11 Practical Steps to Master Your DORA Compliance Audit
Take control of your DORA compliance audit with these clear, actionable tactics designed specifically for fintech CTOs aiming to eliminate audit anxiety.
As a fintech CTO, you're no stranger to regulatory scrutiny. With the Digital Operational Resilience Act (DORA) enforcement now in full swing, the stakes have never been higher. But here's the good news: mastering DORA compliance doesn't have to be daunting. In fact, by following these 11 practical tactics, you'll transform your next DORA Compliance Audit from a stressful event into a smooth, predictable process.
1. Start With a Blunt Gap Analysis
Why the "Blunt" Approach Works Best
Before you dive into new controls, find out exactly where you stand. A brutally honest gap analysis reveals hidden weaknesses faster than any polished presentation. For you, this means fewer surprises during audits and a clear roadmap for spending.
Your Four-Step Playbook
1. Gather Existing Documents
Collect policies, runbooks, vendor contracts, and penetration-test reports into one central folder. Don't forget parallel frameworks like ISO 27001 and SOC 2, you can reuse this evidence later.
2. Map Artefacts to DORA’s Five Pillars
- ICT risk management
- Incident reporting
- Digital operational resilience testing
- ICT third-party risk
- Information-sharing arrangements
Create a spreadsheet with DORA articles as rows and artefacts as columns. Mark each as direct, partial, or missing coverage.
3. Score and Visualise Gaps
Assign scores from 0 (Not Compliant) to 3 (Compliant). Generate a heatmap so executives instantly see weak spots. Validate your scoring with a free checklist fromCISO.
4. Turn Gaps Into Two-Week Sprints
Prioritise critical "red" controls that carry fines or customer impact. Assign each action to Jira with clear owners, definitions of done, and expected evidence. Re-score monthly and watch your heatmap shift from red to green.
Mini-case: Payment scale-up OneCompanyPay boosted its ICT third-party coverage from 43% to 88% in just six weeks using this method. The blunt gap analysis clearly demonstrated ROI, making it easy to secure board approval.
2. Map a Federated Controls Library
Why Consolidation Beats Silos
Running SOX, ISO 27001, PCI-DSS, and DORA separately leads to duplicate testing and audit fatigue. A federated controls library eliminates overlap, letting one piece of evidence satisfy multiple frameworks.
Five Steps to Build Your Matrix
1. Pull Source Material
Export controls from SOX, ISO 27001 Annex A, PCI-DSS v4, and DORA Articles 9-15. Standardise wording into "action + object + purpose."
2. De-duplicate by Intent
Group controls with the same outcome. Keep the strictest requirement as master, referencing others as aliases.
3. Assign Universal IDs
Prefix IDs with framework codes (e.g., SOX-SD-01). Add a DORA cross-reference column for easy sorting.
4. Tag Supporting Evidence
Link controls to Jira tickets, AWS Config rules, or SOC 2 reports. Aim for "one-click proof" during audits.
5. Store in a Living Repository
Use a version-controlled GRC platform like LeanIX Continuous Controls Catalogue. Set up peer-reviewed pull-request workflows.
Quick Wins for Next DORA Compliance Audit
- Replace multiple auditor lists with one export from your matrix.
- Auto-populate evidence packets using DORA filters.
- Track control ownership centrally, ending "who owns this?" email chains.
Red Flags to Avoid
- Mapping only at clause level—always drill down to control statements.
- Letting the library go stale—schedule quarterly reviews aligned with sprint retrospectives.
Adopt this matrix now, and your next DORA review will feel like reusing code instead of rewriting it.
3. Refresh Your DORA Compliance Audit Charter for DORA
Why a Charter Update Matters
DORA makes ICT risk a board-level liability. Your audit charter must clearly show the internal audit’s ability to independently assure all five pillars without conflicts of interest. fromCISO’s guide on the five pillars is a solid reference.
Step-by-Step Rewrite
1. Expand the Mandate
Include ICT third-party risk, incident response, and resilience testing explicitly in your annual DORA Compliance Audit plan.
2. Define Clear Roles
3. Hard-Code Escalation Paths
Material findings must reach the Audit Committee within five business days. Legal non-compliance issues go straight to the board chair.
4. Continuous Assurance
Authorise auditors to use continuous monitoring dashboards. Schedule quarterly mini-reviews.
5. Resilience Testing Rights
Grant audit observer status during resilience tests. Require post-exercise reports within ten days.
A well-crafted charter arms your team with clear authority, satisfies regulators, and lets you focus on innovation, not firefighting.
4. Automate Your Vendor Register
Why Spreadsheets Won’t Cut It
DORA views critical ICT suppliers as extensions of your risk surface. A static spreadsheet can't capture daily changes. Automating your vendor register ensures real-time accuracy.
Four Moves to Automation
- Embed vendor creation in your procurement portal.
- Enrich data nightly with Bitsight or SecurityScorecard risk scores.
- Tie updates to CI/CD pipelines to block shadow IT.
- Stream evidence into the audit via weekly snapshots.
Mini-case: OneCompanyPay caught shadow IT instantly when their CI/CD pipeline flagged an unregistered SaaS. Procurement completed due diligence within 48 hours, impressing auditors with rapid control effectiveness.
5. Monitor ICT Risk in Real Time
Why Continuous Monitoring Matters
DORA Article 9 demands the timely identification of anomalous activities. Continuous control-monitoring (CCM) dashboards replace quarterly PDFs with live risk scores, eliminating blind spots.
Build a CCM Dashboard in Three Sprints
- Pipe data from SIEM, ticketing, and cloud posture tools.
- Map metrics to DORA articles.
- Set visual alerts that trigger Slack and Jira notifications.
Daily metrics like mean time to patch and backup success rates impress auditors and demonstrate proactive oversight.
6. Drill Incident Response & Reporting
Why Drills Are Essential
DORA gives just 24 hours to report material incidents. Regular tabletop and live-fire exercises ensure your team meets this tight deadline.
Internal DORA Compliance Audit observes drills, capturing timestamps and artefacts to prove control effectiveness.
7. Stress-Test Operational Continuity
Why Advanced Testing Counts
Scenario-based resilience tests (e.g., power loss, cloud outages) provide hard evidence that your recovery targets actually work. Automate metric collection for audit-ready documentation.
8. Elevate Board-Level Oversight
Why Regular Updates Matter
Make DORA readiness a standing board agenda item. Present a concise heatmap and clear budget motions quarterly to keep directors informed and accountable.
9. Industrialise Evidence Capture
Why Automation Beats Manual Gathering
Automate evidence capture into a secure data lake, tagging artefacts for rapid retrieval. Regular "evidence health checks" ensure continuous compliance.
10. Stage Mock Supervisory Reviews
Why Practice Makes Perfect
Run mock ESMA/EBA inspections every six months. Identify gaps early and build muscle memory, turning real inspections into routine events.
11. Close the Loop With Continuous Improvement
Why Iteration Is Key
Turn DORA Compliance Audit findings into an agile backlog. Assign clear owners, bake KPIs into operational metrics, and re-run gap analyses semi-annually. Continuous improvement becomes routine engineering work.
Quick Win: Download the 1-Page DORA Compliance Audit Sprint Planner
Grab a free XLSX that slots all 11 tactics into six two-week sprints. Drop it into Google Sheets or Jira, assign owners in minutes, and start turning red gaps green. No calls, no commitments—just a practical worksheet you can use today.
Good luck—your next audit just got easier.