DORA Compliance — STORM GRC | ICT PROTECT
DORA · EU Regulation 2022/2554

Five pillars. One register. Zero spreadsheets.

STORM GRC gives banks, insurers, payment institutions, investment firms and the ICT third-party providers DORA Compliance, by serving them a single workspace for the five DORA pillars — ICT risk management, incident reporting, resilience testing, third-party risk, and the Art. 28(3) register of information.

Pillar 1: ICT risk Pillar 2: Incidents Pillar 3: Resilience Testing Pillar 4: 3rd-party Pillar 5: Art. 28(3) Register
EU 2022/2554 · DORA 1 2 3 4 5 RISK INCIDENT RESILIENCE TPRM ROI
DORA · Register of Information Live
ICT services inventoried · 142 / 142 Complete
Critical contracts · Art. 30 clauses verified Verified
Testing due · Q3 2026 Scheduled
Recognitions Independent awards for the STORM platform and its industry-specific implementations
Cyber Security Awards 2025 Gold
GoldMaritime cyber framework
Cyber Security Awards 2025 Silver – Integrated cyber services
SilverIntegrated cyber services
Cyber Security Awards 2025 Silver – GRC automation
SilverGRC automation
Cyber Security Awards 2025 Silver – Integrated cyber services
SilverBest Project – New Product (Risk Analysis)
Cyber Security Awards 2025 Silver – Integrated cyber services
SilverBest Use of Risk Technology & Platform
Cyber Security Awards 2025 Silver – Integrated cyber services
SilverBest Cybersecurity Risk Management
Compliance Awards 2025 Bronze – Best compliance platform
BronzeBest compliance platform
What changed with DORA

DORA has moved from a guideline to a regulation — already in force since January 2025.

Five pillars, hundreds of pages of Regulatory Technical Standards from the ESAs, and a register of information that has to be ready for the competent authority on request. Most financial entities discover they have the pieces — just not in one place auditors can read.

PILLAR 01

ICT risk management

A documented ICT risk-management framework approved by the management body, with protection, detection, response and recovery controls running continuously.

Art. 5–16
PILLAR 02

Incident reporting

Classification of ICT-related incidents, major-incident reporting to the competent authority within tightly bounded timelines, and significant cyber-threat reporting.

Art. 17–23
PILLAR 03

Resilience testing

An annual digital operational resilience testing programme — vulnerability assessments, scenario-based tests and tabletop exercises (TTX) structured around your critical ICT functions.

Art. 24–27
PILLAR 04

Third-party risk & the register

Every ICT third-party arrangement classified, contracted under Art. 30, and listed in the Art. 28(3) Register of Information — submitted to the competent authority on demand.

Art. 28(3) & Art. 28–44
Who DORA reaches

Two sides of the same regulation. One data model.

DORA reaches across the boundary between the financial entity and the ICT third party. STORM is built for both — and lets them work against the same control set.

Financial entities

Banks, insurance and reinsurance undertakings, investment firms, payment institutions, electronic money institutions, crypto-asset service providers, CCPs, CSDs, trading venues, credit rating agencies — about 22,000 entities across the EU.

  • ICT risk-management framework documented, approved and reviewed
  • Major-incident classification and reporting submitted to the competent authority
  • Annual testing programme structured around critical ICT functions
  • Register of Information for every ICT third-party arrangement
  • Proportionality same rules, scaled to size and complexity

ICT third-party providers

The cloud, SaaS, telco and data providers that financial entities depend on. Critical ICT Third-Party Providers (CTPPs) — designated by the European Supervisory Authorities — fall under direct oversight from a lead overseer.

  • Sub-contractor chain documented and contractually controlled
  • Concentration risk evidence for financial-entity customers
  • Exit and substitutability plans documented and tested
  • Lead overseer cooperation where designated as a CTPP
  • Operational resilience controls aligned with financial customer expectations
DORA articles

The articles your competent authority will quote.

