DORA might sound like a friendly explorer, but in the finance world, it’s the Digital Operational Resilience Act. And it’s not child’s play. The EU regulation came into force in January 2025, and aims to toughen up the digital defences of the financial sector. Think of it as the cybersecurity personal trainer for brokers, fintechs, and other financial entities offering services in the EU. Its ultimate goal is to protect your organisation from cyber threats and ICT meltdowns while helping the entire financial ecosystem bounce back faster and stronger when things go wrong. We’re breaking down DORA compliance and checking if your brokerage is ready.
Why DORA Matters for Brokers
DORA compliance isn’t just about having good antivirus software. It’s a full-blown, all-systems-go framework designed to ensure your operations are resilient, responsive, and ready for anything. This includes creating a robust plan to detect, prevent, and recover from cyberattacks, sharing threat intelligence with peers (because teamwork makes the dream work!), and shifting the focus from just capital buffers to digital fortification. If you think you’re too big, too robust or too protected to fail, then here’s a cautionary tale. A real-world wake-up call from one of the world’s largest banks.
Real-World Wake-Up Call: The Evolve Bank & Trust Breach
In July 2024, Evolve Bank & Trust, a banking-as-a-service provider, was targeted by a ransomware attack, resulting in the theft of personal information of more than 7.6 million individuals. The attackers used a multi-faceted approach involving a spear-phishing campaign and remote desktop protocol (RDP) vulnerabilities to gain initial access. Once inside, they deployed ransomware across the network and exfiltrated sensitive data before encryption. The ransomware used was a variant specifically designed to bypass traditional security measures in financial environments.
What Went Wrong?
The attackers accessed names, Social Security numbers, bank account numbers, and contact information for most personal banking customers and those of its Open Banking partners. This breach affected 7,640,112 individuals, who were offered 24 months of free credit monitoring and identity protection services. The breach also demonstrates the efficacy of credential stuffing and exploiting weak RDP configurations in gaining footholds within secure systems.
How DORA Could Have Helped
Had DORA’s provisions been in place, several measures might have mitigated the impact of this breach:
- ICT Risk Management: Regular assessments and robust policies could have identified and addressed vulnerabilities in remote access protocols like RDP.
- Incident Reporting: Structured frameworks for incident classification and reporting would have facilitated quicker response and coordination with authorities.
- Digital Operational Resilience Testing: Mandatory penetration and vulnerability testing might have uncovered exploitable weaknesses before attackers did.
- Third-Party Risk Management: Evaluating and monitoring third-party service providers could have reduced the risk associated with external partners.
- Information Sharing: Engaging with threat intelligence networks could have provided early warnings about emerging threats and attack vectors.
This incident serves as a stark reminder of the vulnerabilities present in financial institutions and the critical need for comprehensive regulatory frameworks like DORA to enhance cybersecurity resilience.
Let’s dive in to see how DORA can help your brokerage avoid these nightmare scenarios.
Already up to date with DORA? Read our 2025 MiCA Update.
DORA for Brokers: A Quick-Start Guide
Here’s what you need to know and how to implement. First off, the DORA regulation rests on five key pillars:
- ICT risk management
- Incident reporting
- Digital operational resilience testing
- Third-party risk management
- Information sharing. Let’s walk through what these mean in practice.
Step 1: Determine the Scope
Start by understanding which parts of DORA apply to your business and the vendors you work with. A good old-fashioned gap analysis will help you spot the differences between your current setup and DORA’s requirements. Once you see the gaps, you can start bridging them with a solid action plan.
Step 2: ICT Risk Management
Next up is ICT risk management. Here’s where you create a detailed risk plan that includes clear policies, procedures, and regular assessments. This plan shouldn’t live in a drawer; it needs to be part of your overall risk strategy and regularly reviewed to keep pace with evolving threats.
Step 3: Incident Reporting and Management
Then comes incident reporting. You’ll need a reliable process for spotting, classifying, escalating, and reporting incidents. DORA distinguishes between ‘minor’ and ‘major’ incidents, and those major ones need to be reported to the authorities. So yes, documentation matters — big time.
Step 4: Digital Operational Resilience Testing
Testing your systems is non-negotiable under DORA. Expect quarterly vulnerability testing, annual penetration testing, and a full Threat-Led Penetration Test (TLPT) every three years. These aren’t just checkboxes; they’re your chance to uncover hidden weaknesses and improve your recovery times.
Step 5: Third-Party Risk Management
Don’t forget your third-party partners. You’re expected to know where your vendors stand on compliance and to build that into your contracts. If a vendor drops the ball, you’ll need contingency plans to keep services running and your clients protected.
Information sharing is another key component. The cyber landscape shifts fast, and the more intel you have, the better. Connect with industry forums and regulatory bodies like ESMA, EBA, and EIOPA to stay in the loop and contribute to collective resilience.
Documentation & Governance
DORA isn’t just a technical checklist, it’s a cultural shift. Keep meticulous records of all activities related to compliance, including training sessions and testing outcomes. Also, establish a governance structure that defines roles and responsibilities for key team members, including your CISO, Compliance Officer, and DPO.
From Compliance to Competitive Advantage
Let’s be real, compliance doesn’t exactly scream excitement. But in today’s climate of eroding trust, it can become your brand’s secret weapon. A Forrester survey found that just 2% of US-based financial firms ranked as ‘strong’ on customer trust. The Thales Digital Trust Index 2025 backs this up, showing a global dip in digital confidence. Being compliant is great, but showing your customers that you’re proactive about it? That’s what builds real trust.
Finance Content That’s Compliant and Engaging
That’s where content marketing comes in. A specialised finance content agency (ahem, Contentworks!) knows how to communicate your compliance story in a way that’s engaging, clear, and confidence-boosting. We understand the importance of trust-building content, especially in a sector plagued by scams and uncertainty.
From fintech disruptors to traditional banks, we’ve helped countless financial brands and regulators connect with their audience. Whether you’re targeting retail traders or institutional clients, we tailor each piece of content to ensure maximum engagement and regulatory peace of mind.
Ready to Talk DORA Compliance?
DORA doesn’t have to be daunting, and with the right partner, it won’t be. We’ll help you create DORA compliant communications that go beyond ticking boxes. Reach out to the team at Contentworks Agency to get started.