Digital Operational Resilience Act (DORA) and the Digital Supply Chain: Why Digital Providers Must Step Up

Proving resilience under DORA: How ICT providers can lead the future of digital trust.

In a time where financial services are inseparable from digital infrastructure, the Digital Operational Resilience Act (DORA) has introduced a sweeping new set of regulatory obligations for regulated financial services firms in the European Union. Adopted in late 2022 and fully enforceable from 2025, DORA is not just another compliance requirement, it represents a fundamental shift in how financial institutions must approach technology risk. 

At the heart of DORA is a demand for resilience. Financial institutions are now required to ensure they can prevent, respond to, and recover from Information Communication and Technology (ICT)-related disruptions. Achieving this resilience, however, isn't just about internal processes or cyber hygiene. It's about understanding, and governing every part of the digital supply chain that supports critical operations. 

Understanding the Registry of Information 

A central obligation under DORA is the Register of Information (RoI). Every regulated financial institution must document detailed information about the ICT services they rely on, including contractual arrangements, subcontracting chains, security provisions, recovery objectives, and data location specifics. This data must be structured, up to date, and ready to report to competent authorities through standardized templates. 

This is not a simple task, especially for large firms with dozens or even hundreds of material digital partners. But the real impact is felt further upstream by the ICT companies that provide these services. 

The Expanding Regulatory Perimeter under the Digital Operational Resilience Act (DORA)

For the first time, software vendors, cloud infrastructure providers, cybersecurity firms, and managed service providers are being drawn directly into the orbit of financial regulation. Even those who don’t directly serve banks or insurers but support another ICT provider in that chain are now implicated in DORA’s requirements. 

As a software provider supporting EU-regulated financial firms, you are now expected to deliver a specific set of information to your customers. They need this to meet their obligations, but you bear the burden of assembling it. 

You must be able to provide your legal identifiers, the structure and location of your service delivery, descriptions of subcontractor relationships, and technical information about your systems’ resilience and recoverability. You may also need to provide audit rights, data processing arrangements, security policies, and exit strategies, all in a format that aligns with official templates. 

In short, your services are no longer judged purely on price or performance. They are judged on their regulatory visibility. 

The Case for a New Approach 

Currently, financial firms approach each ICT vendor with their own set of data requests. This creates a chaotic, repetitive, and inefficient loop. Vendors are forced to rebuild nearly identical compliance packs over and over, tailored only in superficial ways. This process is ripe for rethinking. 

What’s needed is a new model for RoI data exchange: a structured, secure, and standardized method by which ICT providers can disclose necessary information once and make it available to all relevant clients. Ideally, this would be API-driven, interoperable with regulators’ own tools, and designed to integrate with existing compliance practices. 

Such a model would ease the reporting burden, reduce duplication, and increase consistency. But most importantly, it would shift the narrative: from compliance as a burden, to transparency as a service differentiator. 

Avoiding Redundant Compliance Costs 

Many ICT providers are already certified under standards such as ISO 27001 or SOC 2, which cover areas like access control, supplier management, and data integrity. Yet under DORA, they are often asked to replicate similar information in bespoke formats, repeatedly. 

This duplication is not only costly. It’s unnecessary. 

A smarter compliance model re-imagines the assembly, protection and sharing of these compliance proofs and allows ICT firms to map existing controls and audits to DORA's RoI requirements. This would eliminate redundant work and harmonize how assurance is demonstrated across different regulatory frameworks. 

Equipping confidential proofs of compliance data sets with self-sovereign access policies empowers your data to protect itself as it is used to meet compliance with multiple regulatory and industry standard obligations. 

Conclusion: Compliance as a Shared Responsibility 

DORA redefines the relationship between financial institutions and their digital supply chains. It places both under the same regulatory lens and expects a seamless exchange of accountability. 

ICT providers that recognize this early and equip themselves to proactively support their clients will not only meet the compliance needs of financial institution customers but stand out in a market increasingly driven by trust, resilience, and transparency. 

If you’re an ICT provider navigating these new expectations, contact Confidios today to discover how self-sovereign data can improve how you meet regulatory and industry obligations and retain access to some of your most important financial services customers. 

Confidios. Your data. Your rules. Empower your data to govern itself.