DORA compliance checklist: key steps for seamless implementation

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General Counsel

Nov 20, 2025

5 min. read

DORA compliance checklist: key steps for seamless implementation

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DORA compliance checklist: key steps for seamless implementation

In this article

Let’s be real for a second: most cybersecurity “strategies” in finance still rely on good intentions and a few dusty PDFs. But regulators have officially lost patience with the theatre. The Digital Operational Resilience Act (DORA)has become the EU’s way of saying:

“You don’t get to wing it anymore“.

DORA is here to test what your resilience actually looks like under pressure. Not just on paper. Not just after a penetration test. But when systems go down, vendors fail, or ransomware hits on a Friday afternoon.

That’s where this DORA compliance checklist comes in. I designed it to help you cut through the legal jargon and focus on what matters: structure, accountability, testing, and readiness.

Why DORA compliance really matters

DORA isn’t just another regulatory checkbox. It’s a wake‑up call: your systems, vendors, and processes must withstand disruption, not just hope it never happens.

The European Union’s regulation demands that banks, insurers, investment firms and their ICT (Information and Communication Technology) service providers prove they can manage digital disruption — from cyber‑attack to service‑outage.

Put simply: resilience isn’t about feeling safe. It’s about being safe when everything’s hit the fan.

What you need to do (yes, you)

You’ve downloaded the DORA regulation checklist — good move. Now here’s how you act on it, without freezing the whole organisation in the name of compliance. Here’s what you need to internalise:

Governance & leadership

The CEO, board, senior team — they have to own this. DORA expects leadership oversight, assigned responsibilities, and operational structure. If leadership treats resilience as “IT’s problem”, you’re already behind.

Seriously: tie digital‑resilience metrics into the board dashboard. One or two clear KPIs (like mean time to detect ICT incidents) make this real.

ICT risk management

You can’t wait for something to break and then say “oops”. You must map your critical systems, assess cyber‑attack threats, vendor dependencies and monitor continuously. Too many organisations treat risk management like a once‑a‑year checklist. DORA demands something active.

Incident response & escalation

If you don’t know what you’ll do when an incident happens, then you’re gambling. DORA requires detection tools, incident classification, escalation to senior management/regulators, and post‑incident review. No fudge‑factor.

Third‑party / vendor risk

Here’s the weak link in many firms: you secure your own house, but your vendors’ doors are wide open. DORA mandates proper vendor risk assessment, contract terms around resilience, and continuous oversight. If your vendor fails, you fail.

Business continuity & recovery

It’s not enough to “recover eventually”. DORA wants you to define Recovery‑Time Objectives (RTOs), Recovery‑Point Objectives (RPOs), test your plans, and update them. Your business continuity plan must be usable — not a PowerPoint gathering dust.

Audit, documentation, improvement

You’ll need records: risk assessments, incident reports, vendor reviews, tests, audits. And not just “we did one” — you need improvement loops. DORA makes this explicit.

The mindset shift you need

Here’s where many organisations trip up: they treat DORA compliance as one more project. It’s not. It’s a mindset change. Resilience becomes operational practice. If you’re still managing your vendor list in Excel, or your “incident‑response plan” is a 10‑year‑old document nobody has touched — stop. That’s archaeology. You’re not doing compliance; you’re caveman‑writing it.

You don’t have to be perfect. DORA isn’t expecting faultless. It is expected that you can bounce back, adapt, and learn.

When disruption hits, good intentions won’t cut it. You need proof.

Why Copla Is the Smart Way to Do DORA and NIS2 Compliance

Copla is built for teams that want DORA and NIS2 compliance without burning out their staff or their budget. By pairing an automation-first platform with expert CISOs, Copla delivers 4 main advantages:

  1. Helps to reduce compliance workload by up to 80%
  2. Automates key DORA and NIS2 compliance tasks
  3. Guides you through the compliance process step-by-step
  4. Provides CISO-level leadership without the overhead

On top of that, clients typically save over €60K per year compared to hiring in-house staff to handle the same compliance workload, while staying continuously audit-ready.

FAQ

  • What is a DORA compliance checklist? +

  • Why is the DORA checklist important for audits? +

  • Is there an official template for the DORA checklist? +

  • Can small firms use a simplified DORA checklist? +

  • How often should the DORA checklist be reviewed or updated? +

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General Counsel

He is regulatory compliance strategist with over a decade of experience guiding fintech and financial services firms through complex EU legislation. He specializes in operational resilience, cybersecurity frameworks, and third-party risk management. Nojus writes about emerging compliance trends and helps companies turn regulatory challenges into strategic advantages.
  • DORA compliance
  • EU regulations
  • Cybersecurity risk management
  • Non-compliance penalties
  • Third-party risk oversight
  • Incident reporting requirements
  • Financial services compliance

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