What is the primary objective of **DORA**?

**The primary objective of DORA (Regulation (EU) 2022/2554) is to strengthen the digital operational resilience of the EU financial sector against ICT disruptions, including cyberattacks, system failures, and third-party risks.** Enacted December 14, 2022, and applying from January 17, 2025, it mandates ICT risk management, incident reporting, resilience testing, third-party oversight, and information sharing across 20 financial entity types and critical ICT third-party providers (CTPPs).

Who is legally or professionally required to comply with **DORA**?

**DORA legally requires compliance from approximately 22,000 EU-regulated financial entities across 20 types, including credit institutions, insurance undertakings, investment firms, payment institutions, and crypto-asset service providers, plus critical ICT third-party providers (CTPPs).** CTPPs, such as cloud and data analytics firms, face direct ESA oversight, with ~1,000+ EU ICT providers potentially designated by end-2025.

Does **DORA** require an external audit or third-party certification?

**DORA does not mandate external audits or third-party certification but requires independent, risk-based digital operational resilience testing, including annual basic tests and triennial threat-led penetration testing (TLPT) for critical entities.** Testing may involve external providers, with results reported to authorities; third-party oversight includes contractual audit rights for CTPPs.

How often should an assessment for **DORA** be performed?

**DORA mandates annual basic ICT resilience tests, such as vulnerability assessments, for all in-scope entities, with triennial advanced threat-led penetration testing (TLPT) for critical or designated entities.** ICT risk management frameworks require annual reviews, proportional to entity size, complexity, and risk exposure.

What are the consequences of non-compliance with **DORA**?

**Non-compliance with DORA incurs administrative fines up to 2% of total global annual turnover for firms or €5 million (or 10% of annual salary) for individuals, imposed by ESAs or competent authorities.** Additional penalties include oversight fees up to €1 million annually for CTPPs, remediation orders, and public censures, effective from January 17, 2025.

Can **DORA** be mapped to other international frameworks?

**Yes, DORA's ICT risk management, incident reporting, testing, and third-party oversight elements can be mapped to other international frameworks, leveraging existing compliance for efficiency.** Financial entities often align DORA's proportional controls, such as recovery time objectives under 4 hours, with prior guidelines like EBA 2019 ICT rules.

What is the first step to begin implementing **DORA**?

**The first step to implement DORA is conducting a gap analysis against the ESAs' Regulatory Technical Standards (RTS) on ICT risk frameworks, published January 17, 2024.** This identifies deficiencies in ICT strategies, incident classification (e.g., major incidents impacting >5% users or €100,000+ losses), third-party dependencies, and testing plans ahead of the January 17, 2025, deadline.

What is the primary objective of **FISMA**?

**FISMA's primary objective is to provide a comprehensive framework for federal agencies to develop, document, implement, and maintain risk-based information security programs protecting the confidentiality, integrity, and availability of federal information and systems.** Enacted in 2002 and modernized in 2014, it mandates agency-wide programs using NIST's Risk Management Framework (RMF) with seven steps: Prepare, Categorize (per FIPS 199), Select (NIST SP 800-53), Implement, Assess, Authorize, and Monitor. This ensures protections are commensurate with risk to operations, assets, individuals, and the nation, with DHS/CISA overseeing civilian systems and OMB providing policy guidance.

Who is legally or professionally required to comply with **FISMA**?

**FISMA legally requires compliance from all federal executive branch civilian agencies and any contractors, vendors, or third parties operating federal information systems or processing federal data.** This includes cloud providers (via FedRAMP), systems integrators, and state/local entities administering federal programs like Medicaid. National security systems are excluded. Agency heads, CIOs, CISOs, and Authorizing Officials bear direct responsibility, with contractors flowing down requirements contractually to ensure equivalent protections for Controlled Unclassified Information (CUI).

Does **FISMA** require an external audit or third-party certification?

