How to Implement DORA: Key Steps to Become Compliant

Digital Operational Resilience Act (DORA) is a European Union regulation designed to enhance the digital operational resilience of the EU financial sector. It establishes a comprehensive framework for Information and Communication Technology (ICT) risk management, ensuring that financial entities can respond to, cope with, and recover from ICT-related incidents.

Companies today face increasing risks related to cybersecurity, operational disruptions, and third-party dependencies. And Fintech companies are especially vulnerable to digital disruptions due to their high reliance on cloud platforms, APIs, and third-party service providers. Key risks include cyberattacks, system failures, and data loss. Such incidents can lead to erosion of customer trust, regulatory fines, financial losses, and even licensing consequences.

Let’s look at the most frequent ICT-related problems of the FinTech industry that implementing DORA will help solve:

DORA regulation implementation applies directly to a wide range of FinTech organizations operating in the EU. It includes:

• Banks
• Investment firms
• Credit institutions
• Payment service providers
• Electronic money institutions

Such businesses face strict obligations to build operational resilience, manage IT risks, and prove they can withstand digital disruptions without service failures. If your business handles financial transactions, customer funds, or digital asset flows, DORA is not optional – it’s mandatory. You must set up governance, document your risk strategy, and ensure full compliance across your internal systems and vendor ecosystem. In addition, any third-party IT provider you rely on, such as cloud platforms, data centers, or cybersecurity firms, must also meet DORA requirements. Their compliance directly affects yours, so it's critical to work only with vendors who understand and align with DORA standards.

If you fall into one of these groups, whether you think about bank, investment, or insurance app development or other related entities, compliance with DORA is no longer optional — it’s required.

To give you a clear view of where to focus your efforts to ensure compliance and build operational resilience, we’ve outlined the five core regulatory areas under DORA.

DORA requires companies to establish a complete ICT risk management framework. It involves all stages of the technology lifecycle, including design, development, deployment, and use. The goal is to protect core operations from disruptions and ensure strong business continuity.

Failure to address ICT risk weakens resilience, slows recovery, and exposes financial operations to avoidable threats. A good risk framework keeps you ahead of disruption and also meets mandatory regulatory expectations.

You must detect, classify, and report ICT-related incidents quickly and accurately. This includes cyberattacks, system failures, and service disruptions. Reports must follow strict formats and timelines set by regulators. By implementing DORA, you get clear lines of reporting, and predefined response protocols will exist with the aim of reducing confusion during high-stress moments. Financial institutions that report late or miss key details may face reputational damage.

Companies must test the strength of their ICT systems regularly. These tests should reflect the scale and complexity of your business and evolve with emerging risks. DORA allows flexibility, but regulators expect meaningful tests that support long-term resilience. From stress testing to red-teaming, results must lead to practical improvements. You should integrate testing directly into your broader DORA implementation plan, rather than operating in isolation.

DORA places full accountability on you for the ICT services your vendors provide. You must ensure that third-party providers, especially cloud and core infrastructure partners, meet the same resilience standards you do. It means vetting, monitoring, and, if needed, replacing vendors who fall short. Contracts must give you audit access, clear termination rights, and defined incident response obligations. DORA regulation implementation fails if vendor risk remains unchecked.

DORA encourages companies to collaborate by sharing information on cyber threats and critical ICT incidents. This builds collective defense across the financial sector and helps others respond faster.

DORA regulation implementation provides structured, secure, and purposeful information sharing. It’s not just about being compliant. It’s a competitive advantage when done right. The strongest businesses don’t just respond to threats; they anticipate them.

As we said earlier, DORA is a regulation that will strengthen your FinTech company from within and help you enter the EU market seamlessly, but the benefits don't end there. Let’s see more reasons why you need DORA regulation implementation now.

Disruptions can cripple operations and erode customer trust. DORA requires firms to build clear processes that keep services running through cyberattacks or system failures. Meeting these standards now ensures that your business remains operational even under extreme stress.

Operating in the EU means facing a patchwork of digital risk regulations. The DORA regulation implementation replaces this with a unified framework, creating one set of expectations across all member states. Investing in compliance early helps you align your processes with this standard, eliminate redundancy, and stay ahead of shifting regulatory deadlines.

Waiting until the deadline to meet DORA standards invites chaos, rushed rollouts, unvetted vendors, and costly patchwork fixes. Building a DORA implementation plan now lets you phase changes logically, use internal resources efficiently, and avoid fines or reputational damage. Upfront investment leads to smoother processes and lower costs over time.

DORA goes beyond external audits and forces internal discipline. It requires firms to monitor IT risk in real time and document responses clearly. Committing to this standard now strengthens internal controls, improves oversight across departments and vendors, and gives leadership a real-time view of where risk lives in the business.

Institutional partners evaluate operational risk before they commit. Implementing DORA shows that your company can manage digital infrastructure with maturity and reliability. Compliance sends a clear message: you take risk seriously and meet high standards before you’re forced to. That builds confidence and puts you ahead of competitors who delay.