STORM’s DORA configuration is pre-mapped to the DORA regulation, the Commission Delegated Regulations and the ESA Regulatory Technical Standards (RTSs). You don’t translate generic ISO 27001 into DORA — STORM does it.

Art. 5
ICT risk-management framework
A documented, sound, comprehensive ICT risk-management framework approved by the management body — the spine that holds the rest of DORA together.
Covered
Art. 6–11
Identification, protection & detection
Asset and function inventory, ICT security policies, protection and prevention controls, detection mechanisms — all on the same data model used for risk assessment.
Covered
Art. 12–13
Response, recovery & learning
ICT business continuity policy, response and recovery plans, post-incident review — with BIA, RTO and RPO tracked at asset and service level.
Covered
Art. 17–18
ICT incident management & classification
Incident detection, classification per ESA criteria, root-cause analysis. Significant cyber threats also captured as a distinct record type.
Covered
Art. 19
Major-incident reporting
Initial, intermediate and final reports to the competent authority — generated from the same incident record, role-based approvals, ESA-template ready.
Covered
Art. 24–27
Resilience testing programme
Annual testing schedule, vulnerability assessments, scenario-based tests and tabletop exercises (TTX) — structured around critical ICT functions and documented for the competent authority.
Covered
Art. 28–29
Third-party risk principles
Pre-contractual due diligence, criticality assessment, sub-contractor flow-down — the TPRM module with BitSight and FortiRecon ratings on the same record.
Covered
Art. 30
Contractual provisions
The mandatory contractual provisions for ICT services supporting critical or important functions — version-controlled, evidenced per contract, reviewable by the authority.
Covered
Art. 28(3)
Register of Information
A complete register of all ICT third-party arrangements in the ESA template, ready to submit to the competent authority on demand.
Covered
Art. 45
Information-sharing arrangements
Voluntary cyber threat-information sharing with peers and ISACs — captured as a documented arrangement in the governance module.
Covered
Major-incident reporting · Art. 19

Initial, intermediate, final. One workflow.

From the moment your team classifies an ICT-related incident as major under the ESA criteria, the clock starts. STORM builds Article 19 into the incident module — so the initial notification, the intermediate report and the final report are produced from the same record without re-keying.

24h
Initial notification

To the competent authority

An initial notification to the competent authority as soon as possible — and no later than 4 hours after the incident is classified as major per the Commission Delegated Regulation.

72h
Intermediate report

What changed, what’s contained

An intermediate report updating the initial notification with a current view of severity, impact, mitigation in progress, and any cross-border implications.

30d
Final report

Root cause & mitigation

A final report covering root cause, the full mitigation set applied, lessons learned, and the changes to controls and processes that follow from the incident.

The DORA workspace

What your Head of Operational Risk actually opens on Monday.

The same STORM platform, configured for DORA — five pillars cross-mapped to your existing ISO 27001 and operational-risk frameworks, Article 19 reporting wired into the incident module, supplier register feeding the Art. 28(3) register of information.

Storm DORA compliance platform with DORA pillars mapped

Register of Information

Every ICT third-party arrangement in the ESA template — contract, criticality, sub-processor chain, exit plan — exported to the format the competent authority asks for.

Five-pillar gap analysis

Each pillar scored on the 5-level maturity scale, with drill-down to controls, evidence and remediation tasks assigned with deadlines.

Major-incident workflow

ESA classification criteria built into the incident form — the initial, intermediate and final reports all generated from one record, with management-body sign-off recorded.

Implementation

Audit-ready DORA compliance in 90 days.

A typical mid-size financial entity (250–2000 staff) hits DORA audit-ready posture within one quarter. Larger institutions with multiple subsidiaries or significant-entity status run a longer programme, but the first 30 days look the same.

