With the enforcement of the Digital Operational Resilience Act (DORA) rapidly approaching, financial institutions and ICT service providers must ensure their operational resilience measures align with regulatory expectations. Compliance with DORA is not just a legal obligation—it is essential for mitigating ICT-related risks and ensuring the stability of financial markets.

A gap analysis is a structured approach to evaluating an organization’s current ICT risk management framework against DORA’s requirements. By systematically identifying compliance gaps, financial entities can address vulnerabilities before they become regulatory liabilities. This proactive assessment helps prioritize remediation efforts, allocate resources efficiently, and strengthen overall resilience.

This guide will walk you through the key steps of conducting a DORA gap analysis. From defining the scope to mapping existing controls and developing an action plan, each step is designed to help your organization navigate the complexities of compliance. By the end, you’ll have a clear roadmap to close compliance gaps and reinforce your organization’s cybersecurity posture.

Understanding Gap Analysis in the Context of DORA

A gap analysis is a structured assessment that compares an organization’s existing ICT risk management framework against the regulatory requirements outlined in the Digital Operational Resilience Act (DORA). This process helps organizations pinpoint areas where their current practices fall short, enabling them to take corrective action before regulatory enforcement begins.

Why It’s Critical for DORA Compliance

Conducting a gap analysis is essential for several reasons:

  • Identifies areas of non-compliance and operational weaknesses – Ensures that all ICT risk management controls meet DORA’s standards.
  • Enables proactive risk mitigation and resource allocation – Helps prioritize remediation efforts and allocate resources effectively.
  • Supports regulatory reporting and audit readiness – Strengthens documentation practices and ensures organizations can demonstrate compliance when audited.

Key Focus Areas

A DORA gap analysis should assess multiple critical domains, including:

  • ICT Risk Management Frameworks – Evaluating governance structures, policies, and risk assessment processes.
  • Incident Response and Reporting Mechanisms – Ensuring timely detection, escalation, and reporting of ICT-related incidents.
  • Third-Party Risk Management – Reviewing vendor oversight, contractual safeguards, and exit strategies for critical ICT service providers.
  • Operational Resilience Testing – Validating the effectiveness of resilience testing, such as Threat-Led Penetration Testing (TLPT) and scenario-based assessments.

By systematically reviewing these areas, organizations can identify compliance gaps, mitigate potential risks, and establish a strong foundation for DORA compliance.

Key DORA Compliance Domains to Analyze

A thorough DORA gap analysis must assess several critical domains to ensure financial institutions and ICT service providers can effectively manage risks and comply with regulatory mandates.

1. ICT Risk Management Framework (ICT-RMF)

Organizations must evaluate governance structures, policies, and controls to ensure alignment with DORA. This includes risk identification, mitigation strategies, and executive accountability.

2. ICT Incident Management and Reporting

Effective incident detection, response, and reporting mechanisms are essential for compliance. Organizations should assess escalation procedures, response timelines, and adherence to regulatory reporting requirements for severe ICT incidents.

3. Third-Party Risk Management

DORA mandates strong oversight of ICT service providers. Organizations must review vendor contracts, conduct continuous risk monitoring, and establish contingency plans to mitigate third-party dependencies.

4. Operational Resilience Testing

Resilience testing ensures organizations can withstand cyber threats and operational disruptions. Key assessments include Threat-Led Penetration Testing (TLPT) and scenario-based resilience testing.

5. Business Continuity and Disaster Recovery

Organizations must confirm that business continuity (BCP) and disaster recovery (DRP) plans meet DORA’s expectations. Testing failover mechanisms, backup strategies, and recovery time objectives (RTOs) is crucial.

6. Regulatory Reporting and Documentation (Register of Information)

Maintaining accurate documentation is critical for demonstrating compliance. Organizations should standardize reporting workflows, track ICT risks, and ensure audit-ready records.

By analyzing these key domains, organizations can pinpoint compliance gaps and implement strategic improvements to strengthen operational resilience and meet DORA’s stringent requirements.

Step-by-Step Guide to Conducting a DORA Gap Analysis

Conducting a DORA gap analysis involves a structured approach to assessing compliance risks and identifying areas for improvement. By following these steps, organizations can systematically uncover gaps, prioritize remediation efforts, and enhance their operational resilience. This process includes defining the scope, gathering relevant data, mapping controls to DORA requirements, identifying compliance gaps, conducting risk impact analysis, and developing an action plan. Continuous monitoring and tracking key performance indicators (KPIs) ensure that organizations stay on track toward full compliance. The following step-by-step guide outlines how to conduct a comprehensive gap analysis to prepare for DORA enforcement.

