Sector reports
Spark02 Sector reportsOctober 202618 min read

When the cloud goes down, who answers?

DORA's first two years. The rule that turned Europe's "what if your systems fail?" question into law: who paid how much, what it fixed, and the market that grew behind it.

DORA in 60 seconds
  • The European Union's digital resilience law for the financial sector. Its official name is Regulation (EU) 2022/2554.
  • It has applied directly since 17 January 2025. Member states don't need to pass their own laws.
  • It covers 20 different types of financial firm: banks, payment institutions, e-money firms, insurers, investment firms, crypto asset service providers and more.
  • The real novelty: a bank's technology suppliers are now inside the supervisory net too. 19 giants such as AWS, Microsoft, Google Cloud and SAP sit directly under European supervisors.
  • The first year's scorecard: 3,383 major ICT incidents were reported in 2025. Roughly one in three started on the supplier's side.
  • The hardest part for banks wasn't technical. It was the inventory: which supplier, which service, which subcontractor, which contract clause.
  • That pain created its own market: supplier risk software, incident reporting tools, register automation, attack simulation services.
01What it is

What is DORA, and where did it come from?

DORA is the European law that makes a bank write down, in advance, what it will do when its systems go down. The name stands for Digital Operational Resilience Act.

Before DORA, the picture was scattered. Every country had its own rules: BAIT in Germany, other circulars elsewhere, and EBA outsourcing guidelines on top. ICT risk sat as a sub-item under the general operational risk heading. Meanwhile banks had long since come to depend on a handful of big cloud and software companies. One of them stumbling could stop hundreds of firms at once.

The EU's answer was a single rulebook. It has two goals: manage ICT risk in the same language from country to country, and bring the tech giants behind the banks under direct supervision for the first time.

Timeline

  1. September 2020The European Commission proposed DORA as part of its Digital Finance Package
  2. December 2022The law was adopted and published in the EU Official Journal
  3. 16 January 2023It entered into force and a two year preparation period began
  4. 2024The technical standards that fill in the details were published one by one
  5. 17 January 2025Application began. No transition period
  6. February and April 2025The TARGET payment system outage and the Iberian Peninsula blackout became the first big tests
  7. April 2025Banks submitted their supplier registers (Register of Information) for the first time
  8. 18 November 2025European supervisors named 19 critical technology providers
  9. 19 November 2025The Commission published its Digital Omnibus proposal, aimed at simplifying reporting
  10. March 2026Second annual submission of the register
  11. 3 June 2026The first annual report on major ICT incidents under DORA came out
  12. October 2026Today
  13. December 2026BAIT is fully withdrawn for banks in Germany, leaving the field to DORA
  14. 17 January 2028End of the first attack simulation (TLPT) cycle for selected firms and the law's first major review
02Who it covers

Who does it apply to?

Short answer: almost everyone working under a licence in the EU, and everyone who sells them technology. The Commission's impact assessment puts more than 20,000 firms in scope.

Directly in scope (20 types of firm)

  • Banks and credit institutions
  • Payment institutions and electronic money institutions
  • Investment firms, asset managers, exchanges, clearing houses
  • Insurance and reinsurance companies, insurance intermediaries
  • Crypto asset service providers
  • Crowdfunding platforms, credit rating agencies, pension funds

Being small doesn't get you out. A payment institution licensed under PSD2 is inside DORA even with a team of five. The only difference is how deep it goes: smaller firms get a lighter framework, and the heaviest tests fall only on large, systemic ones.

Pulled in indirectly

This is where the real surprise is. DORA brings technology companies inside in two ways:

  1. 01Through the contract. Every software, cloud or data provider that delivers a critical service to a bank runs into the DORA clauses the bank is obliged to get signed: audit rights, incident reporting, an exit plan, subcontractor transparency. It makes no difference whether the company sits in Istanbul, Bangalore or California.
  2. 02Through direct oversight. Providers of systemic importance are designated "critical" (CTPP) and come under the direct watch of European supervisors. The first list has 19 names.

