Integrating EU DORA with ISO 27001: What CISOs Need to Know

Written by Laurent Dupont

Integrating EU DORA with ISO 27001:
What CISOs Need to Know

As of January 17, 2025, the Digital Operational Resilience Act (DORA) is officially in effect. For financial entities operating in the EU, this regulation marks a significant evolution in the regulatory landscape, placing digital resilience front and center.

If your organization is already ISO/IEC 27001 certified, you’re starting from a strong foundation. But DORA introduces new expectations that go beyond traditional information security.

In this blog, we’ll explore what DORA is, who it affects, and how to align your ISO 27001-based ISMS to meet the requirements.

What Is DORA?

The Digital Operational Resilience Act (DORA), formally Regulation (EU) 2022/2554, is designed to ensure that financial institutions across Europe can withstand and recover from ICT-related disruptions. It became applicable on January 17, 2025, and is now enforceable.

The goal? To elevate digital resilience to the same level of regulatory importance as financial and operational risk, because in today’s landscape, cyber risk is business risk.

Who Needs to Comply with DORA?

DORA applies to a wide range of financial entities, including:

  • Banks
  • Insurance companies
  • Investment firms
  • Payment service providers
  • ICT third-party service providers

If your organization operates in or supports the financial sector in the EU, DORA likely applies to you.

What are the DORA key components from a CISO perspective ?

For CISOs and security teams, DORA introduces several key obligations:

1. ICT Risk Management:

  • Establishes a comprehensive framework for managing ICT risks.
  • Requires financial entities to implement robust ICT risk management policies and procedures

2. Third-Party Risk Management:

  • Mandates monitoring and managing risks associated with third-party ICT service providers.
  • Includes key contractual provisions to ensure third-party compliance

3. Digital Operational Resilience Testing:

  • Encompasses a range of testing requirements, from basic to advanced, to ensure systems can withstand disruptions

4. Incident Reporting:

  • Requires timely reporting of major ICT-related incidents to competent authorities.
  • Enhances the ability to respond to and recover from incidents

5. Information Sharing:

  • Promotes the exchange of information and intelligence on cyber threats among financial entities

6. Oversight of Critical Third-Party Providers:

  • Establishes an oversight framework for critical ICT third-party providers designated by the European Supervisory Authorities (ESAs)

ISO 27001: A Strong Start, but Not the Finish Line

Organizations certified to ISO/IEC 27001 already have much of the foundational governance in place. However, DORA introduces additional governance layers, testing regimes, and regulatory interfaces that aren’t fully addressed by ISO 27001 alone.

Here’s how to close the gap:

Additional Deliverables

Task DORA Reference ISO 27001 Reference
Review internal governance and control frameworks Art. 5.1, 5.2.f, 6.4 5.1, 9, 10
Define a digital operational resilience strategy aligned with security policies Art. 6.8, 5.2.d 5.2, 6.2
Maintain a register of ICT third-party providers and report on new arrangements annually Art. 28.3 A.5.20
Launch a formal digital resilience testing program and conduct TLPTs at least every 3 years Art. 24–27 9.2.2, A.5.35
Conduct annual reviews of your ICT risk management framework Art. 6.5, 13.4–13.5 9.3
Run annual risk assessments specifically focused on legacy ICT systems Art. 8.7 8.2

Key Alignment Areas

Task DORA Reference ISO 27001 Reference
Integrate DORA into the ISMS context and requirement register - 4.1, 4.2, A.5.31
Update scope, roles, and responsibilities Art. 2, 4, 8.1 4.3, 5.1, 5.3
Enhance communication plans to include DORA reporting channels Art. 14, 45 7.4, A.5.5
Expand your asset register to reflect DORA requirements Art. 8.1, 8.4–8.6 A.5.9
Align business continuity and disaster recovery planning Art. 11.3–11.10 A.5.29–A.5.30
Strengthen incident response and notification processes Art. 17–19, 23 A.5.24–A.5.29
Update awareness and training programmes with board-level focus Art. 5.2.g, 5.4 7.3, A.6.3

Final Thoughts

Now that DORA is in effect, compliance isn’t optional, it’s part of doing business in the EU financial ecosystem. For CISOs, aligning ISO 27001 with DORA is a strategic opportunity: one that reinforces operational resilience while maintaining regulatory confidence.

ISO 27001 provides the structure. DORA adds precision.

If you haven’t already started mapping your ISMS to DORA requirements, now’s the time. The earlier you close the gaps, the smoother your compliance journey will be.

Need help reviewing your current alignment or building out your DORA compliance roadmap? Our team can support your efforts from strategy to implementation.

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