Prepare for DORA Part 7: Long-Term Strategy – How to Build Continuous Resilience
- Chenyun Chu
- Apr 3
- 4 min read
The first six parts of our DORA blog series focused on interpreting regulatory expectations, implementing controls, and managing third-party risks. But as financial institutions move past initial compliance efforts, they face a bigger challenge: how to sustain cyber resilience over the long term.
DORA isn’t just about meeting checklists—it’s about creating a continuous, adaptive resilience strategy that evolves with threats, technology, and your ICT ecosystem. In this final installment, we explore how to move from point-in-time compliance to ongoing operational resilience.
1. From One-Time Compliance to Continuous Readiness
Traditionally, compliance efforts in financial institutions have been driven by static, annual activities—such as scheduled audits, periodic vendor reviews, or point-in-time risk assessments. While that approach may satisfy legacy regulations, DORA explicitly shifts the focus from checkbox-style compliance to ongoing operational resilience.
The intent behind DORA is not only to verify that financial institutions have security controls in place, but also that they are continuously effective, monitored, and adaptive to emerging threats and operational changes.
Here are key areas where the transition from one-time to continuous is most evident:
1-1 Security Monitoring is No Longer Occasional — It Must Be Ongoing
DORA Article 8 requires financial institutions to implement continuous monitoring of their ICT systems, including third-party services. This goes beyond scheduled vulnerability scans or quarterly system health checks.
Organizations must:
Continuously scan for vulnerabilities and misconfigurations
Detect security posture drift in real time
Implement alerting and escalation procedures across internal and vendor ecosystems
Example: A financial institution uses automated asset monitoring and detects a newly exposed cloud subdomain—previously untracked—prompting immediate remediation before exploitation.
1-2 Resilience Testing Must Be Iterative and Threat-Driven
DORA Articles 25–27 require realistic, scenario-based testing of systems, people, and processes.
This includes:
Threat-led penetration testing (TLPT)
Inclusion of critical third parties in simulation exercises
Regular testing of backup, failover, and continuity plans
Post-mortem reviews to drive continuous improvement
Example: A bank simulates a ransomware attack that disrupts both internal systems and vendor-hosted services. The results prompt revisions to its incident coordination playbook and contact protocols with suppliers.
1-3 Risk Assessments Must Evolve with Business and Technology
Risk isn’t static—and neither should your assessments be. Under DORA, institutions must update risk profiles when:
Migrating to new cloud or SaaS services
Adopting AI or API-heavy integrations
Merging/acquiring other businesses
Adding or changing ICT vendors
Example: After onboarding a new fintech analytics vendor, a Swiss institution automatically triggers a reassessment workflow to evaluate data protection, breach notification SLAs, and geographic hosting compliance.
1-4 Incident Response Must Be Fast, Coordinated, and Regulator-Ready
DORA Articles 19–20 require that major ICT incidents be reported to regulators within hours, not days. Institutions need:
Clearly defined incident classification thresholds
Pre-built regulatory notification workflows
Role-based escalation trees that include third parties
Dry runs that simulate joint incident response with vendors
Example: When a partner’s API outage affects real-time payment processing, the institution’s platform flags it, classifies the incident as “significant,” and initiates its DORA-aligned notification protocol within 3 hours.
2. Core Principles of Long-Term Resilience Under DORA
Building long-term resilience means embedding the following principles into your organization’s security, operations, and governance structures:
2-1 Visibility
Maintain real-time awareness of:
Internal systems and services
External attack surfaces
Vendor and third-party integrations
Tip: Use automated discovery and monitoring tools to ensure you can quickly detect unknown assets, misconfigurations, or unsanctioned SaaS use.
2-2 Governance
Ensure oversight flows from the top:
Engage the board on cyber risk (DORA Article 4)
Assign clear accountability to a dedicated ICT risk function (DORA Article 5)
Align security priorities with business resilience objectives
Tip: Create quarterly executive dashboards that connect cyber resilience KPIs to operational and regulatory goals.
2-3 Automation
Manual processes are too slow and error-prone for today’s complex ICT environments.
Automate:
Patch and vulnerability management
Penetration and API security testing
Threat intelligence ingestion
Incident playbook execution
Example: A bank auto-remediates policy violations in Microsoft 365 using workflow integrations with their security platform.
2-4 Adaptability
Treat every test, breach, or vendor change as a chance to learn.
Build feedback loops to:
Regularly update SLAs and contracts
Incorporate real-world threat intelligence into controls
Expand testing scope to match business growth
Tip: Schedule periodic purple team exercises that pair internal and vendor staff in joint readiness drills.
3. Build a Unified Platform for Resilience
To truly scale and sustain resilience, institutions must shift from fragmented tools to an integrated platform that spans internal systems and third-party ecosystems.
A unified resilience platform should include:
Centralized Visibility Across ICT Assets
Track all assets and their relationships—on-prem, cloud, SaaS, and vendor systems.
Example: A dashboard consolidates posture data from Microsoft 365, AWS, and a third-party risk scoring tool to track changes and misconfigurations.
Integrated Third-Party Risk Management
Build end-to-end workflows that:
Automate onboarding risk assessments
Flag SLA violations or expired certifications
Trigger reassessments on vendor or service changes
Example: A vendor's contract is auto-flagged for review after the provider moves hosting to a new data region outside Switzerland.
Coordinated Incident Response
Tie together alerts, triage, escalation, and regulatory reporting.
🛠 Example: A threat feed detects a compromise at a critical cloud provider. The platform launches the response playbook, notifies stakeholders, and generates a draft incident report for submission.
Unified Analytics & Reporting
Deliver tailored insights to security teams, risk managers, and executive leadership.
Tip: Align platform reporting to DORA articles and thresholds so stakeholders know what matters—and when.
Built-in Regulatory Intelligence
Stay ahead of compliance changes with integrated updates and alerts.
Example: A change in DORA Article 30 requirements triggers updates in your contract review workflows and highlights impacted vendor agreements.
4. Conclusion: Resilience Is a Journey, Not a Deadline
DORA raises expectations, but the bigger opportunity is to create a resilient-by-design organization: one that can evolve with its risks, suppliers, and services. With the right combination of automation, testing, governance, and collaboration, you don’t just meet DORA, you lead through it.
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