DORA Started. Do You Have the ICT Third-Party 'Register of Information' Ready?

DORA Started. Do You Have the ICT Third-Party 'Register of Information' Ready?

The Digital Operational Resilience Act (DORA) is now in effect as of January 17, 2025, and financial entities across the EU are scrambling to meet the stringent new requirements for ICT third-party risk management. If you're a bank, fintech, insurer, payment service provider, or ICT vendor serving EU financial services, you need to establish a comprehensive 'Register of Information' immediately.

This isn't just another compliance checkbox—DORA represents a fundamental shift in how financial institutions must manage their ICT third-party relationships. The stakes are high: non-compliance can result in significant penalties and reputational damage, while proper implementation can strengthen your operational resilience and competitive advantage.

DORA Started: What This Means for Your Organization

The Digital Operational Resilience Act (DORA) has officially commenced, introducing the most comprehensive ICT risk management framework ever implemented in the European Union. This regulation affects over 22,000 financial entities, including banks, insurance companies, investment firms, payment service providers, and critical ICT third-party service providers.

Who Must Comply with DORA?

DORA applies to a wide range of financial entities:

• Credit institutions and investment firms
• Insurance and reinsurance undertakings
• Payment service providers and electronic money institutions
• Central counterparties and central securities depositories
• Critical ICT third-party service providers designated by ESAs
• Crypto-asset service providers and issuers

Key DORA Requirements at a Glance

DORA introduces five main pillars of operational resilience:

1. ICT Risk Management - Comprehensive risk management frameworks
2. Incident Reporting - Mandatory reporting of ICT-related incidents
3. Digital Operational Resilience Testing - Regular testing of ICT systems
4. Information Sharing - Enhanced information sharing mechanisms
5. Third-Party Risk Management - Strict oversight of ICT third-party relationships

The 'Register of Information' falls under the third-party risk management pillar and is one of the most critical compliance requirements for financial entities.

Understanding the ICT Third-Party Register Requirements

The 'Register of Information' is not just a simple list of vendors—it's a comprehensive database that must capture every aspect of your ICT third-party relationships. This register serves multiple strategic purposes beyond mere compliance.

Why the Register of Information Matters

Your register of information serves as:

• Risk Assessment Tool - Enables systematic evaluation of ICT third-party risks
• Regulatory Compliance Mechanism - Demonstrates adherence to DORA requirements
• Operational Resilience Foundation - Identifies critical dependencies and concentration risks
• Business Continuity Planning Resource - Supports incident response and recovery planning
• Strategic Decision-Making Aid - Informs vendor selection and contract negotiations

Regulatory Timeline and Deadlines

Understanding the compliance timeline is crucial:

Essential Components of Your Register of Information

Creating an effective register of information requires careful attention to detail. Each component serves a specific purpose in your overall ICT risk management strategy.

1. Provider Information

The provider section must capture comprehensive details about each ICT third-party service provider:

• Legal Entity Name - Official registered name
• Legal Entity Identifier (LEI) - Unique 20-character identifier
• Registration Number - Company registration details
• Headquarters Address - Primary business location
• Contact Information - Key personnel and communication channels
• Regulatory Status - Any relevant licenses or authorizations

2. Service Description

Detailed service descriptions enable accurate risk assessment and dependency mapping:

• Service Category - Type of ICT service (cloud, software, infrastructure, etc.)
• Service Scope - Detailed description of services provided
• Service Level Agreements - Performance metrics and guarantees
• Geographic Coverage - Regions where services are provided
• Service Dependencies - Other services or providers required

3. Data Types and Processing

Understanding data flows is essential for compliance with data protection regulations:

• Personal Data Categories - Types of personal information processed
• Financial Data Types - Payment, transaction, and account information
• Sensitive Data Classification - Confidential or restricted information
• Data Processing Purposes - Why data is collected and used
• Data Retention Periods - How long data is stored
• Data Location - Where data is stored and processed

4. Criticality Assessment

Criticality assessment determines the importance of each service to your operations:

• Critical Function Support - Whether service supports critical business functions
• Important Function Support - Whether service supports important business functions
• Business Impact Rating - Potential impact of service disruption
• Recovery Time Objectives - Maximum acceptable downtime
• Recovery Point Objectives - Maximum acceptable data loss

5. Exit Strategy and Contractual Provisions

Exit planning is crucial for operational resilience and business continuity:

• Contract Termination Clauses - Notice periods and termination conditions
• Data Portability Requirements - How to retrieve data upon termination
• Transition Planning - Steps for service migration
• Exit Costs - Financial implications of termination
• Alternative Providers - Backup options and contingency plans

Step-by-Step Implementation Guide

Implementing your register of information requires a systematic approach. Follow this step-by-step guide to ensure comprehensive coverage and compliance.