Now we'll describe to you how to implement DORA effectively and build a digital resilience strategy that meets regulatory requirements. Let's look at six steps to move from preparation to full compliance faster and with fewer surprises.

Start by selecting a technology partner with deep FinTech experience and proven knowledge of industry-specific regulatory compliance. The right partner supports every phase of the DORA regulation implementation, from initial risk analysis to long-term IT process setup. Look at the partner’s portfolio and check client reviews on trusted platforms like Clutch.

For example, we at Cleveroad have in-depth experience helping FinTech companies achieve their goals and aligning them with security and regulatory standards. We provided IT staff augmentation services to a financial company from Ireland named Mangopay. Mangopay is a leading European provider of modular payment infrastructure, trusted by over 2,500 platforms including Vinted, Rakuten, and Wallapop. Backed by Advent International, Mangopay delivers tailored solutions across C2C, B2C, B2B, and marketplace models, with standout products like its FX suite for global money movement.

Mangopay partnered with Cleveroad to strengthen their existing platform and build a new product from scratch that is aligned with the highest security and regulatory standards, including KYC and AML compliance. Our collaboration led to the successful launch of a high-quality FinTech product, exceeded timeline expectations, and established a long-term partnership grounded in trust, agility, and consistent performance.

Here is what Kirk Donohoe, CPO at Mangopay, says about cooperation with Cleveroad:

Work with your IT partner to assess your current operations. Identify which processes, systems, and documents already meet DORA requirements and which areas need work. For example, if your data protection and backup systems have no regular tests or incident logs, you need to flag that for improvement. It’s a common gap for companies exploring how to create a financial app without regulatory guidance early on. A thorough gap analysis builds the foundation of your DORA implementation plan.

Define roles and assign responsibility, involving leadership, compliance officers, IT leads, and external advisors. Your FinTech partner should help set up governance structures and escalation paths that provide quick decisions and clear accountability. This alignment speeds up implementing DORA and reduces the risk of overlooked requirements.

At this step, you should build your strategy around IT and third-party risk management, coordination, resilience testing, and remediation protocols. Ask your partner for templates, planning tools, and reference architectures that match your business model. A solid strategy ensures your team knows exactly how to respond to disruptions and regulatory checks.

After designing a digital resilience strategy, it’s time to deploy the technical components, set up secure systems, run resilience simulations, and document your results. Your partner handles the infrastructure, test environments, and configuration. A strong implementation phase is key to meet performance goals and demanded compliance within your DORA regulation implementation roadmap.

The last step is establishing automated monitoring and reporting systems. These ensure visibility and help you prove compliance to auditors. Your partner should support real-time alerts, prepare audit logs, and ensure your systems stay inspection-ready. Regular testing closes the loop on how to implement DORA successfully and maintain compliance over time.

Cleveroad is a FinTech software development company headquartered in Estonia, the CEE region. For over 13 years on the IT Market, we’ve been offering various FinTech services, such as custom software development and legacy systems modernization, third-party integrations, IT consulting, and more. Throughout these services, we provide electronic trading platforms, digital payments, financial planning and management systems, and other FinTech solutions. Moreover, Cleveroad engineers are experienced in building software solutions aligned with financial regulations, including DORA, AMLD, MiFID II, PSD2, and MiFIR.

Choosing Cleveroad to implement DORA, you’ll get:

• Free Solution Workshop stage to align your DORA compliance needs with technical implementation
• Product quality assurance and control at all levels to validate every part of your software: functionality, integrations, performance, usability, and security
• Initial project cost estimation with no hidden payments or additional fees
• Partnership with an ISO-certified company that strictly adheres to ISO 27001 security standards and implements ISO 9001 quality management systems
• All guarantees for your business information security and signing an NDA per your request

We have deep experience building FinTech solutions in compliance with strict domain regulations. To prove our expertise, we would like to present some of our recent case studies.

For our client from Saudi Arabia, our team has developed a cross-platform micro-investment application. We’ve designed the architecture and the authentication process and provided the main functionality modules: multi-factor authorization, Know-Your-Customer (KYC) verification with liveness detection, and the monitoring and reporting system. Also, the app is compatible with the SAMA Cybersecurity Framework and considers all domain and local regulations.

• Discover the micro-investment platform in our case study

For our customer from Switzerland, we’ve created an eBanking software system that covers the needs of bank clients, optimizes the operators’ workflow, and automates core internal business processes. We applied custom tools and approaches compared with the terms of Swiss banking regulators (namely FINMA), including the need-to-know access control, and met the requirements of the Financial Market Infrastructure Act (FMIA).

• Learn more about the eBanking software system in our case study

For our client from the UK, the Cleveroad team has built an investment management system for real estate, covering all the processes and parties of real estate development investment and loan management. We provided platform development according to KYC/AML requirements and a Financial Conduct Authority #722801. Cleveroad created the ecosystem consisting of mobile apps (iOS and Android), a web-based Advisor portal, and a web-based backoffice for system Admins.

• Read more about theinvestment management system we built in our case study