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 on December 14, 2022, and applying from January 17, 2025, it mandates ICT risk management, incident reporting, resilience testing, and third-party oversight for 20 financial entity types and critical ICT third-party providers (CTPPs).

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

**DORA applies to 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 if designated, with ~1,000+ EU ICT providers in scope per the 2024 ESAs landscape report.

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

**DORA does not mandate external audits or third-party certification but requires independent 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 requires annual basic ICT resilience tests, such as vulnerability assessments, and triennial advanced threat-led penetration testing (TLPT) for critical or designated entities.** ICT risk management frameworks must undergo annual reviews, with testing tailored proportionally to entity size, complexity, and risk exposure per ESAs' RTS.

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 and up to €5 million or 10% of annual salary for individuals, imposed by ESAs or competent authorities.** Additional measures include remedial orders, oversight fees up to €1 million annually for CTPPs, and reputational damage from public enforcement.

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

**DORA's does not specify mappings to other international frameworks, focusing solely on its harmonization of EU financial sector rules.** Entities should conduct entity-specific gap analyses against DORA's RTS/ITS (Batches 1 and 2, 2024) for any alignments, prioritizing its standalone ICT risk, testing, and reporting pillars.

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

**The first step to implement DORA is to conduct a gap analysis of current ICT risk management frameworks against ESAs' Regulatory Technical Standards (RTS) published January 17, 2024.** This identifies deficiencies in incident reporting, testing, and third-party oversight, enabling proportional roadmaps ahead of the January 17, 2025, application date.

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

**The primary objective of **GDPR** is to protect the fundamental rights and freedoms of natural persons, particularly their right to the protection of personal data, while ensuring the free movement of personal data within the EU.** Adopted on 14 April 2016 and directly applicable from 25 May 2018, it replaces the fragmented 1995 Data Protection Directive (95/46/EC) by harmonizing rules across Member States through core principles in Article 5, including lawfulness, fairness, transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity, confidentiality, and accountability.

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

**GDPR applies to any **data controller** or **data processor** established in the EU, or any non-EU entity offering goods/services to or monitoring the behaviour of EU data subjects, per Article 3's extraterritorial scope.** This includes organizations processing **personal data**—any information relating to an identifiable natural person, such as names, IP addresses, or genetic data—regardless of location. Non-EU controllers/processors must appoint an EU representative under Article 27 unless processing is occasional and low-risk.

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

**No, **GDPR** does not mandate external audits or third-party certification for compliance.** Article 42 encourages voluntary certification mechanisms, codes of conduct (Article 40), and seals/ marks as accountability tools, but these are optional. Organizations demonstrate compliance via internal measures like Records of Processing Activities (Article 30), Data Protection Impact Assessments (DPIAs, Article 35), and Data Protection Officer (DPO) appointments (Article 37) where required.

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

**GDPR requires ongoing, risk-based assessments rather than fixed intervals, with **DPIAs** mandatory prior to high-risk processing and reviewed if risks change (Article 35).** Security of processing (Article 32) demands continuous evaluation of "state-of-the-art" measures, while breach notifications must occur within 72 hours of awareness (Article 33). Accountability (Article 5(2)) necessitates regular reviews of Records of Processing Activities (Article 30) to ensure perpetual compliance.

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

**Non-compliance with **GDPR** can result in administrative fines up to **€20 million or 4% of total global annual turnover**, whichever is higher, for severe infringements (Article 83(5)).** Tiered penalties apply: up to €10 million or 2% for lesser violations (Article 83(4)). Supervisory authorities impose sanctions via the one-stop-shop mechanism (Article 56), with additional remedies including injunctions, data subject compensation (Article 82), and reputational damage, as seen in fines against Google (€50M) and Meta (€1.2B).

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

**Yes, **GDPR** principles have influenced and can be mapped to frameworks like Brazil’s LGPD, California’s CCPA/CPRA, Japan’s APPI, and South Korea’s PIPA, via adequacy decisions (Article 45).** Its extraterritorial reach and concepts like accountability, consent, and data subject rights exemplify the Brussels Effect, enabling data transfers under equivalence, though differences exist in opt-in/opt-out models and penalties.

