Digital Operational Resilience for Financial Services
DORA requires financial entities to ensure digital operational resilience through ICT risk management, incident handling, and third-party risk governance. Control provides the physical enforcement layer that demonstrates resilience beyond software controls.
DORA
DORA requires financial entities to not merely survive ICT disruptions, but to demonstrate they have the resilience measures in place to continue operating through them.
Ch. II
ICT risk management framework coverage
100%
Third-party ICT path governance
Ch. V
Third-party risk management evidence
Full
Automated regulatory evidence generation
Financial services face stringent resilience requirements.
ICT Risk Management
DORA Chapter II requires comprehensive ICT risk management frameworks with demonstrable technical controls that go beyond policy documentation.
Third-Party Concentration
Financial entities increasingly depend on third-party ICT providers, creating concentration risks that DORA Chapter V specifically addresses.
Recovery Testing
DORA requires regular resilience testing including threat-led penetration testing. Organisations must demonstrate that recovery capabilities work under realistic conditions.
The Scenario
Scenario: DORA Resilience Assessment
A financial entity undergoes its first DORA resilience assessment. The regulator examines third-party ICT risk management and discovers that 14 vendor connections maintain persistent network access to production payment systems. The entity cannot demonstrate that these connections are actively governed or that access can be revoked in a defined timeframe. The regulator also finds that backup systems share network infrastructure with production, meaning a ransomware attack could compromise both simultaneously. With Control, all vendor connections are physically governed with time-limited access windows. Control-plane baselines are held on infrastructure with no live network path to production. The entity demonstrates continuous evidence of ICT risk management and third-party governance that exceeds DORA requirements.
"The regulator asked us how quickly we could sever a compromised vendor connection. Honestly, it would have taken us days to identify all the paths, update firewall rules, and verify the changes. With physical path governance, the answer is seconds."
Where DORA articles meet Control modules.
DORA puts ICT resilience at the heart of financial services regulation. Control provides the physical containment and recovery layer DORA assumes is in place.
Reference: Regulation (EU) 2022/2554 (DORA), Articles 5 to 14 (ICT risk management) and Articles 28 to 30 (third-party risk).
ICT risk management framework (Art. 5-8)
-
Art. 6
ICT risk management framework
Boundary enforcement is physical and continuously evidenced.
Firebreak
Validate -
Art. 8
Identification of ICT-supported business functions
Crown-jewel functions sit behind a named, severed conduit by default.
Isolate
Lock
Protection and prevention (Art. 9)
-
Art. 9(2)
ICT security measures
Privileged actions require explicit approval and produce signed evidence.
ExecuteValidate -
Art. 9(4)
Network and infrastructure security
Zone boundaries are physically severed and reachable only via governed conduits.
FirebreakIsolate
Detection and response (Art. 10-11)
-
Art. 11(2)
Response and recovery
Recovery copies remain in an offline vault, disconnected from the live network.
Archive
Transfer -
Art. 11(4)
ICT business continuity policy
Restoration is an authorised Execute event with quorum approval and recorded intent.
ExecuteValidate
Third-party risk (Art. 28-30)
-
Art. 28
General principles for ICT third-party risk
Vendor reach is default-severed; engagements run as time-bound Relay sessions.
Firebreak
RelayLock -
Art. 30
Contractual provisions on use of ICT services
Vendor sessions are named, scoped and revocable at the boundary.
Lock
Unlink
Modules & symbols
FirebreakPhysical severValidateIntegrity checkIsolateZone boundaryLockNamed accessExecuteApproved actionArchiveDisconnected copyTransferControlled moveRelayTime-bound pathUnlinkRemove trustFeatured In
Key Capabilities
Financial Data Sovereignty
All financial system data and configurations remain within the agreed jurisdiction in secured Firevault Bunkers, supporting data localisation requirements.
Third-Party Access Governance
Every vendor and third-party ICT access session is multi-party authorised, time-limited, and fully logged for regulatory review.
Regulatory Evidence
Automated logging generates continuous evidence for DORA, FCA, PRA, and EBA requirements across all ICT risk management domains.
Resilience Testing Support
Physical isolation capabilities support threat-led penetration testing (TLPT) by providing demonstrable containment boundaries for test scenarios.
Audit Trail
Tamper-proof logs record every ICT system access, third-party connection, and incident response action for regulatory audit.
Recovery Assurance
Verified control-plane baselines demonstrate operational resilience that withstands even total network compromise scenarios.
Demo to Live
Adoption Guide
DORA Gap Assessment
Map your current ICT risk management measures against DORA chapter requirements to identify where physical enforcement strengthens compliance.
Resilience Architecture Design
Design physical ICT system boundaries and third-party governance models that satisfy DORA requirements across all applicable chapters.
Resilience Validation
Deploy Control and conduct threat-led testing to validate physical containment capabilities before your regulatory assessment.
Full DORA Deployment
Organisation-wide deployment with continuous regulatory evidence, third-party governance, and verified control-plane baseline assurance.
DORA Gap Assessment
Map your current ICT risk management measures against DORA chapter requirements to identify where physical enforcement strengthens compliance.
Resilience Architecture Design
Design physical ICT system boundaries and third-party governance models that satisfy DORA requirements across all applicable chapters.
Resilience Validation
Deploy Control and conduct threat-led testing to validate physical containment capabilities before your regulatory assessment.
Full DORA Deployment
Organisation-wide deployment with continuous regulatory evidence, third-party governance, and verified control-plane baseline assurance.
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