By Ian Wilson, SVP of GRC Business Development, EMEA
April 30, 2025, looms large on the calendar for financial institutions across Europe. This is not just another regulatory deadline for compliance officers, chief risk officers, CIOs, CISOs, and risk management professionals—it’s a defining moment. The Digital Operational Resilience Act (DORA) is pushing organizations to reassess how they manage operational resilience, third-party risks, and digital threats.
Take Emma, a Chief Compliance Officer at a mid-sized European bank. When she first heard about DORA’s Register of Information requirement, she assumed it was just another spreadsheet exercise. But as she dug deeper, she realized the magnitude of the challenge. Manually tracking ICT third-party providers, mapping compliance requirements, and ensuring reporting accuracy across disparate systems felt like an insurmountable task.
Her team, already stretched thin, was struggling to keep up. Conversations with peers painted a similar picture: compliance processes were fragmented, regulatory expectations unclear, and automation seemingly out of reach.
The Compliance Bottleneck
The concerns we hear from risk and compliance leaders like Emma are strikingly similar:
“Manual tracking is overwhelming, making accurate reporting nearly impossible.”
“Our compliance solution doesn’t align with our risk and resilience frameworks, delaying implementation.”
“We need an adaptive system—one that fits into our workflows instead of forcing us to overhaul them.”
“DORA compliance demands specialist knowledge, slowing our readiness.”
“With cyber threats escalating and regulations evolving, a structured, automated approach is our only hope.”
The tension between increased regulatory scrutiny and operational inefficiency is reaching a breaking point. While DORA presents a framework for resilience, its implementation exposes the underlying weaknesses of outdated compliance processes.
CTPP Designation and the Next Phase of Oversight
The European Supervisory Authorities (EBA, EIOPA, and ESMA) are advancing efforts to oversee Critical ICT Third-Party Providers (CTPPs), an essential aspect of DORA implementation. This includes:
- Register of Information Collection: Competent authorities must submit all received ICT third-party arrangements by April 30, 2025.
- Criticality Assessments: The ESAs will determine which ICT third-party providers qualify as critical and notify them by July 2025.
- Final CTPP Designation: Seated CTPPs will be subject to continuous regulatory oversight and engagement after a six-week objection period.
- Integrated Oversight Function: The ESAs have established a joint DORA oversight body to ensure consistency and resource efficiency in monitoring ICT risks across financial sectors.
For Emma, this meant one thing: the days of reactive compliance were over. To meet these expectations, her institution needed an end-to-end automated compliance solution.
Achieving DORA Compliance with CLDigital 360
At CLDigital, we offer a comprehensive and automated approach to managing DORA compliance with CLDigital 360. Our platform simplifies compliance through:
- Leverage Out-of-the-Box Solutions: Pre-built workflows for ICT risk management, incident tracking, resilience testing, and third-party risk oversight streamline regulatory reporting.
- Comply with DORA Controls and Policies: Automated templates ensure organizations meet predefined ICT security and resilience policies.
- Automate the DORA Register of Information: Our platform centralizes compliance data, automates workflows, and integrates seamlessly with existing systems.
- Simplify DORA Reporting: CLDigital 360 generates regulator-ready reports, eliminating manual formatting and ensuring data accuracy.
For Emma’s team, this meant they could eliminate spreadsheets, automate reporting, and focus on higher-value resilience strategies rather than scrambling to meet regulatory deadlines.
A Scalable DORA Compliance Framework
Our Design to Operate methodology integrates DORA requirements into daily operations through:
- Design – Data identification, aligning regulatory requirements with business objectives, and conducting ICT risk assessments.
- Plan – Implementing governance strategy, building risk registers, and setting compliance workflows.
- Build – Implementing resilience testing, establishing controls and policies, and conducting automated compliance reporting.
- Deliver – Deploying controls for ICT risk monitoring, third-party oversight, and regulatory reporting.
- Operate – Real-time monitoring, audits, and compliance tracking.
- Improve – Adapting to evolving regulatory standards, refining risk management, and optimizing response times.
Beyond the Deadline: A New Compliance Landscape
Emma’s journey is not unique. Across the financial sector, compliance teams are waking up to the reality that manual processes and siloed systems are no longer sustainable. DORA isn’t just about checking a regulatory box—it’s about establishing a long-term operational resilience strategy that keeps institutions ahead of evolving threats and regulations.
DORA is a wake-up call. The question for compliance leaders is not whether they will meet the deadline but whether they will do so in a way that transforms compliance from an administrative burden into a strategic advantage.
Is your organization ready?
At CLDigital, we help financial institutions navigate regulatory change with confidence, clarity, and capability. The time to act is now—because compliance should be a foundation for resilience, not a roadblock to innovation.