Who's left out? A fintech standing behind a bank in a BaaS model isn't directly subject to DORA if it has no licence of its own. But as the bank's supplier it has to carry every DORA clause in the contract. So in practice it's inside too.

03Five pillars

Five pillars: what exactly does DORA ask for?

DORA wants answers to five questions. What they all share is that the answer has to live in a working process, not on paper.

  • ICT risk management

    The question it asksDo you know your risk, and who owns it?
    What it means inside a bankThe board is directly responsible for ICT risk. An asset inventory, a risk framework, backup and recovery plans must be written down and tested
  • Incident management and reporting

    The question it asksWhen something breaks, how fast do you tell people?
    What it means inside a bankOnce a major incident is classified, the first notification goes in within 4 hours (no later than 24 hours after it was detected), an intermediate report at 72 hours, a final report within a month
  • Resilience testing

    The question it asksDoes it actually work, and have you tried it?
    What it means inside a bankAnnual tests for everyone. For selected large firms, TLPT every three years on live systems, with teams that act like real attackers
  • Third party risk

    The question it asksWho do you depend on, and what happens if they go?
    What it means inside a bankA record of every technology contract (Register of Information), mandatory contract clauses, an exit plan for critical services
  • Information sharing

    The question it asksDo you share the threats you see with others?
    What it means inside a bankSharing cyber threat intelligence within the sector. Not mandatory, but encouraged

The detail people miss: The fourth pillar looked like the quietest one, but it created the most work. A bank's technology contracts number in the hundreds, and behind each of them sit more subcontractors.

04Domino

Domino: pull the plug on a provider

When a single technology provider goes down, how many firms, how many countries, how many services go dark? Don't read about it, try it.

Pick a providerBefore DORA

Pick a provider, then pull the plug.

DE · Germany
North BankBank
  • App
  • Card
  • Transfer
Runs onCloud ACore banking softwareCard processorShared payment rail
Rhine BankBank
  • App
  • Card
  • Transfer
Runs onCloud BCore banking softwareCard processorShared payment rail
Digital BankDigital bank
  • App
  • Card
  • Transfer
Runs onCloud ACard processorShared payment rail
NL · Netherlands
Delta BankBank
  • App
  • Card
  • Transfer
Runs onData centreCore banking softwareCard processorShared payment rail
Alpha PayPayment institution
  • App
  • Card
  • Transfer
Runs onCloud ACard processorShared payment rail
FR · France
Beta PayPayment institution
  • App
  • Card
  • Transfer
Runs onCloud BCard processorShared payment rail
Gamma MoneyE-money institution
  • App
  • Card
  • Transfer
Runs onCloud ACard processorShared payment rail
Loire BankBank
  • App
  • Card
  • Transfer
Runs onData centreCore banking softwareCard processorShared payment rail
ES · Spain
Atlas InsuranceInsurer
  • App
  • Transfer
Runs onCloud BData centreShared payment rail
Invest PlatformInvestment platform
  • App
  • Transfer
Runs onCloud AShared payment rail
Ebro BankBank
  • App
  • Card
  • Transfer
Runs onData centreCore banking softwareCard processorShared payment rail
Tajo BankBank
  • App
  • Card
  • Transfer
Runs onCloud BCore banking softwareCard processorShared payment rail
Firms affected
0 / 12
Countries affected
0 / 4
Services in the dark
0 / 34
First word to customers
?
Illustrative. Under DORA, the first notification goes in within 4 hours of an incident being classified as major.

The simulation is illustrative. The firms and providers are fictional; the dependency structure is inspired by the table in the ESAs' 2025 incident report.

What the simulation tells you: DORA doesn't prevent the outage. It changes how many people it touches, for how long, and how much they're left in the dark.

From real life: About 29% of the major ICT incidents reported in Europe in 2025 started at a provider, and a third spilled across borders. The TARGET outage in February 2025 and the Iberian Peninsula blackout in April 2025 showed that a failure at a single point can trigger reports from dozens of firms.

05Scorecard

The first two years in numbers

The most striking finding: most of the major incidents reported in 2025 came not from hackers but from ordinary system failures and outside events.

