The Digital Operational Resilience Act (DORA) officially came into force in January 2025. It sets strict expectations for how financial institutions handle ICT risk, incident reporting, resilience testing, and third-party oversight.
If you already use ISO 27001 for your information security management, you’re not starting from scratch. A DORA–ISO 27001 mapping helps you connect what you already have with what DORA now requires.
By mapping the two frameworks, you can avoid duplicated work, identify gaps, and create a clear roadmap for continuous improvement. With a structured mapping template, your existing ISMS (Information Security Management System) becomes a DORA-ready framework for operational resilience.
Or, as I like to say, you can finally stop juggling checklists and start building absolute continuity.
What DORA adds to ISO 27001
ISO 27001 already provides a strong foundation for managing information security. It focuses on leadership involvement, risk-based thinking, and continuous improvement. But DORA adds layers of accountability, testing, and reporting that push organisations from secure to resilient.
As Recital 12 of the official DORA Regulation (EU 2022/2554) explains:
“This Regulation aims to consolidate and upgrade ICT risk requirements as part of the operational risk requirements that have, up to this point, been addressed separately in various Union legal acts… all provisions addressing digital risk in the financial sector should, for the first time, be brought together consistently in one single legislative act.”
— EUR-Lex DORA Regulation
Here’s what that means in practice.
Governance and accountability
ISO 27001 expects top management to establish and oversee the ISMS. DORA takes it further by making boards personally accountable for ICT risk. Governance now includes a culture of resilience, not just policies.
Incident management
ISO 27001 focuses on detection, escalation, and post-incident review. DORA adds tight regulatory deadlines and harmonised templates for notifying supervisors, meaning existing ISO processes must be adapted for external reporting.
Third-party risk
ISO 27001 requires supplier management. DORA goes deeper, asking for subcontractor visibility, specific contractual clauses, and exit strategies. Vendor oversight moves from “manage suppliers” to “understand your entire ICT chain.”
Resilience testing
ISO 27001 requires regular control testing. DORA mandates resilience testing of critical systems, including threat-led penetration testing (TLPT) for significant entities. This is an entirely new level of assurance.
Registers and inventories
ISO 27001 expects an inventory of assets. DORA requires a Register of Information in machine-readable formats such as XML or CSV. It’s not just an internal list — it’s a regulator-ready record.
As the European Commission put it:
“The objective of DORA is to consolidate and upgrade ICT risk requirements across the financial sector to ensure that all participants are subject to a common set of standards.”
— European Commission, DORA Regulation
Common gaps in DORA–ISO 27001 mapping
When you run a structured DORA–ISO 27001 mapping (yes, there’s a PDF template for that), you usually uncover the same four gaps:
| Gap area | What ISO covers | What DORA adds |
| Regulatory incident reporting | Internal response and lessons learned | External reporting to supervisors within hours |
| Subcontractor oversight | Basic supplier management | Full subcontractor chain visibility and exit planning |
| Threat-led testing | Periodic control checks | Mandatory TLPT for critical ICT assets |
| ICT registers | Generic asset inventories | Structured XML/CSV register of information |
These differences may look small, but each one carries major operational implications. The mapping exercise turns them from hidden risks into clear, manageable actions.
How to run a mapping exercise
Start with the scope definition. Group DORA’s obligations into governance, risk, incident reporting, testing, outsourcing, and registers. Then, align each requirement with the corresponding ISO 27001 clauses or Annex A controls.
For each match, mark whether your current control provides full, partial, or no coverage.
A simple table format helps keep this visual.
| DORA requirement | ISO 27001 reference | Coverage status | Action required |
| Report incidents to regulator within timelines | A.16 – Information Security Incident Management | Partial | Add external reporting workflows and templates |
| Threat-led penetration testing for critical systems | Not explicitly covered | Gap | Create TLPT plan and schedule regular tests |
| Oversight of subcontractors in ICT outsourcing | A.15 – Supplier Relationships | Partial | Expand monitoring and contract terms for subcontractors |
| Register of Information in XML/CSV format | A.8 – Asset Management | Partial | Adapt register to DORA formats and automate updates |
This format turns a dense regulatory document into something usable by every stakeholder — management, auditors, and regulators alike.
Once complete, focus on the gaps. If incident reporting is weak, create escalation paths and templates. If supplier oversight is missing, update contracts and monitoring systems. If resilience testing is new territory, schedule TLPT exercises and include them in your audit cycle.
The goal isn’t just to complete the mapping. The goal is to turn it into a living action plan for resilience.
Why a mapping template helps
Building and maintaining a DORA–ISO 27001 mapping template delivers more than compliance convenience.
It gives you:
- Efficiency by reusing existing ISO 27001 processes.
- Clarity for audits and board discussions.
- Visibility into emerging risks.
- Resilience-first thinking that moves beyond checkbox compliance.
It also becomes a communication tool. Executives can instantly see where the company stands, regulators appreciate the transparency, and teams understand their responsibilities without needing legal translation.
From compliance to resilience
A DORA–ISO 27001 mapping is more than a spreadsheet. By aligning these two frameworks, you’re not just meeting regulatory expectations — you’re building operational resilience that lasts.
At Copla, we help organisations make this shift. Our automated registers, vendor oversight workflows, and DORA-specific micro-tools transform static documentation into continuous assurance.
With the right mapping, ISO 27001 stops being a certificate on the wall and becomes the living foundation of your DORA compliance strategy — and your company’s resilience story.
