The DORA “Hot Seat” Blueprint: A Zero‑to‑Hero Guide for Management Body Interviews

Executive Summary (The What & The Who)

The Digital Operational Resilience Act (DORA) is an EU regulation (Regulation (EU) 2022/2554) that became fully applicable on 17 January 2025.

It forces financial institutions to prove they can withstand, respond to, and recover from ICT disruptions – from cyberattacks to third‑party outages.

Unlike previous, high‑level ICT guidelines, DORA:

• Is directly binding in all Member States.
• Has detailed Regulatory Technical Standards (RTS) and Implementing Technical Standards (ITS) on ICT risk, incident reporting, testing, and third‑party risk.
• Makes the management body (board and senior leadership) explicitly accountable.

Who must care

DORA applies to more than 20 categories of financial entities, including:

• Credit institutions, investment firms, insurers, reinsurers, payment and e‑money institutions.
• CCPs, CSDs, trading venues, benchmark administrators, issuers of asset‑referenced tokens, and other crypto‑asset service providers.
• ICT third‑party providers that support critical or important functions, especially those designated as Critical ICT Third‑Party Providers (CTPPs) under ESA oversight.

If you sit on the board, executive committee, or lead risk, ICT, security, operations, or third‑party risk, you are now squarely in scope for in‑depth supervisory interviews on DORA.

What this guide gives you

This blueprint shows you how to prepare leadership for those interviews – from zero to confident:

• The questions supervisors actually care about across DORA’s pillars.
• A 4‑phase implementation playbook to get your management body “interview‑ready”.
• Concrete artefacts to build: evidence packs, dashboards, RoI summaries, incident storylines, and TLPT narratives.
• A first‑moves checklist you can start today.

Before diving into detail, here are the four moves that make or break the hot seat:

1. Know the examiner’s script: Translate DORA articles + RTS into a practical “question bank” for the board.
2. Build your story and your proof: Governance, risk appetite, incidents, testing, and third‑party risk all need a coherent, evidenced narrative.
3. Drill like it’s real: Run structured mock interviews and crisis simulations with the actual management body.
4. Make readiness continuous: Embed DORA metrics into regular board packs so interviews feel like “another deep‑dive”, not a special event.

The rest of this guide unpacks how.

The “Why” (Risk & Reward of the DORA Hot Seat)

Mandatory risk: what happens if you’re not ready

DORA is not optional. Consequences of poor compliance – and poor interviews – include:

• Fines

  • Administrative penalties and remedial measures as determined by Member States.
  • For CTPPs: Periodic penalty payments of up to 1% of average daily worldwide turnover.

• Supervisory escalation

  • Intensified onsite inspections, deep‑dive reviews, and remedial programmes.
  • For CTPPs: Joint Examination Teams (JETs) under the ESAs.

• Personal and reputational exposure

  • Management body members can be held responsible for deficient oversight, poor risk appetite setting, or repeated incident mishandling.
  • Public enforcement or high‑profile incidents damage franchise value and trust.

With tight incident timelines (initial notification within hours, intermediate and final reports with root‑cause analysis) and mandatory Registers of Information (RoI) on all ICT third‑party contracts, supervisors quickly see who is genuinely in control versus who is paper‑compliant.

Strategic upside: why getting this right is a business win

Well‑prepared leadership interviews are more than defensive:

• Stronger grip on digital risk

  • Boards that can clearly articulate ICT risk tolerance, critical services, and vendor dependencies make better strategic decisions on cloud, AI, and outsourcing.

• Operational advantages

  • Institutions that implemented DORA‑aligned tooling and processes report 40–70% lower ongoing compliance effort.
  • Incident response times cut from hours to minutes.
  • Uptime of 99.99%+ with zero major incidents over extended periods.

• Regulatory trust and flexibility

  • A management body that consistently gives structured, data‑backed answers gains credibility.
  • That often translates into less intrusive supervision and more constructive dialogue when something does go wrong.

Getting ready for the DORA “hot seat” is therefore both risk protection and a strategic positioning exercise.

The DORA “Hot Seat” Implementation Cookbook

This cookbook assumes you already have some level of DORA programme in motion (policies, project plans, maybe tooling), but leadership is not yet interview‑ready.

We’ll move through four phases:

1. Decode the examiners’ playbook.
2. Build a coherent leadership narrative + evidence.
3. Drill the management body under realistic pressure.
4. Make readiness continuous.

