EU DORA Regulation: ICT Incident Response Management Requirements

Enacted as part of DORA (the EU Digital Operational Resilience Act), the DORA Regulation (Regulation (EU) 2022/2554 on digital operational resilience for the financial sector) sets out cyber security and business continuity requirements for financial organisations and their third-party ICT (information and communication technology) service providers.

These include implementing an ICT risk management process. A crucial part of risk management is incident response management – preparing for and reacting to security incidents.

DORA’s specific technical requirements are yet to be finalised (they’re due to be published in January 2024). However, the Regulation does give a broad overview of the approach financial entities must take. So if you want to get ready for the January 2025 compliance deadline, there’s no good reason not to start now.

In fact, ensuring your cyber risk management processes are up to date – particularly your cyber incident response management plans – is always time well spent.

When you inevitably suffer a cyber attack or incident, the sooner you can respond and the more effective your response, the less disruption you suffer, the quicker your recovery and the lower your remediation costs.

What are the DORA Regulation’s ICT incident response management requirements?

Articles 8–13 of the DORA Regulation set out combined risk management and incident response management requirements for financial entities. These include:

  • Implementing and maintaining an ICT risk management framework to ensure the resilience, continuity and availability of ICT systems;
  • Developing and documenting an information security policy that defines rules to maintain the confidentiality, availability, integrity and authenticity of data;
  • Implementing, maintaining and regularly testing mechanisms to detect anomalous ICT activities, identify potential points of failure and alert relevant staff to incidents;
  • Implementing and testing an ICT business continuity policy, including response and recovery plans, to ensure the continuity of critical or important functions; and
  • Developing and documenting backup policies and procedures, and restoration and recovery procedures and methods.

Articles 17–23 provide further information, including about incident classification and reporting obligations.

There are many exceptions and simpler requirements for smaller organisations. However, a best-practice approach to ICT incident response management will help ensure that your organisation is resilient to complex cyber risks and complies with its obligations under the Regulation.

How to implement a DORA-compliant cyber incident response management framework

At IT Governance, we understand that developing and maintaining the ability to withstand the complex cyber security risks your organisation faces requires a multi-layered approach.

This is why our defence-in-depth approach to cyber security encompasses detection, protection, management, response and recovery.

We can support your organisation in its implementation of best-practice information security and business continuity measures, including management systems based on the international standards ISO 27001 and ISO 22301.

See our full range of DORA products and services

DORA Gap Analysis

Determine the extent to which your organisation’s existing practices comply with your DORA obligations with our DORA Gap Analysis:

  • Efficiently bridge compliance gaps.
  • Identify priority areas for improvement and compliance enhancement.
  • Streamline your resilience strategy.
  • Receive expert, actionable recommendations tailored to your organisation’s specific needs, providing a clear path to regulatory compliance.

Once this has been completed, we can also work closely with you to provide the solutions you need to address the compliance gaps the assessment identifies.

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