ICT Risk Management Framework Under DORA

DORA mandates that financial entities establish comprehensive ICT risk management frameworks addressing governance, strategy, risk processes, and documentation. Unlike principle-based requirements in earlier guidance, DORA specifies concrete obligations that regulators will assess directly.

Governance Requirements

Management body accountability represents a core DORA principle. The board or equivalent governing body must approve ICT strategy and risk management frameworks. They must oversee ICT risk management implementation and ensure adequate resources. Board members require sufficient knowledge and competence to understand ICT risks, necessitating ongoing training programs.

Personal liability provisions mean that management cannot simply delegate ICT risk to technical staff. Failures to ensure appropriate governance can result in individual enforcement action against directors and senior managers.

Framework Elements

ICT strategy must align with overall business strategy while specifically addressing digital operational resilience objectives. The strategy should document planned technology transformation, anticipated technology dependencies, and resilience capabilities required to support business continuity.

ICT risk appetite must be explicitly defined, documented, and approved by management. This includes quantitative tolerance levels for availability, recovery time, and acceptable risk exposure. Metrics must enable meaningful measurement against appetite. Escalation thresholds trigger management attention when risk levels approach or exceed defined tolerances.

Risk Management Processes

DORA requires systematic processes across the risk management lifecycle. Asset identification and classification must catalog ICT assets and their criticality to business functions. Risk identification processes must systematically identify threats and vulnerabilities affecting ICT assets.

Risk assessment must analyze identified risks considering likelihood and potential impact. Risk treatment must address identified risks through mitigation, transfer, or documented acceptance. Ongoing monitoring must track risk levels and control effectiveness. Regular review cycles must reassess risks as the organization and threat landscape evolve.

Documentation Requirements

DORA requires comprehensive documentation including ICT risk registers cataloging identified risks, their assessment, and treatment status. Business impact analyses must document the consequences of ICT disruptions on business functions. ICT continuity plans must detail maintaining operations during disruptions.

Response and recovery plans must specify how the organization will detect, respond to, and recover from ICT incidents. All documentation requires at minimum annual review, with additional review following significant changes or material incidents.