Phase 1 – Decode the Examiner’s Playbook

Objective: Turn DORA’s articles and RTS/ITS into a concrete question bank and heat‑map of likely interview topics.

1.1 Map DORA pillars to “board‑level questions”

Create a short, focused matrix with one row per DORA pillar:

• ICT risk management

  • How did the management body set ICT risk tolerance?
  • How are critical and important functions identified and reviewed?
  • How do you know ICT risk is within appetite today?

• ICT incident management & reporting

  • Describe your major incident process end‑to‑end.
  • Who decides an incident is “major” under the RTS criteria?
  • What were your last 3 significant incidents and what changed after them?

• Digital operational resilience testing (incl. TLPT)

  • What is your multi‑year test strategy and how is it approved?
  • If in TLPT scope: how did the board sign off on scoping, threat scenarios, and remediation?

• ICT third‑party risk & RoI

  • How does the board oversee outsourcing strategy and concentration risk?
  • Can you explain your Registers of Information in plain language?
  • What is your plan if a critical cloud or SaaS provider fails?

• Information sharing & continuous improvement

  • Are you part of information‑sharing arrangements (e.g. ISACs)?
  • How do lessons from incidents and tests change your controls?

For each question, note:

• Primary owner (CRO, CIO, CISO, COO, Head of TPRM, etc.).
• Existing artefacts (policies, dashboards, minutes, reports) that already answer part of it.
• Gaps – where you have work to do before anyone can answer confidently.

1.2 Form a DORA “Interview Squad”

Create a small, empowered working group specifically tasked with leadership readiness:

• Chair: CRO or Chief Risk/Resilience Officer.
• Members:
  • CIO / CTO (ICT architecture & operations).
  • CISO (security, threat landscape, incident response).
  • COO / Head of Business Continuity.
  • Head of ICT Third‑Party Risk / Procurement.
  • Head of Compliance / Legal.
  • Board Secretary / Head of Corporate Governance.

Tasks for the squad:

• Finalise the question bank.
• Own the evidence pack structure (next phase).
• Plan and run mock interviews and crisis simulations.
• Track management body action items arising from rehearsals.

Keep meetings short and focused; this is not another steering committee – it’s a readiness cell.

Phase 2 – Build the Leadership Story and Evidence

Objective: Create a coherent, defensible narrative for each DORA pillar, backed by concise, exam‑ready evidence.

2.1 Draft the “DORA narrative” for the management body

For each pillar, write a one‑page storyline in plain language:

1. What is our approach?

   • Key policies, governance structures, risk appetite statements.

2. What have we actually done?

   • Concrete actions in the last 12–24 months:
   • Frameworks redesigned, registers built, controls implemented.
   • Incidents handled, tests completed, TLPT performed, vendor exits managed.

3. How do we know it works?

   • Metrics and qualitative evidence:
   • Incident volumes & response times.
   • Control testing results, audit findings, independent reviews.
   • Trends in vendor risk ratings and concentration indicators.

4. What are our known gaps and plans?

   • Be honest. Supervisors expect gaps – what matters is:
   • That you know them.
   • That they’re prioritised, funded, and tracked.

These one‑pagers become the spine of every leadership answer.

2.2 Assemble a “DORA Evidence Pack” leaders can navigate

For each narrative page, link to specific artefacts, grouped logically:

• Governance & organisation

  • DORA governance map (committees, reporting lines).
  • Terms of reference, minutes showing management body challenge.
  • Approved risk appetite statements for ICT / operational resilience.

• Risk & control framework

  • ICT risk taxonomy and registers.
  • Control library mapped to DORA, NIS2, ISO 27001 etc.
  • KRI/KPI dashboards (e.g. patching SLAs, incident MTTR, backup success rates).

• Incidents & lessons learned

  • Last 3–5 major or significant incidents:
  • Initial / intermediate / final reports (aligned to ESA templates).
  • Board or committee packs discussing root cause and remediation.
  • Evidence of policy or control changes that followed.

• Testing & TLPT

  • Annual test plans, scenarios, and coverage of critical functions.
  • TLPT scopes, threat intel reports, debriefs, and remediation tracking.
  • Evidence of management body approval and follow‑up.

• Third‑party & RoI

  • Current Registers of Information with summaries for:
  • Number of ICT providers.
  • Which support critical/important functions.
  • Concentration on major cloud/SaaS platforms.
  • Template DORA‑compliant contract clauses (audit rights, incident notification, exit).
  • Vendor risk dashboards and recent material vendor incidents.

