Digital Operational Resilience Act (DORA): Where Do We Stand?

Our Financial Services Briefing analyses the EU level developments regarding the Digital Operational Resilience Act (DORA) and their implementation in Greece, including:

A.   Consolidation of the Regulatory Framework and Activation of Oversight Mechanisms 
B.   Oversight of Critical ICT Third-Party Providers
C.   Incident Reporting and Data Quality
D.   Resilience Testing and TLPT
E.   Developments in Greece
F.   Outlook for 2026 and Beyond

Following a two-year implementation period after entering into force, the Digital Operational Resilience Act (Regulation (EU) 2022/2554 - DORA) became fully applicable in January 2025, setting a harmonized, directly applicable regulatory framework for digital operational resilience in the EU financial sector. A little over a year later, the focus is shifting from the definition of the regulatory framework to its implementation in practice. Supervisory expectations have become more concrete; the technical standards are now largely in place and