The Digital Operational Resilience Act (DORA) and its Challenges
The Digital Operational Resilience Act (DORA) marks a significant step forward in ensuring that financial institutions across the European Union are prepared to face digital disruptions—be it cyberattacks, technological breakdowns, or any other IT-related incidents.
However, as with any regulatory framework, the path to full compliance isn’t without its obstacles. According to a recent Deloitte survey, the most significant challenge faced by financial institutions in implementing DORA is creating and maintaining a comprehensive information register. This register is designed to map out an institution’s entire ICT ecosystem, detailing critical assets, third-party service providers, their roles, and the contractual obligations that underpin the institution’s digital operations, as well as the risks associated with the elements in this register.
The main pain points revealed in the survey include:
- Mapping subcontracting chains: Only 29% of institutions have identified service providers beyond level 1, making it difficult to gauge full exposure to digital risk.
- Incomplete documentation: Over one-third of institutions have yet to document all their business functions alongside the ICT assets and contracts they rely on.
- Concentration risk: Institutions often fail to assess the critical dependencies within their supply chain, leaving them vulnerable to unmonitored risks.
With these challenges in mind, Brainframe offers a solution that simplifies the complex processes involved in DORA compliance. From creating a dynamic risk register to allowing you to track third-party vendors and assess their risks, Brainframe provides organizations with the tools they need to meet DORA’s demands.
Getting the Risk Register Right with Brainframe
The information register is a critical component of DORA compliance. It helps organizations map out their entire ICT ecosystem—assets, third-party providers, and their roles—giving financial institutions the transparency needed to manage digital risks effectively. This register is fundamental to identifying critical functions, assessing risk, and ensuring the institution meets DORA’s resilience standards.
However, compiling this information isn’t always straightforward:
- Mapping subcontractors: Many organizations find it difficult to trace their entire subcontracting chain. Only a fraction of institutions go beyond their direct connections, which leaves them exposed to potential risks within their extended supply chain.
- ICT asset documentation: Ensuring every asset is properly documented and linked to its corresponding business function and responsible stakeholder can be a complex task. Many institutions still struggle to integrate these details into their risk management systems.
- Keeping it current: An outdated register can defeat the purpose. As digital environments evolve, keeping the information register up to date becomes an ongoing challenge.
Brainframe helps organizations address these issues:
- It facilitates the creation of a comprehensive risk register, mapping both primary and secondary providers to ensure all critical dependencies are captured, and linking it to the corresponding business processes.
- Risk management per asset: Brainframe allows organizations to manage risks individually for each ICT asset type, ensuring that risks are accurately assessed and tracked on a case-by-case basis.
- Easy documentation: By simplifying the connection of ICT assets, business functions, and third-party contracts, Brainframe ensures that the data is integrated into your risk management framework.
With Brainframe’s support, institutions can ensure they meet DORA’s rigorous demands while staying ahead of the digital risks that could disrupt their operations.
Mapping ICT Assets to Business Processes
Mapping ICT assets to business functions is one of the trickiest challenges in DORA compliance. On top of listing your hardware and software; you must understand how each asset supports a business function, how it interacts with third-party providers, and what the consequences are if that asset fails. Given the complexity of modern digital ecosystems, this is often easier said than done.
For many institutions, the struggle lies in understanding the full context—which assets are critical, which are interconnected, and which third-party providers are involved in delivering key services. Without a clear map, it's easy to miss gaps.
Here’s where Brainframe makes a difference:
- Integration: Brainframe helps connect your business functions directly to the ICT assets and their corresponding third-party providers. Instead of dealing with isolated chunks of information, Brainframe creates a unified view that links business processes with the technology that supports them. This ensures that critical dependencies are clearly identified and tracked.
- Documentation made easy: Brainframe simplifies process-to-asset mapping by allowing you to easily track and document ICT assets, their roles in business functions, and the providers that ensure their operation. No more guessing about which third-party service powers a critical function; the tool gives you the full picture.
- Risk management: By integrating business processes with the corresponding ICT assets, Brainframe enables you to assess and manage risks at a granular level. Whether it’s a failure in a key asset or a potential disruption from a third-party provider, you can track and mitigate risks with precision.
Third-Party Risk Management
Under DORA, third-party risk management is a critical pillar of ensuring operational resilience. Financial institutions are required to monitor and manage their relationships with third-party service providers—whether it’s cloud providers, software vendors, or any external party that plays a role in delivering their services. The challenge lies in the complexity of these relationships, particularly when it comes to managing subcontracting chains.
