Interpreting DORA's third party and ICT risk obligations in practice

A practical guide for legal, risk and security leaders responsible for interpreting
and overseeing third-party obligations under DORA.

DORA materially changes how third-party risk must be governed

The Digital Operational Resilience Act introduces explicit, enforceable obligations around ICT and third-party risk across the financial sector.

For many organisations, the challenge is not awareness of DORA. It is understanding what applies, where accountability sits, and how regulatory requirements translate into operating practices that will withstand scrutiny.

This guide is designed to support that interpretation.

Where DORA creates uncertainty in practice

While DORA is prescriptive in intent, it leaves room for interpretation in execution.

In practice, uncertainty most often arises around:

defining which suppliers fall within scope
understanding obligations for critical and important third-party providers
aligning legal, risk and security ownership
translating regulatory language into operational processes
demonstrating ongoing compliance over time

A practical operating model for Third-Party Risk Management

In practice, uncertainty most often arises around:

How DORA defines ICT and third-party risk obligations
What constitutes a critical or important third-party provider
The respective responsibilities of regulated entities and suppliers
How oversight, monitoring and exit planning are expected to operate
What proportionality means under DORA in practice
How DORA aligns with existing third-party risk and operational resilience programmes

For readers looking to understand how these regulatory expectations align with the practical operation of third-party risk programmes, a more detailed overview of Third-Party Risk Management in practice is available here.

Intended audience

This guide is intended for legal, risk, compliance and security leaders responsible for interpreting, implementing or overseeing DORA-related third-party and ICT risk obligations.

It is particularly relevant where accountability spans multiple functions and requires coordinated governance.

Purpose of this guide

This guide does not provide legal advice and does not restate the regulation.

It is intended to help organisations understand how DORA’s third-party and ICT risk requirements are commonly interpreted, operationalised and governed in practice, particularly within UK-regulated financial services firms.

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Applying this in practice

Many organisations find that the most difficult aspect of DORA is not understanding the regulation, but translating it into operating practices that are clear, consistent and defensible.

If you would find it helpful to discuss how DORA applies to your organisation’s third-party and ICT risk approach, you can request a short exploratory conversation.