  • 3,383

    What it tells youMajor ICT incidents reported in the EU financial sector in 2025. An average of 0.18 per firm
    SourceESAs annual incident report, June 2026
  • ~29%

    What it tells youShare of incidents that started at a third party provider
    SourceESAs annual incident report
  • 1/3

    What it tells youShare of incidents with cross-border impact. Shared infrastructure creates a domino effect
    SourceESAs annual incident report
  • ~15%

    What it tells youShare of incidents left out of the statistics because the final report didn't arrive on time
    SourceESAs annual incident report
  • 19

    What it tells youCritical technology providers placed under the direct oversight of European supervisors
    SourceESAs, November 2025
  • 40%

    What it tells youShare of firms in Luxembourg that had submitted their register two weeks before the deadline (16 March 2026)
    SourceCSSF
  • 43%

    What it tells youShare of firms saying they spent more than 1 million euros over two years on DORA and similar compliance
    SourceRubrik Zero Labs survey
  • 70%

    What it tells youShare of firms that think DORA will permanently raise their technology running costs
    SourceMcKinsey survey
  • 37%

    What it tells youShare of firms saying their technology suppliers raised prices after DORA
    SourceVeeam survey, 2025

Two big tests: The TARGET payment system outage in February 2025 and the Iberian Peninsula blackout in April 2025 each triggered a large number of notifications on their own. One failure means separate reports from dozens of firms. These two events explain better than anything why DORA is so focused on shared infrastructure.

The good news: According to the report, the impact on customers and transactions stayed limited in most incidents. Detection and recovery usually worked fast.

Note: The survey figures come from different samples, and some measure DORA together with UK rules. They show the direction, not a precise measure of the market.

06Challenges

What it put on banks' plates

The biggest challenge wasn't technology. It was information. Banks had never written down their own technology dependencies in this much detail.

  1. 01The never ending spreadsheet. The Register of Information isn't a single list. It's a data model made of linked tables. Dozens of fields for every contract, an identifier for every supplier, and for every service, which function it supports and who it's been subcontracted to. If the file sent to the supervisor has errors, it comes back, gets fixed and is sent again. Even in 2026 that loop hasn't ended.
  2. 02The contract table. Hundreds of contracts needed mandatory clauses added: audit rights, incident reporting, exit plans. A small bank can't negotiate with a big cloud provider, so it signs the standard addendum. Delays in the subcontracting rules also left negotiations hanging for months.
  3. 03Clock pressure. Deciding within hours whether an incident is "major" and filing the first notification within 4 hours means a new on-call setup at most banks. On top of that, a single shared infrastructure failure demands a separate report from every firm.
  4. 04The talent gap. The red teams and threat intelligence that TLPT needs are scarce. Team leads are expected to have at least 5 years of penetration testing experience. In Europe, people with that profile are few and far between.
  5. 05Cost and fatigue. Almost half of the firms surveyed went past one million euros in two years. Pressure on IT and security teams grew, and suppliers passed the cost of DORA compliance on in their prices.
  6. 06A pile of rules. DORA didn't come alone. NIS2, GDPR, the Cyber Resilience Act and the AI Act touch the same systems from other angles. AFME, the association for Europe's capital markets, complains in particular that DORA and the Cyber Resilience Act put double rules on the same banking applications.
  7. 07The burden on the small. There is a proportionality principle, but the register, incident reporting and contract clauses are the same for a small payment institution. For a fintech with no compliance team, that's a serious fixed cost.
  8. 08Slower product speed. (Our observation) Adding a new partner or SaaS tool is no longer just a technical integration. First comes DORA due diligence, then contract addenda, then a register update. At a bank, that adds a few weeks, sometimes months, to the time it takes a new product to go live.
07What it fixed

What did it fix?

DORA's real achievement is drawing the first technology map of Europe's financial system. Without that map, nobody could talk about concentration risk or hold the giants to account.

