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ARTICLE · 07 JULY 2026

Would Your Firm Pass A CySEC DORA Inspection Today?

AGPLAW | A.G. Paphitis & Co. LLC
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Cyprus financial services firms face a new era of digital operational resilience supervision as CySEC shifts focus from policy preparation to practical implementation, evidence-based governance, and third-party ICT oversight under DORA. Recent circulars C751 and C784 make clear that regulated entities must now demonstrate operational compliance through documented frameworks, incident readiness, and board-level accountability rather than merely maintaining policies on paper.

CyprusStrategy
Angelos Paphitis
Angelos Paphitis
Mihaela Neagu
Mihaela Neagu
Andrea Hadjigeorgiou
Andrea Hadjigeorgiou
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Audit findings must not remain theoretical: firms must maintain a formal follow-up process for timely verification and remediation of critical ICT audit findings.

A Practical Analysis of CySEC Circulars C700 and C751 and the New Reality of Digital Operational Resilience Compliance

Cyprus financial services firms are entering a new phase of digital operational resilience supervision. The Digital Operational Resilience Act, known as DORA, has moved beyond the stage of general policy preparation. The regulatory focus is now shifting towards implementation, evidence, governance, incident readiness and third-party ICT oversight.

This is particularly clear from CySEC Circular C751, issued in January 2026, which reminds regulated entities of their obligations under DORA in relation to reporting, governance and CySEC portal-related requirements. The circular applies to a broad range of CySEC-regulated entities, including CIFs, CASPs, AIFMs, UCITS management companies, trading venues

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