DORA Compliance Checklist: A Practical Guide for Cybersecurity Teams 

What Is DORA and Why Does It Matter? 

The Digital Operational Resilience Act (DORA) is a pivotal regulation from the European Union designed to ensure that financial entities can withstand, respond to, and recover from all types of Information and Communication Technologies (ICT)-related disruptions and threats.  

With cyberattacks increasingly targeting the financial sector, DORA mandates comprehensive cybersecurity and operational resilience across the entire digital ecosystem — from internal systems to third-party services. 

At its core, DORA ensures secure and authenticated device communication, robust network security compliance, and a standardized approach to cyber risk management across EU financial services. 

DORA Compliance Checklist: Meeting the Five Pillars 

To align with DORA, organizations must comply with five key pillars. Below is a concise, actionable checklist for each requirement, tailored for cybersecurity and compliance teams. 

1. Risk Management: Build a Robust Cyber Risk Framework 

Under DORA, financial entities must identify, assess, and mitigate ICT risks systematically. They must implement frameworks that address critical areas of risk. 

Action Steps: 

• Implement a formal ICT risk management framework 
• Conduct regular risk assessments of internal systems and third-party services 
• Classify and prioritize assets based on criticality 
• Establish device authentication policies to verify trusted endpoints 
• Integrate vulnerability management and patching into operational workflows 

2. Incident Reporting: Prepare for Fast, Accurate Disclosures 

DORA mandates that significant ICT incidents be reported within strict timeframes to competent authorities. Details must be provided about any incident as well as its impact and steps that were taken for remediation. 

Action Steps: 

• Establish an internal incident response and escalation process 
• Use automated tools to detect, log, and report security incidents 
• Ensure reports include impact assessments, root causes and mitigation steps 
• Train security staff on DORA reporting obligations 

3. Operational Resilience Testing: Continuously Validate Security Posture 

To comply with DORA, entities must regularly test their digital resilience under realistic threat conditions. These include conducting vulnerability assessments, penetration testing as well as stress testing. These tests will show whether or not systems can withstand a variety of disruptions or attacks. 

Action Steps: 

• Conduct scenario-based and threat-led penetration testing (TLPT) 
• Test authentication and encryption controls on connected devices 
• Simulate attacks on communication protocols and data flows 
• Continuously validate controls across all attack vectors 

4. Third-Party Risk Management: Secure Vendor Relationships 

DORA enforces strict oversight of ICT service providers to minimize third-party vulnerabilities. Many past high-profile data breaches and security incidents begin with vulnerabilities presented by third party access to critical systems and infrastructure, so securing those relationships is of paramount importance to meet DORA security requirements. 

Action Steps: 

• Maintain an inventory of all ICT third-party providers 
• Assess vendors for compliance with DORA-aligned security standards 
• Monitor access privileges and ensure secure device communication 
• Include security SLAs in vendor contracts 

5. Information & Intelligence Sharing: Collaborate for Stronger Defense 

DORA promotes proactive sharing of threat intelligence among financial institutions to build collective resilience. 

Action Steps: 

• Join threat intelligence sharing communities (e.g., FS-ISAC) 
• Integrate shared indicators of compromise (IOCs) into detection systems 
• Leverage threat intelligence feeds to inform simulations and test defenses 

Who Must Comply with DORA? 

DORA applies to a wide range of financial and ICT-related entities within the EU and who operate with EU-based clients, including: 

• Banks 
• Investment firms 
• Insurance companies 
• Payment service providers 
• Credit institutions 
• ICT third-party service providers (e.g., cloud platforms, data centers) 

Why It Matters: These institutions operate in high-risk digital environments, where secure device authentication and encrypted communications are essential to protect customer data and financial integrity. 

What Happens If You Don’t Comply? 

Organizations that are required to comply with DORA regulations but do not do so could face significant consequences if an incident leads to a finding of non-compliance. As such, non-compliance with DORA can lead to: 

• Regulatory fines and legal consequences. 
• Increased exposure to cyberattacks and data breaches. 
• Reputational damage and loss of customer trust. 
• Potential restrictions on business operations by regulators. 

In particular, the financial penalties for DORA non-compliance can be massively detrimental. DORA allows leaders to impose financial penalties on ICT providers amounting to 1% of the provider’s average daily worldwide turnover in the previous business year. 

Failing to implement DORA’s device and network security mandates could result in unverified endpoints accessing sensitive systems — a risk too great in today’s threat landscape. 

How Cymulate Strengthens Your DORA Compliance 

Cymulate can help your organization check down the list of requirements to meet DORA compliance. Cymulate offers an automated, continuous exposure validation platform that aligns directly with DORA’s cybersecurity and operational resilience objectives. 

Key Cymulate Capabilities: 

• Real-time Exposure Validation and Management: Understand and reduce your attack surface dynamically. 
• Continuous Breach and Attack Simulation: Mimic attacker tactics to test your defenses 24/7. 
• Support for Audit & Reporting: Provide measurable, audit-ready data to support DORA compliance reviews. 
• Device & Network Security Validation: Ensure encryption, access controls and authentication mechanisms are tested and effective. 

Utilizing the Cymulate platform, your organization can leverage production-safe testing and validation of your ICT security controls with numerous automated test scenarios and templates. These best practice templates can be scheduled to run on a regular basis to perform assessments of key ICT security controls and processes, including: 

• Email and Web Gateways 
• Web Application Firewalls 
• Antivirus & Endpoint Security 
• Cloud Workload & Container Security 
• Lateral Movement & Data Loss Prevention 
• Advanced Persistent Threat Scenarios 
• Phishing with Full Kill-Chain Campaigns 

These assessments highlight areas of risk, identifying gaps and weaknesses that could be exploited by threat actors to disrupt financial operations. The detailed findings offer mitigation guidance to configure and tune your ICT security controls to increase resiliency and lower the risk of a cyber breach. 

You'll get the proof you need to achieve DORA compliance. The reports and dashboards provide evidence highlighting the effectiveness of your ICT security controls to prevent and detect the latest cyber attacks. 

The DORA compliance checklist isn’t just about checking regulatory boxes — it’s about building lasting operational resilience in financial sector cybersecurity.  

With Cymulate, you gain the tools to proactively test, validate, and reinforce your cybersecurity posture in line with DORA requirements. Learn more about how Cymulate can help by downloading and reading our DORA solution brief. 

Ready to simplify and strengthen your path to DORA compliance? Book a demo with Cymulate and see how we can help your team stay compliant, resilient and secure.