**FISMA requires annual independent evaluations by agency Inspectors General (IGs), who may use third-party assessors, but does not mandate external certification like ISO.** IGs assess program maturity across NIST Cybersecurity Framework functions using 20 core and 17 supplemental CISA metrics, rating levels from Ad Hoc (1) to Optimized (5). Security Assessment Reports (SARs) and Plans of Action and Milestones (POA&Ms) support Authorizations to Operate (ATOs), with continuous monitoring evidence collected via tools like DHS Continuous Diagnostics and Mitigation (CDM).

How often should an assessment for **FISMA** be performed?

**FISMA requires annual independent IG evaluations of agency-wide security programs, supplemented by ongoing continuous monitoring of controls.** RMF assessments occur during the Assess step and continuously via NIST SP 800-137, with system reauthorizations tied to risk changes. Major incidents demand real-time reporting to CISA and Congress within 30 days for PII breaches. POA&Ms track remediation with defined milestones, feeding quarterly IG and OMB metrics.

What are the consequences of non-compliance with **FISMA**?

**Non-compliance with FISMA results in unfavorable IG reports, OMB remediation directives, reduced funding, operational restrictions, and potential contract loss or debarment for contractors.** Agencies face public exposure via OMB's annual report to Congress, increased CISA oversight, and DHS binding operational directives. Persistent failures, as in HHS's repeated "Not Effective" ratings, lead to GAO scrutiny, mission constraints, and eroded stakeholder trust without direct monetary fines.

An **FISMA** be mapped to other international frameworks?

**FISMA does not officially map to other international frameworks, as it is a U.S.-specific federal mandate focused on NIST RMF and SP 800-53 for civilian agencies.** Its risk-based controls align conceptually with global standards, enabling informal reciprocity for contractors, but formal mappings are agency-driven and not statutorily required. FedRAMP facilitates cloud reuse without cross-framework certifications.

What is the first step to begin implementing **FISMA**?

**The first step to implement FISMA is the RMF Prepare phase: establish governance, assign roles (e.g., CIO, CISO, Authorizing Official), and create a complete system inventory.** Develop a risk management strategy, classify systems per FIPS 199 (Low/Moderate/High impact), and document in initial System Security Plans (SSPs), prioritizing high-value assets for quick wins in complex environments.

DORA vs FISMA | GRADUM

Standards Comparison

DORA

Mandatory

2023

EU regulation for digital operational resilience in financial sector

FISMA

Mandatory

2014

U.S. federal law for risk-based information security management

Quick Verdict

DORA mandates ICT resilience for EU finance firms with testing and reporting, while FISMA requires risk-based security for US federal systems via NIST RMF. Companies adopt DORA for regulatory compliance, FISMA for contracts and resilience.

Digital Operational Resilience

DORA

Regulation (EU) 2022/2554 Digital Operational Resilience Act

Cost

€€€€

Complexity

High

Implementation Time

18-24 months

Key Features

Mandates comprehensive ICT risk management frameworks overseen by management
Enforces 4-hour initial incident reporting for major disruptions
Requires triennial threat-led penetration testing for critical entities
Imposes direct oversight on critical third-party ICT providers
Applies proportionality principle based on entity size and risk

Cybersecurity

FISMA

Federal Information Security Modernization Act of 2014

Cost

€€€€

Complexity

Medium

Implementation Time

18-24 months

Key Features

NIST RMF 7-step risk management lifecycle
Continuous monitoring and diagnostics requirements
FIPS 199 system impact categorization
NIST SP 800-53 tailored security controls
Annual IG evaluations and OMB reporting

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 establishing a harmonized framework for digital operational resilience in the financial sector. It targets ICT disruptions like cyberattacks and third-party failures, applying a risk-based, proportional approach to 20 financial entity types and critical ICT providers across 27 member states, effective January 17, 2025.

Key Components

Four core pillars: ICT risk management, incident reporting, resilience testing, and third-party oversight.
Specific requirements like 4/72-hour/1-month reporting timelines, annual basic tests, triennial TLPT, and ESAs supervision of CTPPs.
Built on principles of proportionality, governance by management body, and integration with frameworks like EBA guidelines.
Compliance via self-assessment, authority reporting, and potential fines up to 2% global turnover.

