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Control and DORA

Digital operational resilience for financial services.

DORA expects ICT risk management, incident handling and third-party risk governance you can demonstrate. Control provides a physical enforcement layer that evidences resilience beyond software controls.

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The problem

Financial services face stringent resilience requirements.

DORA asks firms to show, not describe, how ICT risk, third parties and recovery are controlled.

  1. Financial system configurations held in Firevault Bunkers: Europe live, US and Middle East next.

  2. Vendor sessions are multi-party authorised, time-limited and logged for regulatory review.

  3. Automated logging that can help support DORA, FCA, PRA and EBA expectations.

Problem 3

Recovery testing.

DORA requires regular resilience testing, including threat-led penetration testing, so recovery has to work under realistic conditions.

Physically disconnected Offline Secure Storage: server, three drives and a padlock
Answered byRegulatory evidence

The mapping

Where DORA articles meet Control modules.

From the ICT risk management framework to third-party contracts, each article mapped to the modules that evidence it.

DORA article Control modules How Control helps
Art. 6ICT risk management framework
  • Firebreak
  • Validate
Boundary enforcement is physical and continuously evidenced.
Art. 8Identification of ICT-supported business functions
  • Isolate
  • Lock
Crown-jewel functions sit behind a named, severed conduit by default.
Art. 9(2)ICT security measures
  • Execute
  • Validate
Privileged actions require explicit approval and produce signed evidence.
Art. 9(4)Network and infrastructure security
  • Firebreak
  • Isolate
Zone boundaries are physically severed and reached only via governed conduits.
Art. 11(2)Response and recovery
  • Archive
  • Transfer
Recovery copies remain in an offline vault, disconnected from the live network.
Art. 11(4)ICT business continuity policy
  • Execute
  • Validate
Restoration is an authorised Execute event with quorum approval and recorded intent.
Art. 28General principles for ICT third-party risk
  • Firebreak
  • Relay
  • Lock
Vendor reach is severed by default; engagements run as time-bound Relay sessions.
Art. 30Contractual provisions on the use of ICT services
  • Lock
  • Unlink
Vendor sessions are named, scoped and revocable at the boundary.

Alignment, not certification. Control can help support these measures; your assessor decides what satisfies them.

The scenario

Scenario: a DORA resilience assessment.

Regulators ask how quickly a compromised vendor connection can be severed. Step through it, or play it through.

Step 1 of 2

Without physical evidence

A regulator finds 14 vendor connections with persistent access to production payment systems.

Backups share network infrastructure with production.

Boundaries
Logical, configured in software
Evidence
Point-in-time, at each audit

An illustrative scenario.

Capabilities

What you get with every deployment.

Six things Control gives a DORA programme, from the first boundary to the audit afterwards.

DORA

Data held in Firevault Bunkers

Financial system configurations held in Firevault Bunkers: Europe live, US and Middle East next.

DORA

Third-party access governance

Vendor sessions are multi-party authorised, time-limited and logged for regulatory review.

DORA

Regulatory evidence

Automated logging that can help support DORA, FCA, PRA and EBA expectations.

DORA

Resilience testing support

Physical isolation provides containment boundaries for threat-led penetration testing.

DORA

Audit trail

Tamper-evident logs record ICT system access, third-party connections and incident response actions.

DORA

Recovery assurance

Verified control-plane baselines help demonstrate operational resilience.

Adoption guide

From gap assessment to continuous evidence.

  1. 1

    DORA gap assessment

    Map current ICT measures against DORA chapters to find where physical enforcement strengthens compliance.

  2. 2

    Resilience architecture design

    Design physical ICT system boundaries and third-party governance across the applicable chapters.

  3. 3

    Resilience validation

    Deploy Control and run threat-led testing to validate physical containment before your regulatory assessment.

  4. 4

    Full DORA deployment

    Roll out with continuous regulatory evidence, third-party governance and baseline assurance.

Questions

What teams ask about Control and DORA

Chapter II (ICT risk management), Chapter III (incident handling and recovery) and Chapter V (ICT third-party risk), as the mapping shows.

Physical isolation gives testers real containment boundaries to work against, and every action is logged.

It governs the paths to third parties: vendor reach is severed by default and opened as time-bound sessions, which can help support Chapter V.

In milliseconds, over an out-of-band command, through Firebreak.

All questions

Map Control to your regulator’s language.

Walk through DORA with the Firevault team and see where physical evidence fits your programme. Alignment, not certification.