  • 27 countries, one language. A single regulation replaced the national rules. A group operating in more than one EU country no longer follows a separate ICT guide for each. In Germany, BAIT is fully withdrawn for banks at the end of 2026.
  • Hidden dependency became visible. The registers banks submitted became the main data European supervisors used to pick the 19 critical providers. So the spreadsheet banks struggled with turned into the ruler for measuring systemic risk.
  • Balance at the table with the giants. A small bank can't audit AWS or Microsoft on its own. Now European supervisors do it. A critical provider that breaks the rules can be fined up to 1% of its average daily worldwide turnover, for up to six months.
  • Shared incident data. For the first time, Europe collected major ICT incidents in the financial sector under one definition and in one format. The first report, with 3,383 incidents, is the starting line for every debate from here on.
  • The topic moved up to the board. ICT risk is no longer the IT manager's problem but something the board is responsible for, with its signature on it. In McKinsey's survey, the large majority of firms say they put DORA on the board's agenda.
  • People started asking "what if they leave?" The mandatory exit plan for critical services brought supplier dependency, unspoken for years, to the table.
  • A shared language in contracts. (Our take) Because every bank asked for the same clauses, suppliers prepared standard DORA addenda. The first year was painful, but over time a template emerged that could speed up new partnerships.
08Elif

A customer's story: Elif's three outages

An illustrative story. The character is fictional; the events and rules behind it are real.

Elif runs a small online shop in Cologne selling handmade ceramics. Her account is with a mid-sized digital bank, and she takes payments through a payment institution. She has never heard of DORA. But in the last three years she has run into it three times.

My account
Balance1.240,50 €

We're experiencing a technical issue.

Pending payments
Incoming payment48,00 €Pending
Incoming payment112,50 €Pending
Incoming payment36,90 €Pending

Customer service · Wait time: 34 min

November 2023. A silent outage.Friday evening, customer payments aren't landing in her account. The app shows a single line: "We're experiencing a technical issue." The call centre doesn't know when it will be fixed. On Monday everything fixes itself. Over the weekend Elif cancels three orders, because she doesn't want to ship before she sees the money. Nobody tells her what happened.

My account
My accountYour outgoing transfers may be delayed
13:12

There's an outage on Europe's shared payment system (TARGET). The problem isn't on our side. Your transfers are queued and safe. Next update: 16:00

Outgoing transfer320,00 €Queued

February 2025. Same kind of outage, a different attitude.Europe's TARGET payment system stalls for hours. Elif's outgoing transfer is delayed. This time the difference is this: within a few hours an information box appears in the app, followed by an email. The problem isn't at the bank but in the shared infrastructure, the payments are queued, the estimated time is such and such. DORA gave firms a duty to inform customers about major incidents that affect their money. Elif doesn't know that, but she feels the difference: instead of panicking, she plans.

My account
Invoice collectionComing soon

We're finishing the security and continuity checks on our new infrastructure provider.

Spring 2026. A delayed feature.Her bank had announced invoice payment and collection for small businesses as "coming soon". The launch slips by two months. Elif is annoyed. What's happening in the background (our estimate): the new invoicing infrastructure provider the bank picked will support a critical function, so it's going through DORA due diligence, audit and exit clauses are being added to the contract, the register is being updated. All Elif gets is a delay. But the same process means that if that provider ever goes under, the bank can still process her money another way.

The story in short: Customers don't see DORA directly. What they see is two things: faster, more honest news when something breaks, and a slightly longer wait for new features. A good bank is one that can balance the two.

09Market

The market DORA opened

Yes, products built specifically for DORA appeared, and a category was born. Every pillar banks struggled with now has a piece of software or a service sitting across from it.

