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ARTICLE · 14 MAY 2025

DORA In 2025: Navigating Post-Deadline Challenges And The Road Ahead

The Digital Operational Resilience Act (DORA) became fully applicable nearly four months ago, requiring financial organisations to enhance operational resilience across key areas like governance, risk, incident...

United StatesFinance and Banking

The Evolving Implementation Landscape

The Digital Operational Resilience Act (DORA) became fully applicable nearly four months ago, requiring financial organisations to enhance operational resilience across key areas like governance, risk, incident, and third-party management. Financial Institutions (FIs) are now navigating a landscape proving far more complex than anticipated. What was expected to be a straightforward transition has instead evolved into a dynamic, multi-phase journey marked by continued regulatory developments, varied supervisory maturity, and a rapidly adapting market ecosystem.

Non-compliance with DORA requirements, including those related to preventing and managing cybersecurity failures, carries the risk of significant penalties from competent authorities (such as national regulators and the European Supervisory Authority (ESA)), encompassing financial fines (potentially up to 2% of annual worldwide turnover), administrative measures, and possible criminal

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