DORA requires institutions to not only identify their direct vendors but also understand and assess the risks posed by their subcontractors and tiered service providers. The issue? Many organizations are still struggling to identify and document every player in their supply chain. According to the Deloitte survey, only 29% of institutions have tracked service providers beyond their direct relationships, leaving gaps that could expose them to significant risk.
Brainframe helps organizations meet these challenges:
- Comprehensive identification and tracking: Brainframe enables institutions to go beyond just their immediate vendors by helping them track every level of the supply chain. Whether it’s primary providers or subcontractors, Brainframe creates a holistic view of all third-party relationships, ensuring that no critical link is overlooked.
- Continuous monitoring: Brainframe makes it easy to monitor third-party vendors on an ongoing basis, tracking performance, contractual obligations, and any potential risks that could arise. This continuous oversight ensures that your supply chain remains resilient and compliant over time.
- Improved resilience and risk mitigation: By offering deep insights into third-party risk, Brainframe helps organizations assess the impact of dependencies and create strategies to mitigate potential disruptions. Whether it’s a key cloud service provider or an overlooked subcontractor, you’ll have the tools to manage risks effectively and ensure that resilience is embedded across your entire ecosystem.
Get a complete risk register
Ghost software—untracked or unauthorized software—presents a significant and often overlooked risk. These are applications that exist on a network but haven’t been properly recorded, tracked, or vetted. They could be old legacy systems, unauthorized tools, or new software installed without proper oversight. Whatever the cause, ghost software can lead to unmitigated vulnerabilities, potential breaches, and compliance issues, especially in a framework like DORA, which emphasizes digital resilience and security.
The challenge? Organizations often lack visibility into every corner of their IT ecosystem, allowing ghost software to slip through the cracks. This becomes even more problematic when these programs:
- Create security gaps: Untracked software may not receive the same security patches or updates, leaving organizations exposed to known vulnerabilities.
- Conflict with compliance standards: Unauthorized software can lead to violations of policies or regulations, like DORA, if it's not properly documented or integrated into risk management systems.
- Increase operational complexity: Managing an inventory of all the tools and software used within an organization quickly becomes overwhelming, especially as digital environments grow.
Brainframe helps address these issues by providing a robust mechanism for detecting and managing ghost software:
- Automatic detection: Brainframe scans the entire ICT ecosystem and flags untracked or unauthorized software, ensuring that even the most hidden applications are identified.
- Risk management integration: Once detected, ghost software is integrated into the risk management process, where it can be assessed for potential threats, compliance risks, and other vulnerabilities. This enables organizations to prioritize remediation efforts effectively.
- Visibility and control: With Brainframe, organizations gain full visibility into their SaaS landscape, helping them stay compliant and secure by ensuring all software is properly tracked, documented, and risk-assessed.
The Path Forward with Brainframe
Compliance with DORA is a necessity for financial institutions aiming to ensure their digital resilience. DORA sets the standard for how organizations must protect their critical systems, manage third-party risks, and continuously monitor their digital ecosystem to withstand the inevitable cyber threats and operational disruptions. The importance of operational resilience cannot be overstated—failure to comply exposes institutions to regulatory penalties but more importantly to potentially disastrous security breaches and service outages.
Brainframe goes beyond just helping organizations meet DORA’s current requirements. It’s a platform designed to evolve alongside regulatory changes and the increasing complexity of digital ecosystems. Here’s how it helps organizations build a resilient, compliant future:
- Continuous updates and improvements: As DORA requirements evolve and the threat landscape shifts, Brainframe stays ahead of the curve, ensuring that its features and capabilities are always up-to-date with the latest regulatory and security standards. This ensures long-term compliance without the need for constant manual updates.
- Comprehensive resilience building: Brainframe helps organizations not only comply with the technicalities of DORA but also build resilience into every part of their operations. From due diligence during third-party vendor selection to incident management when disruptions occur, Brainframe is there to ensure that resilience is embedded into daily workflows.
- Informed strategic decision-making: Brainframe offers powerful into risks, vulnerabilities, and opportunities, allowing organizations to make more informed decisions. Assessing new vendors, updating their risk register, or responding to incidents, Brainframe’s tools provide the platform, data and clarity needed to drive strategic decisions that enhance resilience.
By adopting Brainframe, organizations can build a resilient foundation that can withstand any digital disruption. With the platform’s proactive approach to managing digital risks, institutions are better equipped to navigate the evolving regulatory landscape, ensuring both compliance and long-term success.
