Making Financial Services Operationally Resilient in the DORA Era

Financial institutions are more digitally dependent than ever. Core banking platforms, payment systems, trading applications, and customer-facing services now run across highly complex, interconnected technology environments. By design they often span on-premises infrastructure, multiple clouds, and third-party service providers.

However, as recent outages and cyber incidents have shown, even brief technology disruptions can trigger widespread customer harm and systemic risk. Recognizing this growing vulnerability, the European Union introduced the Digital Operational Resilience Act (DORA). This landmark regulation was designed to strengthen the financial sector’s ability to withstand, respond to, and recover from ICT-related disruptions.

While DORA is often discussed through a cybersecurity or compliance lens, its true focus is operational resilience. Ensuring that critical financial services continue to function and data integrity remains intact despite systems failures or attacks.

A closer look at DORA and operational resilience

At its core, DORA establishes a uniform operational resilience framework across the EU financial system. It applies to more than 22,000 financial entities and ICT service providers, including banks, insurers, investment firms, payment providers, crypto-asset firms, and critical technology suppliers. DORA’s objectives go beyond preventing incidents. They are designed to ensure that firms can operate through disruption.

Key goals of DORA include:

• Establishing a comprehensive ICT risk management framework
• Requiring continuous identification, management, and reduction of operational risk
• Mandating regular resilience testing to validate recovery capabilities
• Ensuring that major ICT incidents are detected, managed, and learned from
• Reducing systemic dependency on critical third-party and cloud providers

In short, DORA shifts resilience from a theoretical exercise to an operational discipline.

Why operational resilience and not just system uptime matters

Historically, resilience strategies focused on system availability: redundancy, failover, and disaster recovery plans designed to keep infrastructure online. Yet many recent financial outages occurred despite high infrastructure availability.

DORA addresses this gap by emphasizing operational resilience — the ability to maintain or rapidly restore critical business services with trusted data and predictable outcomes.

Operational resilience asks different questions:

• Can payment processing continue during infrastructure disruption?
• Can trading systems recover without data integrity loss?
• Can institutions exit or substitute a critical cloud provider if required?

Answering these questions requires more than security controls or backups. It requires application-aware continuity, real-time data protection, and provable recovery.

DORA and the challenge of digital dependency

A central concern driving DORA is the financial sector’s increasing reliance on:

• Complex application stacks
• Shared cloud and infrastructure providers
• Interconnected data and services

DORA explicitly requires firms to manage third-party concentration risk, ensure exit strategies are executable, and demonstrate that operational dependencies are controlled — not merely documented.

This means resilience can no longer be siloed by infrastructure, cloud provider, or individual technology teams. It must be consistent, continuous, and independent of underlying platforms.

Achieving operational resilience under DORA

Meeting DORA’s operational resilience expectations requires a shift in how firms design and operate their technology environments. An effective operational resilience strategy should enable institutions to:

Maintain application continuity under disruption

Critical services must continue operating, or recover predictably, even when components fail. This requires application-aware monitoring and automated recovery, not just infrastructure redundancy.

Preserve data integrity and recover trusted state

Operational resilience depends on data. Recovery is only successful if applications restart with consistent, trusted data, not just restored systems.

Continuously test resilience, not assume it

DORA mandates regular testing to validate that recovery mechanisms work under real conditions. This includes testing failover, recovery orchestration, and dependency behavior without disrupting live operations.

Reduce third-party and cloud dependency risk

Exit strategies must be technically executable. Firms must be able to move or recover workloads and data across environments without rewriting applications or relying on provider-specific tooling.

The path forward

DORA marks a decisive shift in how resilience is regulated across Europe’s financial system. It reflects a broader recognition that capital buffers and security controls alone are not sufficient in a digitally dependent economy.

Operational resilience grounded in real-time visibility, deterministic recovery, and continuous validation is now a regulatory expectation.

As financial institutions prepare for DORA enforcement, the focus should not be on compliance checklists alone, but on building resilient operations that can withstand disruption and protect customers, markets, and the broader financial ecosystem.

Resilience is no longer defined by how systems fail but by how effectively institutions understand the breakdown and continue to operate when they do.