Phase 1: Discovery and Inventory

Step 1: Identify All ICT Third-Party Relationships

Begin by conducting a comprehensive audit of all ICT third-party relationships:

• Review all active contracts and service agreements
• Identify sub-outsourcing arrangements
• Document indirect relationships through primary vendors
• Include both critical and non-critical services

Step 2: Categorize Services by Criticality

Classify each service based on its importance to your operations:

• Critical Services - Essential for core business functions
• Important Services - Significant impact on operations
• Supporting Services - Limited impact on core functions

Phase 2: Data Collection and Documentation

Step 3: Gather Provider Information

Collect comprehensive information about each provider:

• Request updated company information and certifications
• Verify legal entity identifiers and registration details
• Document contact information and escalation procedures
• Review regulatory status and compliance certifications

Step 4: Document Service Details

Create detailed service descriptions for each relationship:

• Define service scope and deliverables
• Document service level agreements and performance metrics
• Identify service dependencies and integration points
• Map geographic coverage and data processing locations

Phase 3: Risk Assessment and Analysis

Step 5: Conduct Risk Assessments

Evaluate risks associated with each third-party relationship:

• Assess financial stability and business continuity capabilities
• Evaluate cybersecurity posture and incident response procedures
• Review data protection and privacy compliance
• Analyze concentration risks and dependency levels

Step 6: Develop Risk Mitigation Strategies

Create risk mitigation plans for identified vulnerabilities:

• Implement additional monitoring and oversight measures
• Develop contingency plans and alternative arrangements
• Establish enhanced reporting and communication protocols
• Create incident response and recovery procedures

Phase 4: Implementation and Maintenance

Step 7: Deploy Register Management System

Implement systems and processes for ongoing register management:

• Choose appropriate technology platform or spreadsheet solution
• Establish data governance and quality control procedures
• Create user access controls and approval workflows
• Implement regular review and update schedules

Step 8: Establish Monitoring and Reporting

Create ongoing monitoring and reporting capabilities:

• Implement regular provider performance reviews
• Establish incident reporting and escalation procedures
• Create management reporting and dashboard capabilities
• Develop regulatory reporting templates and processes

Aligning DORA with ISO 27001 and ISO 22301 Standards

Integrating DORA requirements with existing ISO standards can streamline compliance efforts and enhance overall risk management effectiveness.

ISO 27001: Information Security Management

ISO 27001 provides a systematic approach to managing sensitive company information, ensuring its security through a comprehensive information security management system (ISMS).

Key Alignment Points:

• Risk Assessment - Both frameworks require systematic risk identification and assessment
• Vendor Management - ISO 27001's supplier relationship management aligns with DORA's third-party requirements
• Incident Management - Both require robust incident response and reporting procedures
• Continuous Monitoring - Regular review and update of security controls and risk assessments

ISO 22301: Business Continuity Management

ISO 22301 focuses on business continuity management systems, helping organizations prepare for, respond to, and recover from disruptive incidents.

Key Alignment Points:

• Business Impact Analysis - Critical for determining service criticality levels
• Recovery Planning - Essential for developing exit strategies and contingency plans
• Testing and Exercising - Regular testing of business continuity plans and procedures
• Communication Management - Coordinated communication during incidents and disruptions

Integrated Compliance Approach

Our InfoSec (ISO 27001) and Business Continuity (ISO 22301) Toolkit provides:

• Ready-to-Use Registers - Pre-populated templates aligned with DORA requirements
• Comprehensive Policies - Integrated policies covering ICT risk management and business continuity
• Incident Runbooks - Detailed guides for incident response and recovery
• Assessment Tools - Risk assessment templates and criticality evaluation frameworks
• Training Materials - Staff training resources for DORA compliance and ISO implementation

By leveraging our comprehensive compliance toolkit, you can accelerate your DORA compliance journey while building a robust foundation for long-term operational resilience.

