7 Resilience KPIs Every Fintech CTO Should Use under DORA
Discover 7 key Resilience KPIs for fintech CTOs to measure resilience and communicate progress to both technical and business leaders.
Effective management of resilience is a strategic priority for fintech organisations operating under increasing regulatory scrutiny. The following seven resilience Key Performance Indicators (KPIs) are specifically designed for CTOs to measure, communicate, and drive operational improvements while aligning with EU security regulations, including the Digital Operational Resilience Act (DORA), GDPR, and current European Union cybersecurity laws.
1. Third-Party Risk Exposure Score
Managing third-party risk remains a core challenge under evolving EU security regulations. CTOs require a KPI that aggregates and quantifies vendor-related exposures while demonstrating ongoing compliance with laws such as DORA and other related frameworks.
Definition and Components:
Vendor Assessment Coverage measures the percentage of all third-party suppliers, especially critical ICT and cloud providers, that have passed documented risk assessments within the past twelve months. DORA and associated compliance guidelines require full inclusion of any critical service providers.
Risk Tier Classification organises vendors according to business impact:
Tier 1 (Critical): Directly support essential business functions or handle sensitive financial data.
Tier 2 (High): Strongly influence operational continuity but are less integral than Tier 1.
Tiers 3–4 (Medium/Low): Limited immediate impact on operations. Typically, only Tiers 1 and 2 undergo the most detailed controls required under DORA, the NIS2 Directive, and sector norms.
DORA-Compliant Contract Status tracks the proportion of Tier 1 and Tier 2 vendors with up-to-date contracts containing mandatory ICT risk, audit, and incident-reporting clauses. According to recent industry surveys, contract modernisation delays are consistently cited as a major obstacle during DORA implementation.
Composite Score Calculation:
Third-Party Risk Exposure Score = Σ (Domain Weight × Risk Tier Score × Compliance Status)Domains include ICT and cybersecurity risk, regulatory compliance, service criticality, financial resilience, and contractual completeness. Assign scores (1–5) and weights reflecting organisational priorities, typically giving precedence to cybersecurity and current contracts.
Application and Reporting:
Dashboards often present:
Per cent of Tier 1 vendors with current assessments and DORA-compliant contracts.
Proportion of critical vendor agreements that specify audit rights and incident reporting.
Aggregated risk exposure scores for all essential suppliers are reviewed quarterly.
Adopting this metric directly supports audit preparation and provides evidence of ongoing oversight as required by regulators. Configurable scoring makes this KPI both adaptable and actionable, highlighting both compliance gaps and risk management progress.
The Third-Party Risk Exposure Score enables CTOs to present vendor management performance in a format accessible to both technical teams and executives, strengthening transparency and accelerating both compliance and operational improvement initiatives.
2. Incident Detection & Response Time
DORA sets strict timelines for notifying competent authorities of significant ICT‑related incidents. MTTD and MTTR are recommended KPIs to help ensure those timelines are met.
Key Metrics:
Mean Time to Detect (MTTD) records the elapsed time from incident occurrence to initial detection.
Mean Time to Respond (MTTR) measures the interval from detection through to remediation and return to standard operations.
Regulatory Alignment:
DORA mandates notification of significant ICT‑related incidents per the European Supervisory Authorities’ incident‑reporting technical standards: within four hours of classification and, in all cases, within 24 hours of detection, with an update at 72 hours and a final report within one month.
Improvement Strategies:
Establish real-time observability across payment and core business systems, leveraging solutions for traceability.
Integrate Security Information and Event Management (SIEM) and Security Orchestration, Automation and Response (SOAR) platforms to centralise alerts and automate triage. These tools can reduce MTTR by automating triage and response; actual impact varies by implementation. If you cite a percentage, include a verifiable source and context (e.g., study scope and methodology).
Maintain well-tested Incident Response Plans (IRPs) with explicit roles and decision points. Conduct regular simulations and reviews, in line with DORA and TIBER-EU guidance.
