The Digital Operational Resilience Act (DORA) is a pivotal regulation for financial entities within the EU, aiming to ensure that these organisations can withstand, recover from, and adapt to ICT-related disruptions. Internal dependency management, a core component of operational resilience, refers to identifying, monitoring, and mitigating risks associated with dependencies on internal ICT resources, including systems, tools, processes, and teams.
This article outlines DORA’s requirements for internal dependency management, providing article references, extracts, and key actions to achieve compliance.
Article 4(1) mandates that financial entities must ensure operational resilience by embedding ICT risk management into their overall governance framework.
Article 5(1) requires financial entities to establish and maintain a comprehensive ICT risk management framework, which must include processes for identifying and managing internal ICT dependencies.
- Establish governance structures to oversee internal dependencies.
- Define policies for managing risks related to critical internal systems and resources.
- Regularly review the internal dependency landscape to identify any risks that could impact operational resilience.
Article 6(1) obligates entities to identify and classify all internal ICT dependencies that are critical for operational resilience.
Risk assessments must evaluate potential threats and vulnerabilities tied to internal ICT systems, processes, and dependencies.
“Financial entities shall identify and classify all ICT-related dependencies, including those within the organisation, that could adversely impact their operations in the event of a failure or disruption.”
- Maintain an inventory of internal ICT dependencies.
- Conduct regular risk assessments to identify vulnerabilities in internal systems.
- Assign criticality levels to dependencies to prioritise monitoring and mitigation efforts.
- Governance: Establish oversight
mechanisms to manage internal dependencies.
- Inventory and Classification: Maintain an
up-to-date inventory of internal ICT dependencies and classify their
criticality.
- Risk Assessments: Conduct regular
assessments of internal systems and dependencies.
- Monitoring and Testing: Implement
continuous monitoring and periodic resilience testing.
- Incident Response: Integrate internal
dependencies into incident management processes.
- Documentation: Maintain comprehensive
documentation to support audits and regulatory reviews.
- Criticality Focus: Apply the
proportionality principle to ensure critical dependencies are prioritised.
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Article
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Key Focus
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Article 4
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Governance and oversight of ICT risk management.
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Article 5
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Development of ICT risk management frameworks, including internal
dependency management.
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Article 6
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Identification and assessment of ICT dependencies and associated
risks.
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Article 10
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Continuous monitoring of ICT risk management frameworks, including
dependency management strategies.
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Article 11
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Periodic resilience testing for critical dependencies.
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Article 14
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Incident management processes for internal dependency disruptions.
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Article 15
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Reporting of major ICT incidents linked to internal dependencies.
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Article 16
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Documentation requirements to demonstrate compliance with DORA
mandates.
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Internal dependency management is a cornerstone of DORA compliance, ensuring that financial organisations can sustain operational resilience against ICT disruptions. By aligning with DORA’s mandates, your organisation can enhance its operational resilience while satisfying regulatory expectations. Regular monitoring, testing, and risk assessments will be key to achieving and maintaining compliance.