Common Implementation Challenges and Solutions

Implementing DORA compliance presents several common challenges. Understanding these challenges and their solutions can help ensure successful implementation.

Challenge 1: Incomplete Third-Party Inventory

Problem: Many organizations struggle to identify all ICT third-party relationships, particularly indirect relationships through primary vendors.

Solution:

• Conduct comprehensive contract reviews and vendor interviews
• Implement vendor self-reporting requirements for sub-outsourcing
• Use network mapping tools to identify indirect relationships
• Establish ongoing monitoring and discovery processes

Challenge 2: Inconsistent Data Quality

Problem: Register data often lacks consistency, completeness, and accuracy, making risk assessment difficult.

Solution:

• Implement data governance frameworks and quality control procedures
• Establish standardized data collection templates and validation rules
• Create regular data review and update schedules
• Implement automated data validation and consistency checks

Challenge 3: Resource Constraints

Problem: Limited resources and expertise can hinder effective implementation of DORA requirements.

Solution:

• Leverage existing ISO 27001 and ISO 22301 frameworks and resources
• Use our comprehensive toolkit to accelerate implementation
• Prioritize critical and important services for initial focus
• Consider external expertise and consulting support

Challenge 4: Technology Integration

Problem: Integrating DORA requirements with existing systems and processes can be complex.

Solution:

• Choose technology platforms that support both DORA and ISO requirements
• Implement phased rollout approaches to minimize disruption
• Ensure proper data integration and synchronization capabilities
• Provide comprehensive training and change management support

DORA Compliance Checklist

Use this comprehensive checklist to ensure your organization meets all DORA requirements for ICT third-party risk management.

Next Steps: Strengthening Your ICT Risk Management

DORA compliance is not a one-time exercise but an ongoing commitment to operational resilience. Here's how to move forward effectively.

Immediate Actions (Next 30 Days)

• Download Our CSV Starter Template - Begin building your register immediately
• Conduct Initial Vendor Inventory - Identify all ICT third-party relationships
• Assess Current Capabilities - Evaluate existing risk management frameworks
• Develop Implementation Plan - Create detailed project plan and timeline

Short-Term Goals (Next 90 Days)

• Complete Register Development - Build comprehensive register of information
• Implement Risk Assessment Procedures - Establish systematic risk evaluation processes
• Develop Incident Response Plans - Create robust incident management procedures
• Begin Staff Training - Educate teams on DORA requirements and procedures

Long-Term Objectives (Next 12 Months)

• Full DORA Compliance - Achieve complete compliance with all requirements
• Integrated Risk Management - Seamlessly integrate DORA with ISO standards
• Enhanced Operational Resilience - Strengthen overall resilience capabilities
• Continuous Improvement - Establish ongoing enhancement and optimization processes

Leveraging Our Toolkit for Success

Our InfoSec (ISO 27001) and Business Continuity (ISO 22301) Toolkit provides everything you need for successful DORA implementation:

• Ready-to-Use Templates - Pre-populated registers, policies, and procedures
• Comprehensive Documentation - Detailed guides and implementation resources
• Training Materials - Staff education and awareness resources
• Ongoing Support - Continuous guidance and best practice updates

By leveraging our toolkit, you can accelerate your DORA compliance journey while building a robust foundation for long-term operational resilience.

Download Your CSV Starter Template

Ready to get started? Download our comprehensive CSV starter template that includes all the essential columns for your DORA register of information:

Conclusion

DORA represents a fundamental shift in how financial institutions must approach ICT third-party risk management. The 'Register of Information' is not just a compliance requirement—it's a strategic tool that can enhance your operational resilience, improve risk management, and strengthen your competitive position.

By implementing a comprehensive register of information and aligning it with ISO 27001 and ISO 22301 standards, you can not only meet DORA requirements but also build a robust foundation for long-term operational resilience.

Don't wait until the April 30, 2025 deadline approaches. Start building your register of information today using our comprehensive toolkit and CSV starter template. Your organization's operational resilience depends on it.