  • Register automation

    What it solvesCollects supplier data and produces a validated file in the format the supervisor wants
    Example playersFormalize, OneTrust, Panorays, Prevalent
  • Third party risk management (TPRM)

    What it solvesMonitors suppliers continuously, keeps questionnaires and scores, shows concentration risk
    Example playersBitSight, UpGuard, Panorays, Riskonnect
  • Compliance automation (GRC)

    What it solvesBrings the five pillars together in one dashboard, produces evidence and an audit trail
    Example playersVanta, OneTrust, LogicGate, SureCloud, CyberArrow
  • Incident classification and reporting

    What it solvesClassifies the incident against DORA criteria, runs the 4 hour, 72 hour and one month clocks
    Example playersDORA modules of GRC platforms
  • TLPT and threat intelligence

    What it solvesRed team testing on live systems with real attacker scenarios
    Example playersRed team firms, intelligence platforms such as Filigran
  • Data resilience

    What it solvesBackup, recovery and recovery from ransomware
    Example playersVeeam, Rubrik
  • Cloud provider packages

    What it solvesReady made DORA mappings and contract addenda from the cloud giants for banks
    Example playersMicrosoft and the other cloud giants
  • Consulting and legal

    What it solvesGap analysis, register submission, contract addendum templates
    Example playersThe Big Four, law firms

How big the market is. There's no market measure specific to DORA, but for the closest category, third party risk management, research firms put the size at between $7.7 and $10.8 billion in 2025, with 14-16% annual growth. Nearly all of them count DORA as the main growth engine in Europe. The numbers vary a lot from firm to firm; the direction is the same.

Price range. Platforms for large firms quote on request. Tools aimed at mid-sized firms show plans starting at around 900 euros a month.

Three layers of the market

  1. 01Software: register, TPRM, GRC. The fastest growing layer. In 2024 most of these were general compliance tools; in 2026 there are new players positioning themselves as "built for DORA".
  2. 02Services: consulting, legal, red teaming, threat intelligence. TLPT's 2028 timetable will keep this layer busy for the next two years.
  3. 03The supplier side: For every SaaS company selling to banks, "we're DORA ready" is now a sales argument. A supplier that can't offer a ready contract addendum, an audit package and exit plan support is more and more often knocked out before the tender (our observation).

Watch out: Buying a tool doesn't solve the problem. The shared view in the industry is that the pain in the register comes not from the tool but from how messy the underlying data is.

10Outlook

What will change in the years ahead?

DORA's first two years went on preparation; with 2026 the supervision phase began. From here its effect will move out of compliance teams and into business models.

  1. 01From guidance to enforcement. National supervisors went into the field in 2026 and are automatically cross-checking register data. The ceiling on fines varies by country, for example up to 5 million euros in Germany. The first public fines will be a test for those who say "DORA stays on paper".
  2. 02Fewer but stronger suppliers. (Our estimate) Every new supplier means new rows in the register, new contract addenda and new monitoring. Banks will move to cut their supplier count and work with large players that are DORA ready.
  3. 03The concentration paradox. (Our take) DORA came out to reduce concentration risk on a handful of giants. But the ones that find compliance easiest are those same giants with ready made packages. The rule may, without meaning to, push risk towards the very place it's trying to reduce it. How supervisors balance this is an open question.
  4. 04The maths changes for small fintechs. The fixed cost of running on your own licence went up. Going through a bank or a licensed platform (BaaS, embedded finance) may make sense for more companies. On the other hand, banks will also put DORA maturity first when they choose partners.
  5. 05Simpler reporting. The Commission's Digital Omnibus proposal would gather incident reports under NIS2, GDPR and DORA into a single entry point run by ENISA: report once, and it goes to everyone who needs it. If the proposal becomes law, the channel is planned to open in about 18 months.
  6. 06The big review in 2028. The Commission will assess DORA from scratch by 17 January 2028. Proportionality is in focus: is the burden on small firms in proportion to their systemic importance?
  7. 07AI is entering the register. The AI services banks use are ICT services too. Model providers will show up in registers, in contract addenda and maybe one day on the critical provider list. The UK is facing open political pressure in this direction.
11UK

The UK: same film, different cinema

The UK isn't in the EU, but it's giving its own answer to the same question. The Critical Third Parties (CTP) regime is the British version of DORA's critical provider leg.

