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DORA (Digital Operational Resilience Act)

DORA (Digital Operational Resilience Act)

EU regulation (effective January 2025) for the financial sector. Requires: ICT risk management, incident reporting, digital operational resilience testing, ICT third-party risk management (including contractual access and audit rights for critical ICT providers), information sharing, threat-led penetration testing (TLPT) for systemic institutions.

Who must comply: 22,000+ financial entities in the EU (banks, investment firms, payment processors, crypto-asset providers, insurance companies). Also ICT third-party providers deemed critical.

Penalties: Up to 2% of average daily turnover × number of days breached, or 10M EUR for legal entities. Personal liability for management.

Why it matters: DORA's third-party risk management requirement is a natural gate stack use case — every ICT provider access must be gated, logged, and auditable. TLPT (threat-led penetration testing) maps to the evaluation harness. First-mover advantage is extremely time-sensitive: DORA is already in effect (January 2025). Financial institutions are scrambling for compliance tooling. A DORA gate package at $50K/yr with zero incremental cost per additional user is an immediate sale.