DORA Compliance Roadmap for Fintech CTOs
Six months past DORA’s Jan 17, 2025 deadline, a 5-step roadmap for fintech CTOs to close compliance gaps and build true digital resilience.
As of June 2025, DORA has been applicable since 17 January 2025. Many fintechs have yet to fully meet their requirements. This roadmap is designed for CTOs of firms that are not yet DORA‑compliant and need a clear plan of action.
Assign Clear Ownership in Your DORA Compliance Roadmap
Why Ownership is Your First Step
DORA (Digital Operational Resilience Act) places direct responsibility for ICT risk management squarely on your board (Article 4). Without formal accountability, remediation stalls, audits drag, and regulators quickly lose patience. By formally assigning board-level responsibility and naming a single DORA Programme Lead, you eliminate confusion and empower teams to focus on delivery rather than debating decision-making authority.
Four Actions Your Fintech Can Complete This Month
Board Resolution
Add DORA compliance explicitly to your risk appetite statement.
Officially appoint a DORA Programme Lead (often your CTO or COO).
Draft a RACI Matrix
Map each Delegated/Implementing Regulation requirement to roles:
Board (Accountable)
Programme Lead (Responsible)
Control Owners (Consulted)
Audit (Informed)
Keep it concise—one page—for daily reference.
Launch an Operational Resilience Council
Members: CTO (Chair), CISO, Head of DevOps, Legal, Risk, and a business-line lead.
Schedule bi‑weekly 30‑minute meetings focused on blockers and metrics, not slide decks.
Publish a Two‑Tier Escalation Path
Tier 1: Medium‑severity incidents handled by Control Owners.
Tier 2: Major ICT incidents escalate internally within 15 minutes; regulators must be notified by the end of the next business day (per DORA Article 9), with a detailed report within one month.
Clear ownership accelerates compliance and reduces regulatory friction.
Mini‑Case: How One 120‑Person Payments Firm Did It
Previously, five separate teams managed security, causing vendor assessments to take 90 days. After appointing a DORA Programme Lead and launching their Operational Resilience Council:
Vendor review cycles dropped to 25 days.
Completed a cross‑service gap analysis in three weeks.
Reduced regulator follow‑up questions by 40%.
Think of ownership as a product feature: design it once, test it regularly, and iterate when people or processes change.
Map Your Critical Business Services
Why This Matters
Under DORA, your board is accountable for critical functions. A glitch in payments or onboarding can trigger regulatory intervention and fines. Clearly defining critical services—those whose failure would harm customers, impact capital, or breach licence conditions—is essential.
Four‑Step Mapping Playbook for Fintech CTOs
List Candidate Services
Identify top‑level customer journeys from your product roadmap and incident logs.
Stress‑test each against DORA criteria: customer impact, market integrity, and financial stability.
Typical critical services: payments execution, digital lending, KYC/AML screening, core ledger.
Decompose Each Service
Break down into people, processes, technology, facilities, and data.
Identify hidden dependencies (shared SRE teams, single secrets vaults).
Tip: Run a half‑day workshop with engineering, ops, and compliance.
Visualise with Service Blueprints
Plot customer activities, internal assets, and external providers.
Label components with RTO/RPO targets defined in your ICT risk management framework (per DORA Article 7) and aligned with ESAs guidance.
Identify single points of failure—input for gap analysis.
Validate and Assign Ownership
Assign an accountable executive (often the product owner) for each blueprint.
Store blueprints in your GRC/wiki, updating quarterly to track drift.
Quick Win: Two‑Week Dependency Map
Week 1: Daily 60‑minute workshops to draft blueprints in Miro or Lucidchart.
Week 2: Circulate for feedback, finalise RTO/RPO tags, and present a one‑page heat map to your board.
Outcome: A regulator‑ready register of critical services by month‑end—no new tooling required.
Run a Structured DORA Gap Analysis
Why a Structured Approach Matters
DORA’s Articles set objectives; the RTS/ITS Regulations (e.g., Delegated Reg 2024/1773, Implementing Reg 2024/2956, ESA v4.0 Reporting Package) specify controls. A systematic gap analysis shows compliant controls, tweaks needed, and missing elements.
Five‑Step Playbook for Fintech CTOs
Scope the Assessment
Entities: parent, regulated subsidiaries, and relevant cloud regions.
Include all applicable Delegated/Implementing texts currently in force.
Map Existing Controls
Leverage SOX, ISO 27001, and PCI evidence where relevant.
Document control owners, artefacts, and frequency.
Score Each Clause
Status: Compliant (✓), Partially Compliant (~), Not Compliant (✗).
Impact: High if it affects critical services; else Medium/Low.
Effort: High for new tooling; else Medium/Low.
Visualize Results
Create a heat‑map spreadsheet (red for urgent gaps).
Import into your GRC platform for remediation tracking.
Prioritize Fixes
Address High‑Impact/Low‑Effort first; schedule Low‑Impact/High‑Effort later.
Set deadlines.
Mini‑Checklist:
Board approval of scope.
Cross‑reference table linking Delegated/Implementing clauses to controls.
Action log with owners, budgets, target dates.
Time‑stamped audit trails from your GRC.
Build a Modular Control Library
Why This Matters
DORA demands consistent, comprehensive ICT controls. A modular library lets you define each control once, reuse across services, and automate updates, cutting maintenance and audit pain.
Four Steps to Your “Golden Sources”
Define a Control Taxonomy
Group by domain (access management, change control, backup & recovery).
Include metadata: objective, owner, frequency, KPIs, and evidence source.
Single Source of Truth
Store controls in version‑controlled Markdown/YAML in Git.
Link to your GRC for synchronisation.
Parameterise for Variation
Use variables for RTO/RPO targets, environments, and jurisdictions.
Automate Distribution
GitOps pipelines push changes to runbooks, IaC templates, and policy portals.
Nightly, jobs update KPI dashboards and flag orphaned controls.
Core Controls to Cover First
Access management (MFA, orphan account sweeps)
Change control (code reviews, rollback plans)
Backup & recovery (immutable snapshots, quarterly tests)
Harden Incident Reporting Procedures
Why It Matters
DORA Article 9 requires notification of major ICT incidents to authorities by the end of the next business day, with a detailed report within one month and a summary within three months. Internal SLAs can be tighter to ensure readiness.
Implementation in Four Sprints
Sprint 1: Map current incident flows.
Sprint 2: Create pre-authorised report templates.
Sprint 3: Automate submission via serverless functions.
Sprint 4: Conduct tabletop exercises.
Launch Threat‑Led Penetration Testing (TLPT)
Note: Delegated Regulation C(2025) 885 (13 Feb 2025) mandates annual TLPT only for systemic financial entities and designated Critical ICT Third‑Party Providers (CTPPs). Tailor your TLPT approach accordingly.
Industrialise Third‑Party Risk Management
Align vendor tiering with the 18 Feb 2025 ESA CTPP Roadmap, and submit registry data using ITS 2024/2956 templates.
Retrofit Contracts for Resilience
Update SLAs with RTOs, incident‑sharing clauses, audit rights, data portability, exit strategies, and sub‑outsourcing notifications.
Embed a Resilience Culture
Use secure‑by‑design checklists, micro‑learning, quarterly drills, and reward proactive behaviours.
Set Up Continuous Assurance
Automate evidence collection via central logs, config‑drift detection, and attestation workflows.
Final Tip: Start your 30‑day sprint now: secure executive ownership, run a focused gap analysis using the Delegated/Implementing Acts in force, and build an actionable backlog. Acting now makes compliance a competitive advantage well before regulators arrive.