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

**The first step to implement **GDPR** is to conduct a comprehensive data mapping exercise to identify all personal data processing activities, controllers, processors, and legal bases (Articles 5, 30).** This informs Records of Processing Activities, lawful basis selection (Article 6), DPIA scoping (Article 35), and DPO evaluation (Article 37), establishing accountability under Article 5(2).

DORA vs GDPR | GRADUM

Standards Comparison

DORA

Mandatory

2023

EU regulation for digital operational resilience in financial sector

GDPR

Mandatory

2016

EU regulation for personal data protection

Quick Verdict

DORA mandates ICT resilience for EU financial firms against disruptions, while GDPR enforces personal data protection globally. Financial entities adopt DORA for compliance by 2025; all firms use GDPR to avoid massive fines and build trust.

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
Requires 4-hour reporting for major incidents
Imposes triennial threat-led penetration testing
Oversees critical third-party ICT providers
Harmonizes resilience across 20 financial entity types

Data Privacy

GDPR

General Data Protection Regulation (GDPR)

Cost

€€€

Complexity

Medium

Implementation Time

18-24 months

Key Features

Extraterritorial scope for non-EU entities targeting EU residents
Fines up to 4% of global annual turnover
Accountability principle requiring demonstrable compliance
One-stop-shop mechanism for cross-border enforcement
Privacy by design and data protection impact assessments

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 in finance against disruptions like cyberattacks. Applicable from January 17, 2025, it covers 20 financial entity types and critical ICT third-party providers (CTPPs) across 27 member states. Employs a proportional, risk-based approach shifting from reactive to proactive resilience.

Key Components

**ICT Risk ManagementComprehensive frameworks for risk identification, mitigation, annual reviews.
**Incident Reporting4-hour initial, 72-hour intermediate notifications for major events.
**Resilience TestingAnnual vulnerability scans, triennial threat-led penetration testing (TLPT).
**Third-Party OversightContractual clauses, monitoring, ESAs supervision of CTPPs. Enforced via RTS/ITS, penalties up to 2% global turnover; no certification but supervisory compliance.

Why Organizations Use It

Mandatory compliance avoids fines amid rising threats (74% ransomware hit rate).
Enhances systemic resilience, stakeholder trust, integrates with Solvency II/NIS2.
Drives competitive advantages through robust defenses, €10-15B EU investments.

Implementation Overview

Gap analyses, framework builds, tool integrations, testing plans. Proportional to size/complexity; ~22,000 entities. Key activities: vendor mapping, simulations, RTS adoption by 2025 deadline.

GDPR Details

What It Is

General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a directly applicable EU regulation protecting natural persons' data. Its primary purpose is harmonizing data privacy across EU member states, with extraterritorial scope for any processing targeting EU residents. It adopts a risk-based, accountability-driven approach emphasizing privacy by design.

Key Components

Seven core principles: lawfulness, fairness, purpose limitation, data minimization, accuracy, storage limitation, integrity/confidentiality, plus accountability.
Data subject rights (access, rectification, erasure, portability, objection).
Obligations like DPIAs, DPO appointment, breach notification within 72 hours.
One-stop-shop enforcement; fines up to €20M or 4% global turnover.

Why Organizations Use It

Mandatory compliance for EU data processing avoids severe penalties.
Enhances risk management, builds stakeholder trust, supports digital single market.
Boosts reputation, enables global data flows via adequacy decisions.

Implementation Overview

Gap analysis, policy updates, training, technical measures (encryption, pseudonymization).
Applies to all sizes processing EU data; ongoing audits, no formal certification but DPA oversight.

Frequently Asked Questions

Common questions about DORA and GDPR

DORA FAQ

GDPR FAQ

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DORA

GDPR

Quick Verdict

DORA

Key Features

GDPR

Key Features

Detailed Analysis

DORA Details

What It Is

Key Components

Why Organizations Use It

Implementation Overview

GDPR Details

What It Is

Key Components

Why Organizations Use It

Implementation Overview

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?

GDPR FAQ

What is the primary objective of GDPR?

Who is legally or professionally required to comply with GDPR?

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

How often should an assessment for GDPR be performed?

What are the consequences of non-compliance with GDPR?

Can GDPR be mapped to other international frameworks?

What is the first step to begin implementing GDPR?

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