The Digital Operational Resilience Act
("DORA") applies to a wide range of
financial entities and is focused on ensuring that these entities
are able to respond effectively to unplanned information and
communication technology ("ICT")
disruption, while minimising the impact on their business and
customers.
In this briefing, we consider the impact of DORA for fund
managers and outline the requirements under DORA to manage and
mitigate ICT risk.
Does DORA apply to fund managers?
A wide range of financial entities are subject to DORA including
AIFMs (excluding sub-threshold AIFMs) and UCITS management
companies (referred to collectively as
"ManCos").
Non-EU AIFMs that manage and/or market AIFs in the EU may also
be in scope for DORA, subject to the proportionality principle
described below. It is hoped that this may be clarified in a
regulatory Q&A or other guidance.