Why Organizations Use It

Mandatory for EU financial entities to mitigate systemic ICT risks amid rising threats (74% ransomware hit rate). Enhances resilience, stakeholder trust, and competitive edge through proactive strategies, reducing outage impacts like CrowdStrike 2024.

Implementation Overview

Conduct gap analyses against RTS/ITS (2024 batches), develop frameworks, test programs, and vendor contracts. Applies EU-wide to all sizes; proportionality eases for SMEs. No certification but ongoing audits, reporting; leverage tools for monitoring.

FISMA Details

What It Is

Federal Information Security Modernization Act (FISMA) is a U.S. federal law establishing a mandatory, risk-based framework for protecting federal information and systems. Enacted in 2014, it modernizes the 2002 version, focusing on federal agencies, contractors, and third-party providers through NIST Risk Management Framework (RMF)—a 7-step process: Prepare, Categorize, Select, Implement, Assess, Authorize, Monitor.

Key Components

NIST SP 800-53 controls (over 1,000 across 20 families) tailored by FIPS 199 impact levels (Low/Moderate/High).
Continuous monitoring via SP 800-137, incident reporting, and POA&Ms.
Oversight by OMB, CISA/DHS, IGs; built on CIA triad (confidentiality, integrity, availability).
Compliance via annual metrics, maturity models (Levels 1-5), no formal certification but ATOs required.

Why Organizations Use It

Mandatory for federal entities/contractors handling federal data; avoids penalties like debarment.
Reduces breach risks, enables market access (e.g., FedRAMP), builds resilience and efficiency.
Enhances trust with stakeholders, aligns cybersecurity to mission outcomes.

Implementation Overview

Phased RMF approach: governance/inventory, categorize/select controls, implement/assess/authorize, continuous monitoring. Applies to federal agencies/contractors; scales by size/portfolio. Requires audits by IGs, evidence-based reporting. (178 words)

Key Differences

Aspect	DORA	FISMA
Scope	Digital operational resilience in finance	Federal information systems security
Industry	EU financial sector only	US federal agencies/contractors
Nature	Mandatory EU regulation	Mandatory US federal law
Testing	Annual basic, triennial TLPT	Continuous monitoring, RMF assessments
Penalties	Up to 2% global turnover	Contract loss, IG reports

Scope

DORA

Digital operational resilience in finance

FISMA

Federal information systems security

Industry

DORA

EU financial sector only

FISMA

US federal agencies/contractors

Nature

DORA

Mandatory EU regulation

FISMA

Mandatory US federal law

Testing

DORA

Annual basic, triennial TLPT

FISMA

Continuous monitoring, RMF assessments

Penalties

DORA

Up to 2% global turnover

FISMA

Contract loss, IG reports

Frequently Asked Questions

Common questions about DORA and FISMA

DORA FAQ

FISMA FAQ

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DORA

FISMA

Quick Verdict

DORA

Key Features

FISMA

Key Features

Detailed Analysis

DORA Details

What It Is

Key Components

Why Organizations Use It

Implementation Overview

FISMA Details

What It Is

Key Components

Why Organizations Use It

Implementation Overview

Key Differences

Scope

Industry

Nature

Testing

Penalties

Frequently Asked Questions

DORA FAQ

What is the primary objective of DORA?

Who is legally or professionally required to comply with DORA?

Does DORA require an external audit or third-party certification?

How often should an assessment for DORA be performed?

What are the consequences of non-compliance with DORA?

Can DORA be mapped to other international frameworks?

What is the first step to begin implementing DORA?

FISMA FAQ

What is the primary objective of FISMA?

Who is legally or professionally required to comply with FISMA?

Does FISMA require an external audit or third-party certification?

How often should an assessment for FISMA be performed?

What are the consequences of non-compliance with FISMA?

An FISMA be mapped to other international frameworks?

What is the first step to begin implementing FISMA?

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