DORA
EU regulation for digital operational resilience in financial sector
ISO 37301
Certifiable international standard for compliance management systems.
Quick Verdict
DORA mandates ICT resilience for EU financial firms against cyber threats, while ISO 37301 offers voluntary certification for comprehensive compliance systems across sectors. Financial entities adopt DORA for regulatory survival; others choose ISO 37301 for governance excellence and stakeholder trust.
DORA
Regulation (EU) 2022/2554, Digital Operational Resilience Act
Key Features
- Mandates comprehensive ICT risk management frameworks
- Requires 4-hour incident reporting for major incidents
- Mandates threat-led penetration testing every 3 years
- Oversees critical third-party ICT service providers
- Harmonizes resilience standards across EU financial sector
ISO 37301
ISO 37301:2021 Compliance management systems – Requirements
Key Features
- Certifiable CMS requirements replacing ISO 19600 guidance
- HLS alignment for integration with other ISO standards
- Risk-based planning for obligations and opportunities
- Mandatory whistleblowing channels and anti-retaliation protections
- Leadership-driven culture and continual improvement PDCA
Detailed Analysis
A comprehensive look at the specific requirements, scope, and impact of each standard.
DORA Details
What It Is
DORA, formally Regulation (EU) 2022/2554, is a transformative EU regulation enhancing digital operational resilience for the financial sector against ICT risks like cyberattacks and outages. It targets 20 financial entity types and critical third-party providers across 27 member states, using a proactive, risk-based, proportional approach.
Key Components
- **ICT Risk ManagementFrameworks for identification, mitigation, and annual reviews.
- **Incident Reporting4-hour notifications, 72-hour updates for major incidents.
- **Resilience TestingAnnual scans and triennial TLPT.
- **Third-Party OversightDue diligence, monitoring of CTPPs. Enforced via ESAs with fines up to 2% global turnover; no formal certification but mandatory compliance.
Why Organizations Use It
- Meets legal mandate effective January 2025.
- Counters threats (74% ransomware hit rate).
- Prevents systemic disruptions like CrowdStrike outage.
- Boosts trust, resilience, and cybersecurity investments.
Implementation Overview
Gap analyses, framework development, testing programs, vendor reviews. Applies EU-wide to all sizes proportionally; involves reporting, audits by authorities.
ISO 37301 Details
What It Is
ISO 37301:2021, officially Compliance management systems – Requirements with guidance for use, is a certifiable international standard for Compliance Management Systems (CMS). It provides auditable requirements to establish, implement, maintain, and improve CMS across all organization sizes and sectors. Built on the ISO High-Level Structure (HLS) and Plan-Do-Check-Act (PDCA) cycle, it adopts a risk-based approach to identify obligations, risks, and controls.
Key Components
- Leadership commitment, policy, roles, and culture.
- **Planningrisk assessment, objectives, actions.
- **Supportresources, competence (per ISO 37303), awareness, communication (whistleblowing).
- **Operationcontrols, third-party management.
- **Performance evaluationmonitoring, audits, reviews.
- **Improvementnonconformities, continual enhancement. Follows HLS (10 clauses); companion standards like ISO 37302 for metrics.
Why Organizations Use It
- Reduces regulatory risks, fines, reputational harm.
- Builds stakeholder trust via certification.
- Integrates with ISO 9001/14001/27001.
- Drives integrity culture, ESG alignment.
- Meets investor, partner demands.
Implementation Overview
Phased: gap analysis, register building, training, audits, certification (3-year cycle via ANAB-accredited bodies). Scalable for SMEs to enterprises; universal applicability.
Key Differences
| Aspect | DORA | ISO 37301 |
|---|---|---|
| Scope | ICT/digital operational resilience in finance | All compliance obligations across sectors |
| Industry | EU financial entities and CTPPs | All industries, global applicability |
| Nature | Mandatory EU regulation | Voluntary certifiable standard |
| Testing | Annual basic + triennial TLPT | Internal audits + certification audits |
| Penalties | Up to 2% global turnover fines | Loss of certification, no fines |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about DORA and ISO 37301
DORA FAQ
ISO 37301 FAQ
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