Schedule frequent threat-led drills involving red, purple, and blue teams, which ENISA recommends and many firms adopt; quantify your effect with internal MTTD data or cite a specific study rather than ENISA generically.
Brief board members through accessible dashboards and clear progress visualisations.
Presenting these metric trends in leadership meetings encourages evidence-based investment in tooling and team development, directly supporting audit obligations and risk governance for fintechs.
3. Regulatory Compliance Coverage
Regulatory requirements governing operational resilience are dynamic, and CTOs face the challenge of aligning technology, process, and contractual obligations to meet DORA and other EU security regulations.
Structuring the KPI:
Regulatory compliance coverage is visualised through a regularly updated gap analysis heatmap. This tool benchmarks organisational controls, policies, and vendor contracts against the latest requirements of DORA and related European frameworks.
Assessment Methodology:
Map current ICT controls, policies, and vendor engagements against all DORA principles.
Identify and prioritise any deficiencies through detailed document review and stakeholder interviews, focusing on technical controls, contractual completeness, and operational readiness.
Display results through a colour-coded heatmap highlighting compliant (green), partially compliant (amber), and urgent remediation (red) areas.
Effective reporting breaks down compliance status by key domains, such as incident management, third-party oversight, and operational risk and tracks completion percentages (e.g., “62% of DORA requirements met, with vendor contract revisions and technology asset inventory remaining”).
Best-Practice Implementation:
Update the gap analysis monthly to account for regulatory updates and organisational changes.
Automate metric collection and dashboarding to reduce manual oversight and error.
Assign clear ownership for all outstanding actions, ensuring board and regulator visibility of progress and accountability.
Comprehensive and ongoing gap analysis reporting enables CTOs to demonstrate how resilience and risk management underpin compliance, building trust with stakeholders at every organisational level.
4. Threat-led Penetration Testing Score
Threat-led penetration testing is required under DORA for entities selected by competent authorities; NIS2 requires regular testing of cybersecurity risk‑management measures but does not mandate TLPT. It is an advanced control for operational resilience, providing actionable insights beyond traditional vulnerability scanning.
Core Metrics:
On-Schedule Completion Rate
Percentage of scheduled threat-led penetration testing (TLPT) exercises completed within planned timeframes. This reflects program discipline and regulatory consistency.Average Remediation Time
Calculated as the mean number of days between vulnerability discovery and resolution. This quantifies the agility of security teams in closing risk windows.Test Types:
Red Teaming: Simulate adversarial attacks.
Purple Teaming: Cooperative offence and defence evaluations.
Blue Teaming: Focused internal detection and response sprints.
Comprehensive coverage supports DORA and other EU data protection standards.
Reporting Practice: Incorporate test progress (on-time completion, risk severity, and remediation velocity) within monthly executive dashboards. Balanced reporting bridges technical operations with business and compliance objectives.
Integrating these KPIs validates penetration testing as both a compliance requirement and an indicator of continuous risk mitigation.
5. ICT Change Management Effectiveness
ICT change management effectiveness directly influences operational resilience and is scrutinised by EU regulators under DORA and related laws.
Primary Metrics:
Percentage of Major ICT Changes Reviewed for Operational Risk
Identifies how thoroughly significant changes are vetted for threats, compliance, and operational impacts. For instance, reviewing 18 of 20 major changes reflects a 90% review rate.Percentage of ICT Changes Resulting in Post-Implementation Incidents
Tracks change-induced issues, such as outages or compliance failures. Set a clear internal target for post‑change incident rates (e.g., <3%).
Reviews should evaluate:
Vulnerability and risk exposures,
Compliance with all regulatory obligations under DORA and GDPR,
Impact on both internal and vendor operations,
Rollback and incident response planning.
Illustrative Example: A mid-sized fintech previously experienced a 7% incident rate after accelerating core API updates without adequate review, triggering a major payment system outage. Subsequently, by introducing automated risk assessments and post-deployment validation, the firm achieved uninterrupted upgrades and lowered its incident metric to below 3%.
