DORA · the supply chain

Who DORA applies to, and how it reaches you

1
Regulator
National supervisor

Applies DORA to the financial entity and can inspect its suppliers through the contract.

2
Regulated
Financial entity

Bank, insurer, payment firm, asset manager. Answerable for every ICT service it relies on.

3
You
ICT supplier

Not in scope of DORA. Bound by whatever the contract with your customer says.

4
Your chain
Subcontractors

Recorded in your customer's register where they support a critical or important function.

1 → 2 · The law
ICT risk and resilience

Risk management, testing, continuity.

Incident reporting

Four hours from classifying a major incident.

Register of information

Every ICT contract, filed once a year.

2 → 3 · The contract
Article 30 clauses

Service, data locations, exit, termination.

Audit and inspection rights

For them, their auditor and their regulator.

Notice in hours

Fast enough to keep them inside their clock.

3 → 4 · The flow-down
What may be subcontracted

Stated in your contract up front.

Notice before changes

Your customer can object to a material change.

You stay responsible

For what your subcontractors deliver.