DORA-compliant fintech software: operational resilience, not aspirational.
DORA (Digital Operational Resilience Act, EU Reg. 2022/2554) applies from 17 January 2025 to the entire EU financial sector: banks, insurance, fintech, funds, crypto-asset, and their critical ICT providers. Software entering production must support DORA requirements: ICT risk management, incident reporting, resilience testing, third-party risk.
What happens today.
DORA is in full application: the entire EU financial sector must have implemented an ICT risk-management framework, a major-incident reporting process within RTS deadlines, a periodic resilience-testing program, and structured third-party risk management. Software running in these companies must support these requirements.
Building DORA-compliant fintech software means integrating structured audit log (for incident reporting), business-continuity controls (defined RTO/RPO, tested DR plan), vulnerability management (for resilience tests), reporting interfaces to authorities (Bank of Italy, EBA, CONSOB).
Resilience is not written in policies. It is measured on the systems that hold when something goes wrong.
The solution, broken into parts.
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Integrated ICT risk management
We implement the DORA ICT risk-management framework controls: asset identification, threat modeling, applied technical controls, continuous monitoring, vulnerability management. Structured output for the company framework.
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Business continuity + DR
Multi-zone or multi-region architecture, RTO/RPO defined per component, DR plan tested periodically, backup encryption, recovery within documented timeframes. Evidence ready for supervisory audits.
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Structured incident reporting
Structured audit log of ICT incidents with automatic severity classification. Interfaces to extract the data required by the DORA incident report (incident classification, root cause, impact, mitigation actions, recovery time).
The typical profiles who benefit.
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Fintech with institutional clientele
Fintech, paytech, lending, wealth, crypto-asset service providers with institutional clientele or retail users. DORA is full-scope from 2025.
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ICT providers to the finance sector
ICT companies providing critical services to banks, insurance, fintech: cloud providers, vertical software houses, payment processors. May be designated as "critical ICT third-party service providers" (CTPP) under direct EBA/EIOPA supervision.
Transparency on what the client does.
Before we start we need a few accesses and decisions. All reasonable, no surprise asks.
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DORA scoping
- Entity classification (financial entity, ICT third-party provider, CTPP)
- Existing or in-progress ICT risk-management framework
- CISO/CIO as interlocutor for technical decisions
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Software to build
- Functional scope and criticality (core operations, accessory services)
- Possible integrations with core supervisory systems
- 24/7 operations constraints and related SLA metrics
Indicative numbers, not quotes.
- TIME
- Typically 6-12 months for medium fintech software. DORA compliance adds 25-35% to the time of an equivalent non-regulated project.
- COST
- Range €100,000-500,000 depending on criticality and complexity.
- MODEL
- Fixed milestones with threat modeling, business-continuity plan, and penetration testing as separate deliverables.
Indicative numbers. For an accurate quote, let's talk.
Answers to the most common questions.
Does DORA apply to fintech SMEs as well?
Yes, DORA has no general size thresholds: it applies to all financial entities in scope (banks, insurance, fintech, fund managers, crypto-asset providers, etc.). Proportionality exists in the requirements: a small fintech does not have the same obligations as a systemic bank. The DORA framework should be scaled proportionally.
NIS2 vs DORA for finance: what is the difference?
DORA is lex specialis for finance and prevails where there is overlap. NIS2 applies generally to the sector (essential banks), but DORA introduces specific and stricter requirements on ICT risk management and third-party risk. For financial entities, DORA is the primary reference; for non-financial ICT providers, NIS2 still applies.
Do you handle contracts with third-party ICT providers?
No, contract negotiation with third-party ICT providers (one of the main DORA points) is legal/compliance matter, handled by your Legal/Compliance Officer. We provide technical evidence on the software, support technical due diligence of ICT providers, build the required monitoring interfaces.
Recognize your case?
Write a couple of lines about your context. We'll reply within 24-48 hours with an initial assessment and a first orientation on time and cost.
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