Step 1: Define the Scope and Objectives

The first step in a DORA gap analysis is to clearly define the scope and objectives. Organizations should determine which business units, processes, systems, and third-party relationships fall under DORA’s regulatory coverage. This ensures that the assessment remains focused and aligned with compliance requirements.

Key objectives may include:

  • Conducting a full compliance assessment against DORA mandates.
  • Identifying high-risk areas requiring immediate remediation.
  • Establishing priorities based on regulatory impact and business-critical functions.

Additionally, organizations should align their gap analysis scope with their broader ICT risk management framework, ensuring that all critical functions related to operational resilience, incident response, and third-party risk are evaluated. Clearly defining these parameters will streamline the analysis and ensure meaningful outcomes.

Step 2: Gather Relevant Documentation and Data

A comprehensive gap analysis requires gathering all relevant documentation related to ICT risk management, incident response, and third-party oversight. This includes:

  • Internal policies and procedures (e.g., cybersecurity frameworks, risk management protocols).
  • Incident reports to assess past ICT disruptions and response effectiveness.
  • Vendor contracts and third-party agreements to evaluate supplier risk.
  • Existing regulatory assessments to identify past compliance issues.

Organizations should also conduct interviews with key stakeholders, including risk managers, IT teams, and compliance officers, to gain a holistic view of existing controls and potential vulnerabilities. This data collection phase ensures that all aspects of DORA compliance are assessed with a factual, evidence-based approach.

Step 3: Map Existing Controls to DORA Requirements

With all relevant data collected, the next step is to map existing security and governance controls against DORA’s requirements. Organizations should:

  • Compare internal policies, procedures, and security frameworks to DORA’s ICT risk management, incident reporting, and resilience testing mandates.
  • Assess whether existing monitoring, detection, and reporting mechanisms align with regulatory expectations.
  • Identify missing or weak controls related to third-party risk management and ICT service provider oversight.

DORA requires a Register of Information report to be provided to the “Supervisory Authority” for categorizing third-party Information and Communication Technology (3P ICT) services supporting “critical and important functions” (CIFA). 

A joint report from the European Supervisory Authorities (EBA, EIOPA, and ESMA) revealed that during a dry run, only 6% of submissions using Excel spreadsheets were accepted. As a result, they advise organizations to avoid spreadsheets and use a dedicated platform instead.

This mapping process provides a clear compliance baseline, helping organizations pinpoint where they already meet requirements and where corrective action is needed. Using a structured framework, such as DORA’s regulatory guidelines, ensures that gaps are identified efficiently and comprehensively.

Step 4: Identify and Categorize Compliance Gaps

After mapping controls, organizations must categorize compliance gaps based on severity and impact. The classification typically includes:

  • Critical Gaps – Immediate risks that could lead to regulatory penalties or operational failures.
  • High-Risk Gaps – Significant weaknesses requiring urgent remediation to ensure resilience.
  • Medium-Risk Gaps – Areas that may not pose immediate threats but need addressing for full compliance.
  • Low-Risk Gaps – Minor inefficiencies or process misalignments that can be improved over time.

Prioritizing compliance gaps helps organizations allocate resources effectively and focus remediation efforts where they matter most. Categorization also supports structured risk management and audit readiness by providing a clear compliance roadmap.

Step 5: Conduct Risk Impact Analysis

Once gaps are identified, a risk impact analysis assesses their potential consequences on operations, financial stability, and regulatory compliance. Organizations should:

  • Evaluate operational impact – How does each gap affect system resilience, business continuity, and incident response?
  • Assess financial and reputational risks – Could a gap result in fines, regulatory actions, or reputational damage?
  • Prioritize gaps based on exposure – Addressing high-impact gaps first minimizes potential disruptions.

Using a risk-based approach, organizations can focus on mitigating the most pressing compliance risks while ensuring that low-impact gaps are addressed efficiently over time.

Step 6: Develop an Action Plan

An effective action plan outlines how to remediate compliance gaps. Key steps include:

  • Defining corrective actions – Specify the exact measures required to close each compliance gap.
  • Assigning ownership – Allocate responsibility to relevant teams or departments.
  • Setting timelines – Establish clear deadlines and milestones for addressing each gap.

The plan should integrate with existing risk management and governance frameworks to ensure a seamless remediation process. Additionally, organizations should consider implementing automation tools to streamline compliance tracking and reporting.

Step 7: Implement and Monitor Progress

The final step involves executing the action plan while continuously monitoring progress. Organizations should:

  • Track remediation efforts using Key Risk Indicators (KRIs) and Key Performance Indicators (KPIs).
  • Conduct regular audits and reviews to validate improvements.
  • Maintain compliance dashboards to provide visibility into ongoing efforts.