  • Legal basis

    EU (DORA)Regulation (EU) 2022/2554
    UK (CTP regime)Financial Services and Markets Act 2023
  • When the rules started

    EU (DORA)17 January 2025
    UK (CTP regime)1 January 2025
  • First critical provider list

    EU (DORA)18 November 2025, 19 companies
    UK (CTP regime)10 July 2026, 4 companies (in effect from 13 July)
  • Who's on the list

    EU (DORA)Cloud, data centre, telecoms, IT services and financial data providers
    UK (CTP regime)AWS, Google Cloud, Microsoft, Oracle
  • Who supervises

    EU (DORA)EBA, ESMA, EIOPA
    UK (CTP regime)FCA, PRA and the Bank of England
  • Firms' supplier records

    EU (DORA)Submitted every year
    UK (CTP regime)Annual submission of material supplier records starts on 18 March 2027

Where's the difference? The EU cast a wide net; the UK caught only the four biggest fish and says openly that it wants to stick to a "small number" of providers. But it's clear the list will grow. Parliament's Treasury Committee wants AI providers brought into the regime too.

For those working in both markets: A group licensed in London and Frankfurt will manage two separate records and two separate sets of supervisory expectations for the same supplier. Different format, same logic.

12Türkiye

The Türkiye bridge

DORA isn't a Turkish law, but every financial bridge from Türkiye to Europe runs over it. It's felt directly in three places.

1. Turkish-owned banks and payment institutions in Europe. Any firm licensed in Germany, the Netherlands or another EU country is directly in scope. The point people miss here is intragroup services. DORA's contract rules apply not only to outside suppliers but also to arrangements within the group. The core banking system, data centre or software provided by the parent bank or a group company in Istanbul goes into the register, and the contract gets audit rights and an exit plan. "Our parent company is already ours" isn't enough under DORA.

2. Turkish technology companies selling into the EU. A Turkish firm providing software, cloud or data services to a European bank runs into the DORA clauses its customer gets signed: incident reporting, being open to audit, subcontractor transparency, exit support. A firm that can offer this as a ready package starts European tenders a step ahead.

3. Turkish fintechs that want to expand into Europe. Getting a licence in Romania, Lithuania or Germany means living with DORA from day one. The register, the incident process and the test plan have become a natural part of the licence application. Going in through a partner bank doesn't remove the responsibility; it moves it into the contract.

Compared with the rules in Türkiye. There are serious parallels between BDDK's Regulation on Information Systems and Electronic Banking Services and DORA on risk management, business continuity and outsourcing. Two important differences stand out: Türkiye has a strong approach of keeping critical data and systems inside the country, which limits cloud use. DORA, on the other hand, isn't against the cloud; it wants dependency on the cloud to be managed, and it supervises the tech giants directly.

Both ends of the bridge: For a group that complies with BDDK in Türkiye and with BaFin and DORA in Germany at the same time, keeping a single supplier inventory is much cheaper than running two separate compliance projects. (Our suggestion)

13Your call

What would you do?

Two desks, two decisions. Make your pick, then see our take.

Desk 1: The fast partner or the ready partner?

You're head of product at a digital bank. You want to ship an invoice collection feature for SMEs in three months. There are two candidates.

Our take: The right answer usually depends not on the launch date but on whether this feature counts as a "critical or important function". If it does, audit rights aren't up for negotiation. Is the startup ready to accept that, or will you find out in the first negotiation?

Desk 2: Where should the infrastructure sit when you expand into Europe?

You're a payments company that grew up in Türkiye, and you want a licence in Romania. All your infrastructure is in Istanbul.

Our take: All three paths are possible, and their cost and speed differ a lot. The supervisor may accept an intragroup service, but it will expect a written, tested answer to the question "if the system in Istanbul becomes unreachable one day, what happens to the Romanian customer's money?" Can you give that answer today?

14Calendar

What's next on the calendar?

The DORA calendar is busy over the next 15 months. The most important date is January 2028, when the first attack simulation cycle for large firms closes.

