DORA
EU regulation for digital operational resilience in financial sector
23 NYCRR 500
NY regulation for financial services cybersecurity.
Quick Verdict
DORA mandates EU-wide digital resilience for financial entities with TLPT testing, while 23 NYCRR 500 enforces NY-specific cybersecurity for licensed firms via MFA, encryption, and 72-hour reporting. Organizations adopt them for regulatory compliance and cyber risk mitigation.
DORA
Regulation (EU) 2022/2554 Digital Operational Resilience Act
Key Features
- Oversight framework for critical ICT third-party providers (CTPPs)
- Threat-led penetration testing (TLPT) every 3 years for critical entities
- 4-hour initial reporting for major ICT incidents
- Comprehensive ICT risk management frameworks with proportionality
- Harmonized rules across 20 financial entity types in EU
23 NYCRR 500
23 NYCRR Part 500 Cybersecurity Regulation
Key Features
- Mandates qualified CISO with board reporting
- Requires periodic documented risk assessments
- 72-hour cybersecurity event notification
- Multi-factor authentication for external access
- Annual compliance certification by April 15
Detailed Analysis
A comprehensive look at the specific requirements, scope, and impact of each standard.
DORA Details
What It Is
Regulation (EU) 2022/2554, known as the Digital Operational Resilience Act (DORA), is an EU-wide regulation establishing a comprehensive framework for managing ICT risks in the financial sector. It applies to 20 types of financial entities and critical ICT third-party providers (CTPPs), focusing on resilience against disruptions like cyberattacks and system failures through a proportionality-based, risk-centric approach.
Key Components
- **Four main pillarsICT risk management frameworks, incident reporting/response, digital operational resilience testing (including triennial TLPT), and third-party risk oversight.
- Standardized requirements like 4-hour initial incident notifications for major events (>5% users or €100k+ losses).
- Built on harmonized RTS/ITS from ESAs, with direct supervision of CTPPs via Joint Examination Teams (JETs).
- No certification but mandatory compliance with supervisory reporting and audits.
Why Organizations Use It
Financial entities adopt DORA to meet legal obligations, mitigate systemic ICT risks amid rising cyber threats (74% ransomware incidence), and enhance resilience. It drives €10-15B annual EU compliance investments, reduces outage impacts (e.g., CrowdStrike 2024), builds stakeholder trust, and supports competitive positioning through unified EU rules.
Implementation Overview
Involves gap analyses against RTS (e.g., Batch 1 Jan 2024), building frameworks, automating reporting/tools like GRC platforms, and testing programs. Targets ~22,000 EU entities; large firms leverage existing setups, SMEs face higher burdens. Full application from January 17, 2025, with ongoing ESAs oversight.
23 NYCRR 500 Details
What It Is
23 NYCRR Part 500 is the New York Department of Financial Services (NYDFS) Cybersecurity Regulation, a mandatory framework establishing minimum risk-based cybersecurity requirements for Covered Entities—financial institutions licensed under NY Banking, Insurance, or Financial Services Law. Its primary purpose is protecting the confidentiality, integrity, and availability of Information Systems and Nonpublic Information (NPI) amid evolving cyber threats.
Key Components
- Seven pillars: governance, risk assessment, policies, controls, monitoring/testing, third-party management, incident response/reporting.
- 20+ sections including CISO designation (§500.4), risk assessments (§500.9), MFA (§500.12), encryption (§500.15), 72-hour notifications (§500.17).
- Built on risk-centric architecture; annual compliance certification.
Why Organizations Use It
- Legal mandate for NYDFS-regulated entities; avoids multimillion-dollar fines via consent orders.
- Enhances resilience, reduces breach risks, builds customer trust; aligns with NIST CSF.
Implementation Overview
- Phased approach: gap analysis, risk assessment, control deployment, testing.
- Applies to banks, insurers, licensees globally if NY operations; Class A enhanced rules.
- Self-certification annually by April 15; no universal external audit, but documentation retained 5 years. (178 words)
Key Differences
| Aspect | DORA | 23 NYCRR 500 |
|---|---|---|
| Scope | Digital operational resilience, ICT risks, third-party oversight | Cybersecurity program, NPI protection, risk-based controls |
| Industry | EU financial entities, CTPPs | NYDFS-licensed financial services |
| Nature | Mandatory EU regulation, harmonized enforcement | Mandatory NY state regulation, supervisory enforcement |
| Testing | Annual basic, triennial TLPT for critical | Annual pen testing, bi-annual vulnerability assessments |
| Penalties | Up to 2% global turnover | Civil monetary penalties, consent orders |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about DORA and 23 NYCRR 500
DORA FAQ
23 NYCRR 500 FAQ
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