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If you work with a European Union financial organization, or a critical Information, Communication, or Technology (ICT) provider to an EU financial company, you are aware that the Digital Operational Resilience Act (DORA) is reshaping how institutions approach resilience. At its core, business continuity is key to ensuring operational stability in today’s digital landscape.
DORA serves as the digital extension of operational resilience, designed to address risks stemming from the digitalization of financial services. It expands on traditional resilience frameworks, ensuring financial institutions can withstand, recover from, and adapt to disruptions such as cyberattacks, IT failures, and third-party outages. With 100 days as of publishing this article, DORA goes into effect (January 17, 2025), financial organizations must ensure their business continuity strategies are aligned with these requirements, supported by a strong GRC framework.
Embedding GRC into Key DORA Articles on Business Continuity
A strong Governance, Risk, and Compliance (GRC) framework provides the governance structure, risk management approach, and compliance oversight that are crucial to meeting DORA’s operational resilience requirements. Integrating GRC into Business Continuity Management (BCM) ensures that policies are both implemented as well as governed and monitored effectively across the entire organization.
BCM is not only a compliance requirement but a strategic imperative for financial stability. Several articles in DORA directly address business continuity and its role in ensuring operational resilience.
Article 11: ICT Risk Management Framework
Article 11 mandates an ICT risk management framework that includes business continuity planning. A GRC system will help align ICT risk management with enterprise-wide policies and ensure oversight mechanisms are in place. GRC tools can streamline the creation, monitoring, and reporting of business continuity policies and processes, helping organizations track compliance and ensure risks are managed throughout the ICT lifecycle.
Article 12: ICT Business Continuity and Disaster Recovery Plans
A robust GRC system allows financial institutions to continuously update and review business continuity and disaster recovery plans, ensuring they comply with evolving regulatory requirements. A GRC program and solution can help facilitate the regular testing, reporting, and documentation of these plans, ensuring that all updates and risks are properly logged and aligned with internal governance protocols.
Article 13: Response and Recovery
GRC frameworks help define roles, responsibilities, and escalation paths for incident response and recovery. Article 13 requires a structured approach to response, and GRC can ensure a structured and coordinated response by providing the necessary oversight and governance, making sure that incident management procedures are followed consistently and that they are compliant with both internal policies and regulatory mandates.
Article 14: Testing of Digital Operational Resilience
Testing and reporting processes can be managed effectively using a GRC solution, allowing senior leaders to document test outcomes and ensure continuous improvement in resilience capabilities. GRC frameworks facilitate the governance necessary to make sure that test results lead to actionable insights and that remediation efforts are tracked to completion, ensuring compliance with Article 14.
Managing Third-Party Risks with GRC
With third-party ICT providers being a major focus of DORA (Articles 28-30), GRC systems can help financial institutions automate vendor risk management, focusing on critical ICTs. A GRC framework allows organizations to assess, monitor, and manage third-party risks continuously, ensuring that vendors meet the same standards of business continuity and operational resilience as the financial institutions themselves. GRC also ensures proper documentation and reporting to governance bodies on third-party risks and compliance.
Leadership’s Role in Ensuring Resilience with GRC
CIOs, CISOs, and CROs must lead the effort to embed business continuity into the organization’s digital strategy, supported by a GRC framework that ensures resilience is not only a priority but also properly governed. By leveraging GRC tools, senior leaders can maintain real-time visibility into business continuity and operational resilience efforts, ensuring that they are in line with both DORA and the organization’s broader risk management and compliance goals.
Conclusion
The countdown to DORA’s implementation underscores the need for financial institutions to focus on business continuity while leveraging GRC frameworks to ensure a structured, compliant, and well-governed approach to resilience. Articles 11, 12, and 13 outline clear expectations for continuity planning, while Article 14 emphasizes the importance of rigorous testing and ongoing improvement, all areas that benefit from effective GRC integration.
By integrating business continuity into the broader GRC and operational resilience strategy, financial institutions will not only meet DORA’s expectations while strengthening their ability to adapt to disruptions in an increasingly interconnected digital world.
Next Steps
Is your organization’s GRC framework and business continuity program ready for DORA compliance? There is a large effort that needs to be done with a short runway for takeoff with the January 2025 deadline fast approaching, OpResONE can help you build a robust ICT risk management and business continuity framework, aligned with GRC best practices. Contact us today for a tailored DORA-readiness assessment and safeguard your operations in the digital era!
