Compliance

DORA: Automating Operational Resilience on a Sovereign Cloud

DORA audit

The Digital Operational Resilience Act (DORA) and the Network and Information Security Directive (NIS2) have transformed ICT risk from an IT problem into a board-level, legally enforceable responsibility for European financial and critical-infrastructure organisations. With full compliance deadlines already passed (NIS2: 18 Oct 2024; DORA: 17 Jan 2025), the regulatory era has moved from preparation into active supervision. Regulators now expect demonstrable, auditable capabilities to detect, contain, recover and report ICT incidents — quickly and with legal certainty.

This blog post explains

  • why jurisdictional risk — not just technical security — is the dominant strategic challenge;
  • the Sovereign Cloud model (operated and governed within the EU by EU legal entities and EU personnel) is the structural answer to that challenge;
  • automation (SIEM + SOAR with DORA-specific playbooks) is mandatory to meet 24-hour / 72-hour reporting timelines.

Strategic nexus: sovereignty, resilience, and the new EU mandate

The regulatory shift

DORA and NIS2 replace principle-based guidance with prescriptive requirements covering ICT risk management, incident reporting, operational resilience testing, and third-party oversight. The practical effect is twofold:

  • Immediate operational requirements — fast incident detection, classification, reporting and recovery processes (24-hour initial notification; 72-hour detailed report).
  • Systemic, upstream impact — regulators now scrutinize the providers that underpin financial services: cloud and other ICT third parties can be designated as Critical ICT Third-Party Providers (CTPPs) and come under direct ESAs oversight.

The core strategic problem: jurisdictional risk

Technical controls alone are insufficient. Legal exposure — the risk that a cloud provider can be compelled by a foreign law (for example, the US CLOUD Act) to disclose data or to operate under extraterritorial commands — creates a material compliance failure for EU-regulated entities. A financial institution that cannot demonstrate legal and enforceable control over its operational data and processes risks regulatory sanctions, regardless of how sophisticated its technical controls might be.

Implication: For regulated entities, ICT risk = technical risk + jurisdictional/legal risk. Solving the latter requires structural, governance and operational realignment — not just encryption and access controls.

II. The geopolitical advantage: mitigating extra-territorial risk with a Sovereign Cloud

Why “data residency” is not enough

Hosting data physically inside the EU (data residency) is necessary but not sufficient. If the cloud provider’s corporate structure or operational control remains subject to non-EU law, the provider can still be legally compelled to disclose data. The Schrems II jurisprudence and DORA/NIS2 expectations make clear that customers must be able to demonstrate legal enforceability of data protection and operational controls.

Sovereign Cloud: fundamentals and safeguards

A credible Sovereign Cloud must combine technical, operational, and legal design choices:

  1. Operational and data localization
    • Data and logs must be hosted in exclusive EU regions.
    • Operational activities (monitoring, support, incident forensics) must be performed by EU-resident personnel subject to EU law.
  2. Dedicated EU legal entities and governance
    • The cloud must be operated by EU-incorporated legal entities with boards and executive control inside the EU.
    • This structural separation lets the provider lawfully resist or legally challenge extraterritorial demands, creating a legal firewall that is often more effective than purely technical mitigations.
  3. Contractual guarantees (DPA alignment)
    • DPAs must codify procedures for third-party requests, subcontracting visibility, audit rights and defined incident handling aligned to DORA/NIS2.
    • A governance committee should maintain and review DPAs and operational procedures to ensure continued alignment with evolving regulation.

Strategic outcome

A Sovereign Cloud removes the primary source of regulatory uncertainty for highly regulated customers, enabling them to demonstrate due diligence before national competent authorities and ESAs. In markets where regulators are focused on systemic concentration and legal enforceability, this structural assurance becomes a competitive differentiator.

III. Automation blueprint: meeting the 24-hour / 72-hour mandates

DORA’s time-critical reporting obligations

DORA imposes strict timeframes:

  • Initial notification to the competent authority: no later than 24 hours after detection.
  • Intermediate/detailed report: within 72 hours of the initial notification (or sooner if circumstances change).

These timelines demand rapid triage, classification against regulatory thresholds, automated evidence collection, and securely auditable reporting. Manual processes will routinely fail under these constraints.

SIEM + SOAR: the closed-loop automation stack

A reliable automation architecture has three integrated layers:

  1. SIEM (detection & centralization)
    • Collects and normalizes logs from cloud, network, applications and endpoints.
    • Applies correlation rules and baselines to surface anomalies and potential incidents.
  2. SOAR (orchestration & response)
    • Hosts playbooks that automate enrichment (AD, CMDB, asset ownership), classification against DORA thresholds, containment actions, and reporting workflows.
    • Automatically composes the initial regulatory notification template and the 72-hour intermediate report, including forensics and mitigation narratives.
  3. Sovereign Cloud enablers
    • Native, high-fidelity logging APIs and secure retention to guarantee forensic integrity and residency.
    • Secure channels for digitally-signed submissions to competent authority portals.

DORA playbooks: practical design

  • 24-Hour Playbook — triggered for incidents meeting ‘Major’ thresholds: auto-enrich, auto-classify, populate the regulator template, and submit the signed initial notification within the 24-hour window.
  • 72-Hour Playbook — continues the data collection, correlates mitigation activity, produces the detailed intermediate report and captures artefacts for RCA and learning.

Automation reduces human error, speeds decision cycles, and creates machine-readable audit trails — transforming compliance from an ad-hoc activity into a measurable operational capability.

