DORA
EU regulation for digital operational resilience in financial sector
CMMC
DoD certification framework for DIB cybersecurity maturity
Quick Verdict
DORA mandates ICT resilience for EU finance against cyber threats via risk frameworks and testing, while CMMC certifies DoD contractors' cybersecurity for FCI/CUI through tiered NIST assessments. Firms adopt DORA for regulatory compliance, CMMC for contract eligibility.
DORA
Regulation (EU) 2022/2554, Digital Operational Resilience Act
Key Features
- Mandates comprehensive ICT risk management frameworks
- Requires 4-hour major incident reporting timelines
- Enforces triennial threat-led penetration testing (TLPT)
- Oversees critical third-party ICT providers (CTPPs)
- Harmonizes rules across 20 financial entity types
CMMC
Cybersecurity Maturity Model Certification (CMMC 2.0)
Key Features
- Three cumulative maturity levels for tiered protections
- 110 NIST SP 800-171 controls at Level 2
- C3PAO third-party assessments for certification
- POA&Ms with strict 180-day closure limits
- DFARS flow-down for supply chain compliance
Detailed Analysis
A comprehensive look at the specific requirements, scope, and impact of each standard.
DORA Details
What It Is
Digital Operational Resilience Act (DORA), formally Regulation (EU) 2022/2554, is an EU-wide regulation strengthening ICT resilience for financial entities against disruptions like cyberattacks. It employs a risk-based, proportional approach, covering 20 financial entity types and critical ICT third-party providers (CTPPs) across 27 member states, effective January 17, 2025.
Key Components
- **ICT Risk ManagementComprehensive frameworks for risk identification, mitigation, encryption, and annual reviews.
- **Incident Reporting4-hour initial alerts, 72-hour updates, 1-month root-cause for major incidents (>5% users or €100k losses).
- **Resilience TestingAnnual vulnerability scans; triennial TLPT for critical functions.
- **Third-Party OversightContractual due diligence, monitoring, ESA-led supervision of CTPPs. No formal certification; enforced via RTS/ITS and penalties up to 2% global turnover.
Why Organizations Use It
Legal mandate for EU finance; mitigates systemic risks (74% ransomware hit); enhances post-CrowdStrike resilience; builds trust; spurs cybersecurity investments (€10-15B EU-wide).
Implementation Overview
Gap analysis against RTS; develop frameworks, testing plans, vendor strategies. Tailored by size/complexity; for ~22,000 entities. Ongoing audits, no certification, urgent 2025 compliance.
CMMC Details
What It Is
The Cybersecurity Maturity Model Certification (CMMC) is a U.S. Department of Defense (DoD) program and certification framework to verify cybersecurity protections for Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) in the Defense Industrial Base (DIB). It uses a tiered maturity model with three levels, mapping to FAR 52.204-21, NIST SP 800-171 Rev 2, and NIST SP 800-172 requirements.
Key Components
- Three cumulative levels: Level 1 (17 basic practices), Level 2 (110 controls), Level 3 (+24 enhanced practices)
- 14 domains including Access Control, Incident Response, Risk Assessment
- Assessment via self-assessments, C3PAO, or DIBCAC; POA&Ms limited to 180 days
- Reporting to SPRS/eMASS with 3-year certification validity
Why Organizations Use It
- Mandatory for DoD contract eligibility, avoiding disqualification risks
- Reduces cyber threats, operational disruptions, insurance costs
- Builds supply chain trust, competitive bidding advantage
- Enhances resilience, reputation among stakeholders
Implementation Overview
- Phased: scoping, gap analysis, remediation, assessment, sustainment
- Targets DIB contractors/subcontractors handling FCI/CUI
- Involves SSP development, evidence collection, training, annual affirmations
Key Differences
| Aspect | DORA | CMMC |
|---|---|---|
| Scope | ICT risk mgmt, incidents, testing, third-party oversight | Cybersecurity practices for FCI/CUI protection |
| Industry | EU financial entities + CTPPs | US DoD contractors/subcontractors |
| Nature | Mandatory EU regulation | Certification program with assessments |
| Testing | Annual basic + triennial TLPT by authorities | Self-assess L1/L2 or C3PAO/DIBCAC every 3 years |
| Penalties | Up to 2% global turnover fines | Contract ineligibility, no direct fines |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about DORA and CMMC
DORA FAQ
CMMC FAQ
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