Recent months have brought major challenges for both financial sector entities and ICT service providers with the entry into force of the Digital Operational Resilience Act (DORA). As financial entities intensify their focus on operational resilience, DORA imposes new responsibilities on the third-party providers they rely on.
If you provide ICT services to the financial sector in the EU, DORA applies to you indirectly — yet very significantly. Here are five strategic takeaways to help you prepare, comply, and remain competitive.
1. Prepare Your Organisation
DORA brings ICT providers under the scrutiny of financial regulators like never before. Even if you're not directly regulated, your clients are — and they'll be required to assess your resilience, security protocols, and ability to recover from disruptions.
Preparing your organisation ahead of time is not just about compliance – it will facilitate more efficient and informed contract negotiations with your clients, give you a clearer understanding of their regulatory expectations, and help ensure that the mechanisms you use across different customers are consistent and coherent.
Conducting an internal gap analysis will go a long way in ensuring that you are well prepared to cooperate with the entities covered by the DORA requirements. Review your business continuity plans, exit strategies, and incident management frameworks. Do they align with what financial institutions will now be required to demand under DORA? Taking the time now to address these areas will position you as a reliable, regulation-ready partner.
2. Negotiate DORA-Compliant Arrangements That Fit Your Service Model
One of the more practical challenges is contract negotiation. DORA sets out mandatory contractual elements for ICT outsourcing arrangements — including incident response, audit obligations, and clear termination rights. Financial entities are also expected to ensure their ICT providers support broader DORA obligations — meaning you will likely be required to assist in implementing your clients' operational resilience measures.
The key here is alignment. Implementation of these requirements should be tailored to the nature and complexity of the services you provide. While some financial institutions may rely on generalised, "one-size-fits-all" terms, these will often require significant adjustment to be meaningful — or even workable — for certain ICT providers.
Negotiating in a way that reflects your specific services and operational realities ensures that you remain compliant, protect your business model, and avoid being boxed into unworkable commitments.
3. Review Existing Contracts with Financial Services Clients
DORA applies not only to new agreements but also to existing arrangements. This means contracts already in place may need to be revised or supplemented by addenda, and the conditions under which existing services are provided may have to change.
A clear understanding of your current relationship with each client is essential for a smooth and efficient review process. Many of the requirements under DORA can be satisfied through mechanisms and processes already in place — so not everything needs to change. Identify which elements already meet regulatory expectations and focus your efforts on the gaps.
That said, adapting legacy contracts may have cost implications. Carefully assess any operational or financial impact the proposed changes may bring, including potential shifts in service scope or risk allocation.
It's also worth noting that clients may see this as an opportunity to reopen broader commercial negotiations. Be prepared for attempts to renegotiate terms beyond DORA — such as pricing, service levels, or liability. Having a clear strategy in place will help you stay in control of the process and protect your position.
4. Embrace the Risk-Based Approach
DORA is not a one-size-fits-all framework — it is explicitly risk-based. This means ICT providers must understand how their services impact each client's risk profile and be ready to support them in managing that risk.
Start by identifying and assessing the specific risks associated with the services you provide — whether related to data confidentiality, availability, service continuity, or incident response. Implement organisational measures to monitor, report on, and test your resilience against those risks.
Financial entities will increasingly expect you to provide transparency around these risk areas and to demonstrate that you have concrete mitigation measures in place. Being prepared for these requirements will not only ensure a smooth adaptation of your services to meet regulatory expectations, but will also highlight your value as a reliable and trusted partner.
5. Train Your Teams
Digital operational resilience is not a one-off compliance exercise — it's an ongoing process that demands continuous improvement and adaptation. DORA compliance won't be achieved by a single project or policy update. It requires a cultural shift in how your organisation approaches risk, continuity, and cooperation with clients.
Your team needs to stay current, not only with the regulatory framework but also with the evolving expectations of your financial services clients. Legal and contract managers must understand DORA's contractual and compliance implications. Sales should be able to communicate your resilience posture with confidence. Operations and technical teams must be prepared to adapt your internal processes, tooling, and reporting as client needs and regulations evolve. Training ensures your teams speak the same language when working with DORA-regulated clients — and positions you as a partner, not a risk.
Perhaps most importantly, your team must be ready to work collaboratively — with each other and with your clients. DORA introduces obligations that depend on joint effort, particularly around incident response, testing, and business continuity. Ensuring that your team is prepared and aligned will enable you to meet those expectations proactively, not reactively.
Conclusion
DORA is both a challenge and an opportunity for ICT providers. Those who take a proactive, strategic approach to compliance will gain a competitive edge in the evolving FinTech ecosystem.
If you're navigating DORA requirements or revising contracts with your financial services clients, feel free to get in touch. I assist ICT providers in aligning their legal strategies with regulatory expectations — while protecting their business interests.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
