage any single stage or the whole journey. Every engagement reuses the controls and evidence you already have, and runs on Verigo Assure so compliance stays current after we finish.

01

DORA gap assessment

Map your existing ISO 27001 / SOC 2 controls to the DORA requirements your EU customers will test.

Control-by-control DORA mapping
Prioritised remediation roadmap
Evidence reuse plan
02

Contract & due-diligence readiness

Prepare for Article 30 clauses, security questionnaires and audit-right requests before they arrive.

Article 30 clause review checklist
Standard DORA due-diligence response pack
Sub-contractor (fourth-party) inventory
03

Incident & resilience processes

Incident classification and customer-notification procedures, plus a resilience testing plan that supports your customers.

Incident notification runbook
Business continuity & recovery testing plan
Exit and transition support plan
04

Ongoing assurance

Keep evidence current for annual customer reviews — on Verigo Assure, alongside your other frameworks.

Continuous evidence on Verigo Assure
Annual customer review support
Regulatory change tracking
The DORA journey

From scoping to ongoing assurance.

Indicative phases and durations. Your plan is scoped to your services, existing controls and deadlines.

Wk 1
Scope
Which EU customers, services and data flows are in scope.
Wk 2–4
Gap assessment
Map current controls to DORA requirements.
1–3 mo
Remediate
Policies, procedures, contract and incident readiness.
Ongoing
Test
Continuity, recovery and incident exercises.
Annual
Assure
Customer reviews, audits and register updates.
Verigo Assure

Keep DORA evidence current, not just audit-ready once.

Our compliance platform keeps controls, evidence and owners in one place and flags gaps before they become findings. Included with Verigo consulting engagements.

DORA questions

Good to know before we start.

Questions about scope, timelines or how DORA fits with your existing frameworks? A senior practitioner will walk you through it.

DORA directly regulates EU financial entities. US companies are affected when they provide ICT services to those entities: your customers must apply DORA requirements to you through due diligence and contract terms, and a small number of providers may be designated as critical ICT third-party providers subject to direct EU oversight.

They are a strong foundation and cover much of the ICT risk-management ground, but DORA adds specific expectations around incident classification and notification, resilience testing, sub-contracting, exit strategies and contract content. Our gap assessment shows exactly what you can reuse and what you need to add.

EU financial entities must include specific provisions in ICT contracts — for example service descriptions, data location, security standards, incident assistance, audit and access rights, and termination and exit arrangements. We help you prepare standard positions so negotiations move faster.

For a provider with an existing ISO 27001 or SOC 2 programme, a typical engagement runs two to four months from gap assessment to customer-ready documentation, depending on scope.

Ready to begin?

Selling into EU financial services?

Tell us which EU customers and services are in scope. We will map your current controls to DORA and show you the fastest route to customer-ready evidence.