Feb 9 / Paul C Dwyer

DORA:Change Management

DORA and Change Management

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Embracing Change Management in the Era of DORA

The financial sector is undergoing a significant transformation, driven by the rapid evolution of technology and the increasing reliance on digital platforms. In this context, change management becomes a pivotal aspect of operational strategy, particularly with the introduction of the Digital Operational Resilience Act (DORA). This legislation is set to redefine how financial entities approach and manage change within their Information and Communication Technology (ICT) environments.

Main Requirements of DORA in Change Management

DORA introduces a comprehensive framework for ICT risk management, which inherently includes managing changes to ICT systems. The main requirements related to change management under DORA include:

ICT Risk Management Framework: Financial entities must establish and maintain a robust ICT risk management framework that includes policies, procedures, and measures to manage ICT risks effectively.

ICT Third-Party Risk Management: Given the reliance on third-party providers, institutions must ensure that changes in third-party services do not adversely affect their operational resilience.

Digital Operational Resilience Testing: Regular testing is required to assess the impact of changes and ensure that financial entities can withstand and quickly recover from ICT disruptions.

Actions to Meet DORA Requirements

To align with DORA’s change management requirements, financial institutions should:

Develop a Structured Change Management Process: Implement a formal process for managing changes, including risk assessment, testing, approval, and documentation.

Engage in Continuous Monitoring: Establish ongoing monitoring mechanisms to detect and respond to changes in the ICT environment that could introduce new risks.

Conduct Impact Assessments: Before implementing any change, conduct thorough impact assessments to understand potential effects on the operational resilience of the institution.

Ensure Third-Party Compliance: Regularly review and update contracts with third-party providers to include clauses that address change management and ensure alignment with DORA’s requirements.


The objectives of DORA are not isolated but form an integral part of the broader operational framework of the financial sector. By adopting a holistic approach to change management, senior members of the financial sector can ensure not only compliance with DORA but also enhance their institution’s overall resilience and agility. In an interconnected financial ecosystem, the ability to manage change effectively is a cornerstone of operational excellence and long-term success.