Preparing for DORA Compliance: A Checklist for UK Financial Institutions

As the financial sector faces increasing regulatory scrutiny, the Digital Operational Resilience Act (DORA) is set to reshape how UK-based financial institutions approach digital risk. While DORA is an EU regulation, its impact extends beyond borders, particularly for institutions with cross-border operations or those interacting with the EU market.

For UK financial institutions, preparing for DORA compliance isn’t just about ticking regulatory boxes—it’s about futureproofing digital resilience strategies and maintaining trust in an era of sophisticated cyber threats and service disruptions.

In this post, we’ll guide you through a practical DORA compliance checklist, helping you align your operations with the regulation’s key requirements and expectations.

Why DORA Matters to UK Financial Institutions

Although the UK has its own regulatory landscape post-Brexit, many UK firms still operate within the EU or serve clients there. As such, DORA’s standards often apply directly or indirectly. Failing to comply could not only lead to fines but also reputational damage and loss of market access.

Moreover, DORA sets a gold standard for ICT risk management—embracing its framework enables UK firms to strengthen operational resilience and gain a competitive edge.

The Core Pillars of DORA Compliance

DORA introduces five key pillars that every financial institution must address:

• ICT Risk Management Framework
• ICT-related Incident Reporting
• Digital Operational Resilience Testing
• ICT Third-Party Risk Management
• Information Sharing Arrangements

For a deeper understanding of each, read the full guide: Five Pillars of the DORA Act – A Comprehensive Guide.

Let’s break these down into a practical checklist to get your organisation compliance-ready.

DORA Compliance Checklist for UK Financial Institutions

1. Establish a Robust ICT Risk Management Framework

Conduct a comprehensive ICT risk assessment to identify vulnerabilities across hardware, software, networks, and data storage systems.

Define clear roles and responsibilities for ICT risk across all levels of your organisation.

Document policies and procedures covering prevention, detection, response, and recovery.

Integrate ICT risks into your enterprise risk management strategy to ensure a top-down commitment.

🔍 Pro Tip: Regularly update your ICT risk documentation in line with changes in technology and threat landscape.

2. Set Up a Formal ICT Incident Reporting Process

Develop internal protocols for detecting, classifying, and escalating ICT-related incidents.

Implement a real-time monitoring system that can track unusual activity or performance issues.

Create external reporting workflows to notify competent authorities within DORA’s required timeframes (e.g., initial report within 24 hours).

💡 Remember: The quality and speed of your incident response will define your resilience reputation.

3. Conduct Digital Operational Resilience Testing

Perform annual penetration testing and vulnerability assessments across all critical systems.

Simulate cyberattacks and disaster recovery scenarios to test your real-world responsiveness.

Ensure involvement of senior management in reviewing test results and action plans.

🛠️ Tip: Use a mix of in-house and third-party testers to gain a holistic view of your resilience posture.

4. Strengthen Third-Party ICT Risk Management

Create an inventory of all ICT third-party providers, including cloud services and SaaS vendors.

Review contractual agreements to ensure service continuity and incident reporting obligations are clearly defined.

Implement a risk-based approach to assess and monitor third-party providers continuously.

🔗 DORA mandates that risk cannot be outsourced—ultimate responsibility stays with your firm.

5. Participate in Threat Intelligence and Information Sharing

Engage with sector-wide information sharing networks, such as FS-ISAC or national cyber resilience forums.

Implement policies to share relevant cyber threat information securely and lawfully.

Foster a culture of collaboration—working with others in the ecosystem enhances collective defence.

📘 Knowledge is power—especially when it comes to staying ahead of cyber threats.

How UK Firms Can Proactively Prepare for DORA

Beyond the checklist, UK institutions should take a strategic approach:

🔄 Align DORA with Existing Frameworks

Leverage existing compliance frameworks like ISO/IEC 27001, NIST, or UK’s PRA and FCA regulations to build a harmonised resilience plan.

👩‍💻 Invest in Technology and Skills

Ensure your ICT teams are trained on DORA’s expectations and equipped with modern tools for risk detection, reporting, and response.

📝 Run Internal Audits

Conduct a gap analysis between your current operational resilience strategy and DORA’s requirements. Use the findings to drive board-level discussions and strategic decisions.

🤝 Work with a Compliance Partner

Collaborating with an experienced IT consultancy or cybersecurity firm like Gradeon can accelerate your path to compliance and ensure your frameworks are both robust and tailored.

Final Thoughts: Turning Compliance into Competitive Advantage

Preparing for DORA compliance may seem like a regulatory burden—but when approached strategically, it becomes a catalyst for innovation, trust, and long-term resilience.

In an age where customers expect uninterrupted digital services and regulators demand transparency, DORA offers a blueprint for future-ready operations.

For UK financial institutions, now is the time to act. The earlier you begin, the stronger your operational defences—and your reputation—will be.