  • November 2026 (expected)

    What happensFirst annual update of the critical provider list. The list is renewed every year
  • December 2026

    What happensBAIT is fully withdrawn for banks in Germany
  • March 2027

    What happensThird annual submission of the Register of Information (with data as of 31 December 2026)
  • 18 March 2027

    What happensIn the UK, firms start submitting their material supplier records every year
  • 2027 (if the proposal becomes law)

    What happensThe single incident reporting point goes live through the Digital Omnibus
  • 17 January 2028

    What happensEnd of the first TLPT cycle for selected firms and the Commission's DORA review
15fspark9 note

fspark9 note

At most banks DORA started as a compliance project and stayed on the compliance team's desk. We think its real effect will be felt at the product desk. Because now every new feature, every new partner, every new market starts with a DORA question.

It's easy to judge from the outside. So instead of a verdict, we'll leave a few questions:

  • When you look at your register, do you see only a list of suppliers, or also where your product roadmap is going to get stuck?
  • When you pick a new partner, do you talk about the DORA clauses in the first meeting, or find out about them at the contract table?
  • Does your next feature count as a "critical or important function"? Who decides that, and when?
  • Would your exit plan for services you get from within the group actually work, or does it only exist on paper?
  • Does choosing among DORA ready partners mean giving up the experience your customers want? It shouldn't.

As people who built two banks from scratch and took products live in both Germany and Türkiye, here's what we've seen: however heavy the rule, the team that builds it into the design from day one ends up moving fastest. It's possible to treat DORA not as a checklist bolted on later, but as the first step in choosing partners and shaping the product flow.

If choosing the right partner for a new digital product, or setting up a launch flow that works with DORA, is on your desk, New Product Line and The Right Bank Partner exist for exactly that.

Want to ship your next product without getting stuck on DORA?

Sources

Where every figure comes from.

Official sources

  1. [1]ESAs: designation of critical ICT third party providers, November 2025. www.eba.europa.eu
  2. [2]ESAs: list of the 19 critical providers (PDF). www.esma.europa.eu
  3. [3]ESAs: 2025 report on major ICT-related incidents (PDF). www.esma.europa.eu
  4. [4]CSSF: DORA scope and the 20 types of firm. cssf.lu
  5. [5]CSSF: register submission update, March 2026. www.cssf.lu
  6. [6]Central Bank of Ireland: register submission 2026. edit.centralbank.ie
  7. [7]GOV.UK: the UK's first four critical third parties, July 2026. www.gov.uk

Analysis and news

  1. [8]Paperjam: the details of the 3,383 incidents. en.paperjam.lu
  2. [9]Fundación Mapfre: summary of the ESAs incident report. documentacion.fundacionmapfre.org
  3. [10]Morgan Lewis: on the critical provider list. www.morganlewis.com
  4. [11]Morgan Lewis: DORA contract clauses. morganlewis.com
  5. [12]Simmons & Simmons: implementation and fines by country. www.simmons-simmons.com
  6. [13]McKinsey: DORA readiness survey. www.mckinsey.de
  7. [14]Infosecurity Magazine: Rubrik cost survey. www.infosecurity-magazine.com
  8. [15]SecurityBrief: Veeam survey. securitybrief.co.uk
  9. [16]CMS: the Digital Omnibus and the single reporting point. cms.law
  10. [17]AFME: the overlap between DORA and the Cyber Resilience Act. www.afme.eu
  11. [18]Lewis Silkin: UK CTP designations. www.lewissilkin.com
  12. [19]Morrison Foerster: UK supplier record timetable. www.mofo.com
  13. [20]Copla: TLPT requirements. copla.com
  14. [21]Legiscope: DORA software compared. www.legiscope.com
  15. [22]ComplyJet: DORA software review. www.complyjet.com
  16. [23]Fortune Business Insights: TPRM market size. www.fortunebusinessinsights.com
  17. [24]Akbank: what DORA means for Turkish companies. www.akbank.com
  18. [25]Capital: BDDK, DORA and the cloud debate. www.capital.com.tr

Note: The customer story is an illustrative piece of fiction. Places marked "our observation / estimate / take" are fspark9's inferences, not sourced findings.