Compile this in a structured digital workspace (GRC platform, DORA tool, or well‑managed SharePoint) with:

• Clear indexing by pillar.
• Short summaries at the top of each section.
• Version control and access logs (supervisors like to see this).

2.3 Tighten management body reporting

Adjust regular board / committee reporting so DORA‑relevant content is routinely visible, not created just for the interview:

• Add a “Digital Operational Resilience” section to the risk report:

  • Top ICT risks vs appetite.
  • Incident and near‑miss summary.
  • Test plan status and key findings.
  • Third‑party risk highlights (e.g. CTPP dependency, RoI progress).

• Embed simple trend charts (3–4 quarters) rather than single snapshots.

Once this is routine, your “hot seat” becomes just a deeper conversation about information they already see.

Phase 3 – Drill the Management Body (Simulations & Mock Interviews)

Objective: Replace theory with muscle memory so leaders can handle tough questioning under pressure.

3.1 Run structured mock interviews

Design 1–2 hour sessions where external facilitators (internal audit, risk, or external advisors) play the role of supervisors.

Steps:

1. Scope the session

   • Focus each on 1–2 pillars (e.g. ICT risk + incidents; third‑party + testing).
   • Define roles: Chair, key executives, “supervisors”.

2. Use real questions

   • Draw from your Phase 1 question bank.
   • Add scenario‑based queries:
   • “Walk us through how you would react if your main cloud provider suffered a 24‑hour outage tomorrow.”
   • “Explain how you determined X function is not ‘critical or important’.”

3. Record and time‑box

   • Time pressure is real in actual interviews.
   • Record sessions (video or at least audio) for constructive debrief.

4. Debrief hard, but safely

   • Evaluate on clarity, consistency, and evidence reference (“can you show us that?”).
   • Identify where answers were:
   • Too conceptual / vague.
   • Overly technical for a board member.
   • Misaligned between executives.

Outcome: a concrete improvement plan for each leader (e.g. “strengthen explanation of RoI”, “simplify TLPT answers”, “know last 3 incident stats by heart”).

3.2 Run an integrated crisis simulation

At least once before you expect a major review:

• Simulate a major ICT incident end‑to‑end, including:
  • Detection and internal escalation.
  • Management body briefings (short, evolving).
  • Drafting of initial / intermediate / final regulator reports.
  • Decisions on customer communications, workarounds, and lessons learned.

Focus the debrief on:

• How quickly leadership got situational awareness.
• Whether they could reconcile technical details with risk appetite.
• How they balanced short‑term service recovery vs long‑term remediation.

This gives leaders lived experience to draw on in real interviews.

Phase 4 – Make “Hot Seat” Readiness Continuous

Objective: Ensure that you stay interview‑ready as DORA evolves (new RTS, CTPP designations, NIS2 interplay).

4.1 Embed DORA into regular governance

• Make DORA a standing agenda item at:

  • Risk or operational resilience committee.
  • At least annual board strategy or risk workshop.

• Once a year, present a succinct “DORA health check”:

  • Summary of supervisory developments (e.g. new RTS on subcontracting, Oversight Guide for CTPPs).
  • Status vs regulatory expectations (green/amber/red).
  • Planned changes to frameworks, tooling, or sourcing strategy.

4.2 Maintain a “living” question bank and playbook

• Update the question bank whenever:

  • New RTS/ITS or ESA guidance appears.
  • You experience a significant incident or major test finding.
  • You renegotiate or exit a major ICT provider.

• After any real supervisory meeting or inspection, capture:

  • Actual questions asked.
  • Concerns raised.
  • Commitments you made – and track delivery.

This becomes your institution‑specific exam prep manual.

4.3 Align tooling and data to interview needs

Where you have GRC / DORA platforms, SIEM/XDR, or TPRM tools:

• Ensure they can generate the views leadership will be asked about:

  • One‑page incident summaries with DORA classification attributes.
  • Up‑to‑date RoI extracts and concentration dashboards.
  • Test inventory, with clear link to critical services.

• Strive for one source of truth per metric.

• Board members should not see conflicting numbers across decks – that’s an instant red flag for supervisors.

The “First Moves” Checklist

Do these 10 things in the next 30–60 days to build real momentum:

1. Name an Executive Owner for DORA interviews

   • Typically the CRO or COO, explicitly accountable for leadership readiness.