Board Reporting and Action: Convey results using trend lines, annotated with significant changes or incident spikes, and supplement with brief narratives that make risks and progress clear for executive oversight. Align improvement and training programs with updated regulatory standards to ensure ongoing compliance.
Effective change management measurement ensures both operational integrity and sustained regulatory compliance, even as expectations continue to evolve.
6. Cyber Resilience Maturity Index
The Cyber Resilience Maturity Index (CRMI) offers a single, comprehensive score summarising a fintech’s readiness across all DORA competencies. By consolidating progress in risk management, incident response, testing, information sharing, third-party risk, and governance, this KPI supports strategic decisions and meets regulatory expectations.
Structure and Assessment:
Each domain is rated 1–5:
ScoreDescription
1 Initial: Unstructured, ad hoc responses
2 Developing: Basic controls, inconsistent
3 Established: Documented routines, reviewed
4 Advanced: Continuous, proactive refinements
5 Optimised: Integrated, automated, audit-ready
This approach, advocated by KPMG and Wavestone in recent sector guidance, ensures consistent interpretation and eases benchmarking.
Visualisation:
A radar chart displays each domain’s score, revealing strengths and highlighting areas needing strategic investment. Comparing current and target positions provides actionable direction for resource allocation.
Practical Benchmarking: Aggregate the six domain scores (e.g., [2, 3, 2, 1, 3, 2]) and average for a sector-comparable maturity index.
Industry data helps CTOs determine if current maturity meets, lags, or exceeds both peer organisations and evolving EU regulatory expectations.
Executive Value: Consolidating resilience measurement into a single KPI streamlines board reporting and provides a direct reference for compliance investment discussions, supported by recognised industry data.
7. Cost and Resource Allocation Efficiency
Proactive management of cost and resource allocation is integral to meeting EU security regulation demands and delivering sustained value from resilience investments.
Measurement Components:
Resilience Proportion of Operational Budget: Identifies the share of total ICT expenditures dedicated to resilience activities—such as risk management, incident response, and compliance—that are essential for EU readiness.
Resource Headcount and Specialisation: Tracks the number and expertise of Full-Time Equivalents (FTEs) supporting resilience objectives, including compliance leads, cyber risk analysts, and incident responders.
Budgetary Trends: Monitors year-on-year changes in spend, aligned to regulatory priorities. External consultancies underscore that sustained increases, such as raising resilience spend from 7% to 10% of total IT budget, signal active compliance management and competitive positioning.
Resource Impact Reporting: Links budget or staff reallocations to tangible improvements (e.g., faster incident resolution, increased risk transparency, or demonstrable progress along regulatory milestones).
Effective Practices:
Quarterly board reporting should include budget splits and headcount tables, emphasising the business value of resilience compliance. Dashboards clarify alignment between investments and risk reduction, supporting executive decision-making.
Consistent cost and resource allocation monitoring positions fintech CTOs to demonstrate efficiency, regulatory leadership, and long-term growth potential.
Executive Summary and Next Steps
Fintech CTOs navigating the demands of EU security regulations establish operational resilience as both a compliance imperative and a strategic asset by deploying focused, quantifiable KPIs. The seven resilience KPIs presented, spanning third-party risk, incident response, regulatory compliance, threat-led testing, change management, resilience maturity, and cost efficiency, offer practical, actionable measurement systems.
These frameworks enable CTOs to:
Transparently communicate progress to technical and non-technical stakeholders,
Prioritise investments by data-driven assessment of risk and readiness,
Satisfy evolving DORA and EU audit standards with evidence-backed reporting.
The adoption and continual refinement of resilience KPIs will support fintechs in quantifying achievements, identifying actionable gaps, and future-proofing both compliance programs and overall business strategy. CTOs are encouraged to select one or more of the outlined KPIs for immediate implementation, ensuring cross-functional collaboration, automated metric tracking, and alignment with regulatory and organisational goals. This approach establishes a clear path towards mature, defensible, and value-driven operational resilience.