By embedding continuous monitoring into their risk management framework, organizations can ensure sustained DORA compliance and remain prepared for evolving regulatory expectations.

Tools and Frameworks to Support DORA Gap Analysis

Conducting a DORA gap analysis requires leveraging the right tools and frameworks to streamline assessments and ensure regulatory alignment. The following solutions help organizations effectively evaluate their compliance posture:

  • Regulatory Mapping Tools – These platforms automate the process of aligning internal controls with DORA’s requirements, identifying gaps, and tracking remediation efforts. They provide a structured framework for compliance reporting and audit preparation.
  • Risk Management Frameworks – Established methodologies like NIST RMF, ISO/IEC 27005, and COBIT help organizations structure their risk assessments. These frameworks offer guidelines for assessing ICT risks, managing security controls, and ensuring operational resilience.
  • Third-Party Risk Management (TPRM) Platforms – Since DORA places significant emphasis on third-party risk and requires organizations to provide a Register of Information. This register is part of the broader ICT third-party risk management framework and helps financial entities track and assess the risks associated with their third-party ICT service providers. Solutions like Panorays enable businesses to assess and monitor supplier risks, ensuring that critical ICT service providers meet regulatory expectations.

By integrating these tools into their DORA compliance strategy, organizations can gain real-time insights, automate compliance tracking, and proactively mitigate risks. Leveraging regulatory technology (RegTech) solutions also enhances efficiency, reducing manual effort while improving accuracy in risk assessments.

Common Challenges and How to Overcome Them

Implementing a DORA gap analysis comes with several challenges that can hinder compliance efforts. Understanding these obstacles and addressing them proactively is key to a smooth assessment process.

  • Complexity in Interpreting DORA’s Technical Standards – DORA’s requirements are highly detailed and can be difficult to interpret, especially for organizations unfamiliar with regulatory frameworks. Solution: Use regulatory mapping tools and consult legal or compliance experts to ensure proper alignment with DORA mandates.
  • Lack of Cross-Departmental Coordination – Compliance is not solely an IT or risk management responsibility—it requires input from multiple departments, including finance, legal, and operations. Solution: Establish a cross-functional compliance team to facilitate collaboration, ensure clear communication, and assign accountability for each aspect of the gap analysis.
  • Inadequate Documentation of ICT Processes – Without well-documented policies and procedures, it becomes challenging to assess compliance gaps. Solution: Conduct a thorough review of existing ICT policies, risk assessments, and incident response procedures. Standardize documentation practices and implement a centralized system for maintaining compliance records.

By addressing these challenges early, organizations can improve the efficiency and accuracy of their gap analysis, ensuring a stronger foundation for DORA compliance.

Best Practices for an Effective DORA Gap Analysis

A well-structured DORA gap analysis ensures compliance readiness and strengthens operational resilience. Follow these best practices to maximize its effectiveness:

  • Engage Senior Leadership – Gaining executive buy-in is essential for securing the resources and support needed to address compliance gaps. Leadership involvement also ensures alignment with broader risk management strategies.
  • Prioritize High-Risk Areas – Focus on critical systems, third-party dependencies, and regulatory reporting processes. Addressing the most significant risks first minimizes potential disruptions and regulatory penalties.
  • Document Findings Thoroughly – Maintain detailed records of identified gaps, risk assessments, and remediation plans. Proper documentation is crucial for audits and regulatory reviews.
  • Integrate Findings into Ongoing Risk Management – A gap analysis should not be a one-time effort. Regularly reassess compliance status, update risk management frameworks, and adapt to evolving DORA requirements.

By embedding these practices into compliance workflows, organizations can proactively mitigate risks and sustain long-term regulatory adherence.

DORA Gap Analysis Solutions

A comprehensive gap analysis is a critical step for any organization aiming to comply with the Digital Operations Resilience Act (DORA). By carefully examining existing internal controls, policies, and practices against DORA’s requirements, companies can identify areas of non-compliance or vulnerability. This process helps reveal where processes need improvement and ensures that an action plan is in place to address compliance risks before they become regulatory issues.

Through an effective gap analysis, organizations can prioritize high-risk areas and create tailored remediation strategies. This enables businesses to align their operations with DORA’s mandates efficiently and reduce the likelihood of penalties or operational disruptions. Additionally, it provides valuable insights into areas of strength that can be leveraged to further enhance resilience.

Organizations must start assessing their compliance posture now to avoid regulatory penalties and operational disruptions. Begin mapping internal controls to DORA requirements and prioritize high-impact remediation to ensure a seamless path to compliance.

Want to learn how to effortlessly automate your DORA Register of Information? Start your DORA compliance journey with Panorays today for a faster, smoother process! Get a Demo today. 

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