2. Stand up the DORA Interview Squad

   • Small, cross‑functional group with clear terms of reference and weekly cadence.

3. Build a first‑cut question bank

   • 30–50 realistic questions mapped to DORA’s pillars and your structure.

4. Draft one‑page narratives per pillar

   • Use the “approach / what we’ve done / how we know / gaps” structure.

5. Inventory existing evidence

   • Map current board packs, risk dashboards, incident reports, test plans, and RoIs against those narratives.

6. Identify obvious red flags

   • Inconsistent incident metrics, missing RoIs, unclear ownership of TLPT, concentration on a single ICT provider without an exit plan.

7. Schedule your first mock interview

   • Pick two pillars, 90 minutes, and send the question themes to leaders one week in advance.

8. Create a DORA section in the next risk committee pack

   • Even if simple at first: key metrics, top issues, and upcoming milestones (e.g. RoI submissions, TLPT dates).

9. Review one high‑impact incident in depth

   • Prepare a case‑study style pack showing detection, classification, reporting, remediation, and board oversight.

10. Document your continuous‑improvement loop

    • How you track DORA gaps, assign owners, fund fixes, and close actions.
    • Supervisors want to see this machinery working.

Execute these and your management body moves rapidly from reactive to credible and prepared.

FAQ

1. What will supervisors actually ask the management body about DORA?

Expect questions in five clusters:

1. Governance & risk appetite – How you set ICT risk tolerance and oversee it.
2. Critical services & architecture – What you consider critical/important and why.
3. Incidents – How you detect, classify, report, and learn from major ICT incidents.
4. Testing & TLPT – How you design, approve, and act on resilience tests.
5. Third‑party risk & RoI – How you manage and exit ICT providers, especially clouds and SaaS.

They will test consistency across executives and between what you say and what your artefacts show.

2. How deeply do board members need to understand technical detail?

They do not need to recite patching windows or firewall rules.

They do need to:

• Understand concepts: critical services, ICT risk appetite, TLPT, major incident criteria, RoI.
• Explain governance: who is responsible, how they challenge, what information they see.
• Recall key facts and trends: recent major incidents, headline metrics, material vendor dependencies.

Think “strategic and oversight‑level fluency with concrete examples”, not engineering detail.

3. We’re behind on DORA implementation; is it still worth focusing on interview prep?

Yes – and supervisors will expect you to be transparent about your status.

A well‑prepared management body can:

• Clearly articulate where you are.
• Show a prioritised, funded plan to close gaps.
• Demonstrate active oversight and challenge.

That often lands better with supervisors than a superficially complete but poorly understood implementation.

4. How often should we run mock interviews?

For most institutions:

• Once initially for each major pillar (so 2–3 sessions total).
• Then annually, or ahead of known supervisory events (onsite inspections, JET reviews, thematic reviews).

After major incidents or TLPTs, run targeted debrief sessions so leaders can rehearse explaining what happened and what changed.

5. Do we need a dedicated “DORA tool” to be interview‑ready?

Not necessarily.

You do need:

• Reliable incident data and reports (often from SIEM/ITSM + GRC).
• Cohesive risk and control registers.
• Accurate RoIs and vendor risk views.
• Traceable testing evidence.

Whether that comes from a dedicated DORA platform, your existing GRC suite, or a curated set of tools is less important than consistency, accessibility, and auditability.

6. What are common mistakes boards make in DORA interviews?

Recurring pitfalls include:

• Over‑delegation – “That’s for IT”; failing to demonstrate true oversight.
• Inconsistent narratives – Different executives giving contradictory answers.
• Over‑optimism – Claiming “full compliance” when gaps are clear in documents.
• No ownership of third‑party risk – Treating vendor risk as a procurement issue, not a resilience one.
• Weak use of data – Being unable to quote or explain basic metrics from their own reports.

All of these are avoidable with the phased approach above.

Recap & Next Step

Supervisors now expect the management body to own digital operational resilience, not just sign policies.

The DORA “hot seat” is where that expectation is tested.

If you:

• Translate DORA into board‑level questions and narratives,
• Back them with clear, consistent evidence, and
• Rehearse leadership under realistic pressure,

then interviews become an opportunity to demonstrate control and maturity, not a threat.

Pick three items from the First Moves Checklist and book time this week to act on them.

Once the leadership team has survived a tough internal rehearsal together, you’ll know you’re on the right side of DORA’s hot seat.