Standards Comparison

    DORA

    Mandatory
    2023

    EU regulation for digital operational resilience in financial sector

    VS

    ISO 27701

    Voluntary
    2019

    International standard for privacy information management systems.

    Quick Verdict

    DORA mandates ICT resilience for EU financial entities via risk management and testing, while ISO 27701 provides voluntary PIMS certification for global privacy compliance. Firms adopt DORA for regulatory survival, ISO 27701 for auditable privacy governance and market trust.

    Digital Operational Resilience

    DORA

    Regulation (EU) 2022/2554 Digital Operational Resilience Act

    Cost
    €€€€
    Complexity
    Medium
    Implementation Time
    18-24 months

    Key Features

    • Mandates comprehensive ICT risk management frameworks
    • Requires 4-hour initial major incident reporting
    • Enforces triennial threat-led penetration testing (TLPT)
    • Establishes oversight of critical third-party providers
    • Harmonizes resilience rules across EU states
    Privacy Management

    ISO 27701

    ISO/IEC 27701:2025 Privacy Information Management

    Cost
    €€€
    Complexity
    High
    Implementation Time
    6-12 months

    Key Features

    • Extends ISO 27001 with PIMS for privacy governance
    • Separate Annex A/B controls for controllers/processors
    • GDPR mappings and risk-based privacy assessments
    • Auditable evidence via RoPA, DSARs, SoA
    • Standalone certification option in 2025 edition

    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 enhancing digital operational resilience in the financial sector against ICT risks like cyberattacks and outages. It targets 20 financial entity types and critical ICT third-party providers (CTPPs), using a risk-based, proportional approach with management oversight.

    Key Components

    • **ICT Risk ManagementIdentify, mitigate risks with annual reviews.
    • **Incident Reporting4-hour initial, 72-hour intermediate, 1-month analysis.
    • **Resilience TestingAnnual basic tests, triennial TLPT.
    • **Third-Party OversightDue diligence, monitoring, ESAs supervision of CTPPs. Built on harmonized standards, mandates compliance without certification but with authority reporting.

    Why Organizations Use It

    • Ensures legal compliance, avoiding 2% turnover fines.
    • Mitigates systemic cyber threats (74% ransomware hit).
    • Boosts resilience, stakeholder trust, and market stability.
    • Drives cybersecurity innovation amid rising incidents.

    Implementation Overview

    • Gap analyses, framework development by Jan 2025.
    • Key steps: Risk assessments, testing programs, vendor contracts.
    • Applies EU-wide to financial firms proportionally by size/complexity.
    • Authority audits, ongoing reporting required.

    ISO 27701 Details

    What It Is

    ISO/IEC 27701:2025 is the international standard for establishing, implementing, maintaining, and improving a Privacy Information Management System (PIMS). It extends ISO 27001's information security framework with privacy-specific requirements for PII controllers and processors, using a risk-based, PDCA (Plan-Do-Check-Act) approach to manage privacy risks.

    Key Components

    • Clauses 4–10 mirror ISO 27001, extended for privacy governance.
    • Annex A (controllers): 37 controls on consent, rights, retention.
    • Annex B (processors): 25 controls on contracts, assistance.
    • Mappings to GDPR (Annex D), ISO 27002; certification via accredited bodies.

    Why Organizations Use It

    • Demonstrates accountability for GDPR, LGPD compliance.
    • Reduces privacy risks, enhances trust, aids procurement.
    • Provides auditable evidence, competitive differentiation.

    Implementation Overview

    • Phased: scope, gap analysis, controls, audits (6-12 months typical).
    • Applies to all PII-processing orgs; integrates with ISMS.
    • Two-stage certification audits, 3-year cycle with surveillance.

    Key Differences

    Scope

    DORA
    Digital operational resilience in finance
    ISO 27701
    Privacy management system for PII processing

    Industry

    DORA
    EU financial entities and CTPPs
    ISO 27701
    All sectors processing PII globally

    Nature

    DORA
    Mandatory EU regulation
    ISO 27701
    Voluntary certification standard

    Testing

    DORA
    Annual basic, triennial TLPT
    ISO 27701
    Internal audits, 3-year certification cycle

    Penalties

    DORA
    Up to 2% global turnover fines
    ISO 27701
    Loss of certification, no legal fines

    Frequently Asked Questions

    Common questions about DORA and ISO 27701

    DORA FAQ

    ISO 27701 FAQ

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