IV. Supply-chain resilience: managing Critical ICT Third-Party Providers (CTPP)

DORA’s focus on concentration and systemic risk

DORA recognises that systemic vulnerability can emerge when many financial entities rely on a small number of ICT providers. The regulation grants ESAs powers to designate and supervise CTPPs based on systemic impact, substitutability and concentration of reliance.

Contractual non-negotiables for financial entities

Article 30 and associated requirements define mandatory contractual and oversight elements:

  • Transparent governance and audit rights — clients and competent authorities must have inspection, audit and access rights commensurate with risk.
  • Termination & exit strategies — contracts must include enforceable termination rights and tested exit plans when supervision becomes ineffective.
  • Subcontracting visibility — full transparency into subcontractors and their jurisdictions is required to feed client registers and maintain continuous oversight.

How a Sovereign Cloud addresses CTPP obligations

A structurally sovereign provider directly fulfils many Article 30 expectations: EU governance and operations, pre-agreed audit scope and frequency, contractually guaranteed exit plans and demonstrable counters to jurisdictional interference. This lowers the provider’s risk of CTPP designation friction and simplifies the client’s regulatory reporting.

V. Quantifying the investment: ROI framework for operational resilience

Reframing compliance as strategic value

Boards and investors demand that resilience investment be tied to measurable business outcomes. A robust ROI model includes:

  1. Avoided penalties — quantify the expected value of avoided maximum fines under NIS2/DORA (e.g. €10M or 2% global revenue for essential entities) multiplied by incident probability, then offset by resilience investment cost.
  2. Operational efficiency — measure reductions in MTTD/MTTR, revenue saved per hour of downtime avoided, and FTE productivity gains from automation.
  3. Strategic revenue unlocked — estimate NPV of new contracts and market access that become achievable because of jurisdictional guarantees and regulatory compliance.
  4. Reduced compliance overhead — lower audit and compensating control costs where the Sovereign Cloud offers pre-approved controls and DPA assurances.

Example ROI formula (simplified)

Avoided Cost = (Probability of Major Incident × Maximum Fine) − Cost of Sovereign Cloud Strategy
Total ROI = Avoided Cost + Operational Savings + NPV(New Contracts) − Implementation Cost

Accelerating ROI with pre-integrated services

Providers that deliver both sovereignty and pre-built automation (SIEM + SOAR playbooks) shorten time-to-compliance, reducing implementation risk and accelerating the commercial benefits of market differentiation.

DORA Compliance Playbook

VI. Conclusion — a three-point imperative for boards

The combined pressures of DORA and NIS2 have permanently re-ordered the risk calculus for European financial and critical infrastructure organisations. The path to resilient, compliant operation is defined by three imperatives:

  1. Resolve geopolitical/jurisdictional risk — adopt providers with EU legal entities, EU governance and EU-resident operations to ensure enforceability and resist extraterritorial compulsion.
  2. Achieve automation speed — implement SIEM + SOAR with DORA-specific playbooks to meet strict 24-hour and 72-hour reporting mandates.
  3. Re-engineer supply-chain contracts — demand Article 28/30-compliant clauses: audit rights, subcontracting transparency, enforced exit plans and termination mechanics tied to regulatory supervision effectiveness.

Adopting a Sovereign Cloud that couples structural legal assurance with automated incident response converts regulatory obligation into a market advantage: fewer regulatory exposures, faster time-to-reporting, demonstrable audit trails, and new revenue unlocked by compliance credibility. In short, operational resilience should be framed and measured as a strategic growth engine — not merely an IT expense.

Let’s work together!

See how we can help to overcome your challenges

FAQ

What is a DORA audit?

A DORA audit is a formal assessment to ensure an organization’s ICT systems, processes, and third-party relationships comply with the Digital Operational Resilience Act (DORA). It evaluates operational resilience, risk management, and reporting practices to meet EU regulatory requirements.

Who needs a DORA audit?

The audit primarily targets financial entities and critical ICT service providers operating within the EU. This includes banks, insurance companies, investment firms, FinTechs, payment service providers, and cloud or IT providers that support essential financial operations.

What are the main objectives of a DORA audit?

The audit seeks to verify that organizations can withstand, respond to, and recover from ICT disruptions. It evaluates the robustness of ICT risk management frameworks, ensures proper incident reporting and testing practices, and confirms that third-party relationships are managed effectively.

How often should a DORA audit be conducted?

While internal assessments can be conducted annually or more frequently depending on the organization’s risk profile, external audits may be required by regulators either periodically or following major incidents. Continuous readiness is a key expectation, meaning compliance is an ongoing process rather than a one-off task.

What areas does a DORA audit cover?

A DORA audit reviews governance structures, ICT risk management, operational resilience planning, incident detection and response, resilience testing, third-party management, and cybersecurity controls. Essentially, it looks at how well an organization is prepared to maintain operations under digital stress or disruption.

What challenges do organizations face during a DORA audit?

Many organizations struggle to align internal processes with regulatory requirements, document third-party risks, report incidents promptly, and incorporate resilience testing into day-to-day operations.

How does DORA relate to NIS2 compliance?

DORA complements the NIS2 directive by focusing on the financial sector’s operational resilience. While both frameworks emphasize strong ICT risk management, DORA is more prescriptive about practices in financial operations, whereas NIS2 applies more broadly to network and information security across sectors.
arrow arrow

Thank you
for contacting us!

Please, check your email

arrow arrow

Thank you

You've been subscribed

We use cookies to enhance your browsing experience. By clicking "Accept," you consent to the use of cookies. To learn more, read our Privacy Policy