30
days

Framework & baseline

  • ICT risk-management framework documented (Art. 5)
  • Asset and service inventory complete
  • Existing ISO 27001 / op-risk controls mapped to DORA
  • Competent authority and ESA contact established
60
days

Register & third parties

  • Art. 28(3) Register of Information populated
  • Critical-function contracts reviewed against Art. 30
  • Major-incident classification & reporting tested
  • Testing programme defined; scenario-based tests and TTX scheduled
90
days

Audit-ready

  • Internal audit completed and reported
  • Management body approval recorded
  • Incident-reporting workflow tested end-to-end
  • Competent-authority documentation pack ready
DORA implementation snapshot

From fragmented supplier records to a submission-ready Register of Information

DORA requires financial entities to maintain a complete view of ICT third-party arrangements, critical services, contractual provisions and exit arrangements. STORM brings those records into one workspace, so the register, evidence and internal review process are ready when the competent authority asks.

DORA register and third-party risk workflow Operational resilience and compliance operations
Operation snapshot
Art. 28(3)Register of Information
Art. 30Contractual provisions
5/5DORA pillars evidenced
1Workspace for audit readiness
DORA FAQ

Questions Heads of Op Risk and CISOs actually ask.

If your question isn’t here, the answer is a 30-minute call — usually faster than email.

Are we in scope for DORA?
If you are an EU-authorised financial entity in one of the 20+ categories named in Article 2 — banks, insurers, investment firms, payment institutions, e-money institutions, crypto-asset service providers and several more — you are in scope. DORA also reaches ICT third-party providers, with critical providers (CTPPs) under direct ESA oversight. STORM’s onboarding includes a guided scope check.
We have ISO 27001 already. Does DORA need a new programme?
ISO 27001 covers most of Pillar 1, but DORA’s Pillar 2 (incident reporting), Pillar 3 (resilience testing), Pillar 4 (third-party contracts and register) and the Art. 28(3) register of information all go beyond ISO 27001. STORM imports your existing SoA and reconciles it with DORA so you can see exactly where the gap is.
What goes into the Art. 28(3) Register of Information?
For every ICT third-party arrangement: identification of the entity, type of service, whether the service supports critical or important functions, sub-contractor chain, contractual provisions (Art. 30), exit and substitutability arrangements, concentration risk indicators, and a list of the data and operations involved. STORM builds the register from the same supplier records used in TPRM — populated, not re-keyed.
How does DORA interact with NIS 2 if we are caught by both?
DORA is lex specialis for the financial sector — where DORA applies, it takes precedence over NIS 2’s risk management and incident reporting requirements. Other NIS 2 obligations (notification to national CSIRT, supply-chain considerations beyond Pillar 4) may still apply. STORM is configured to handle both: same risk register, same controls, two reporting workflows where required.
What about our existing third-party contracts? Do we need to renegotiate everything?
In practice, yes — at least for ICT services supporting critical or important functions. Article 30 lists specific mandatory contractual provisions that must be in place. STORM tracks each contract, flags missing Art. 30 clauses, and queues renegotiations by criticality so you’re not opening every contract at once.
How quickly do major incidents have to be reported?
Initial notification as soon as possible — and no later than the end of the business day following classification as major. Intermediate report within 72 hours of the initial notification (in some MS implementations). Final report within one month. STORM produces all three from the same incident record, with ESA-template export.
Can the platform be deployed on-premise?
STORM is delivered as a managed SaaS solution, hosted in EU-certified data centers. For enterprises in critical infrastructure sectors with strict data locality requirements, on-premise deployment can be discussed.
Certifications

ICT PROTECT holds internationally recognised certifications across quality, security and assurance.

ISO 9001 · ISO 27001 · ISO 22301 · ISO 27701 ISO certifications supporting Storm DORA compliance assurance ISAE 3000 Type I Cyber Essentials Certified and Cyber Essentials Plus
Get started

See STORM GRC working against your DORA obligations — in 30 minutes.

A focused demo with someone who knows the regulation. We walk through how STORM GRC maps to the five DORA pillars and show you exactly how it fits your organisation — no commitment required.

Book a 30-min demo

EU-based team. No sales pressure.