In 2025, UK businesses face increasing pressure to meet evolving compliance standards in a world where digital operations, cyber threats, and data privacy intersect more than ever. Two major regulations are commanding attention: the Digital Operational Resilience Act (DORA) and the General Data Protection Regulation (GDPR).
While GDPR has been around since 2018, DORA is a new entrant, specifically targeting the resilience of financial entities and their ICT infrastructure. But what makes them different? Do they overlap? And what should UK organisations prioritise now?
This guide explores the key distinctions between DORA and GDPR, their areas of overlap, and what steps UK businesses must take in 2025 to remain compliant and secure.
What Is DORA?
DORA (Digital Operational Resilience Act) is a regulation by the European Union, coming into full effect in January 2025, aimed at strengthening the operational resilience of the financial sector. It ensures that financial institutions can withstand, respond to, and recover from ICT-related disruptions such as cyberattacks, system failures, or third-party breaches.
Key Objectives of DORA:
- Improve incident reporting and response mechanisms.
- Regulate the cybersecurity of third-party ICT service providers.
- Require rigorous operational resilience testing.
- Enforce ICT risk management frameworks.
Although it is EU legislation, UK firms with operations, clients, or partnerships in the EU must comply. Additionally, many UK regulators are aligning their frameworks with DORA’s principles.
What Is GDPR?
GDPR (General Data Protection Regulation) is the gold standard for data privacy and came into effect in May 2018. It focuses on protecting personal data of individuals and gives EU and UK citizens control over how their data is collected, stored, and used.
Post-Brexit, the UK adopted its own version known as the UK GDPR, which largely mirrors the original EU regulation.
Core Principles of GDPR:
- Lawfulness, fairness, and transparency in data processing.
- Clear consent mechanisms.
- The right to access, erase, or correct data.
- Mandatory data breach notifications within 72 hours.
- Strong requirements for data security and encryption.
DORA vs. GDPR: Key Differences
| Feature | DORA | GDPR |
| Focus Area | Digital operational resilience of financial entities | Data protection and privacy |
| Applies To | Banks, investment firms, insurance companies, and their third-party ICT providers |
Any organisation processing personal data of EU/UK residents |
| Core Concern | Preventing and recovering from ICT-related disruptions | Ensuring individuals’ control over personal data |
| Regulatory Body | EU Financial Supervisory Authorities (e.g., EBA, ESMA) | ICO (UK), CNIL (France), etc. |
| Compliance Deadline | January 17, 2025 | Already in effect since May 2018 |
| Incident Reporting | Mandatory reporting of all ICT-related incidents | Mandatory reporting of personal data breaches |
| Third-Party Oversight | Strict regulation of ICT service providers | Processors must offer data protection guarantees |
Where Do DORA and GDPR Overlap?
While their core objectives differ, there are areas where DORA and GDPR intersect — and this is where compliance becomes complex for businesses:
1. Incident Response
- Both regulations require timely incident reporting, though DORA focuses on ICT disruptions and GDPR on data breaches.
- A cybersecurity incident could trigger obligations under both.
2. Third-Party Risk
- DORA demands rigorous oversight of third-party ICT vendors (cloud providers, software suppliers).
- GDPR mandates that any third party processing personal data must comply with data protection standards.
3. Resilience Through Security
- While DORA centres on system resilience, both stress the importance of strong cybersecurity controls like encryption, access management, and risk assessments.
4. Documentation and Audit Trails
- Documentation is key under both frameworks — whether it’s ICT risk logs (DORA) or data processing records (GDPR).
What This Means for UK Businesses in 2025
With both DORA and GDPR playing crucial roles, UK businesses — especially those in the financial sector — must take a holistic view of compliance.
If You’re in the Financial Sector:
You’re likely already familiar with GDPR, but DORA will add a new layer of obligations focused on operational technology and digital resilience. Even if your primary business is UK-based, operating in EU markets (or working with EU clients) means DORA applies to you.
You’ll need:
- ICT risk management frameworks aligned with DORA.
- Contracts with ICT providers that meet DORA’s oversight standards.
- Regular resilience testing and scenario planning.
If You’re Not in Financial Services:
You may not fall under DORA directly, but you should still:
- Monitor how regulators adopt similar resilience requirements in the UK.
- Strengthen your supply chain security and incident response readiness.
- Stay up to date with ICO guidance on UK GDPR compliance.
2025 Compliance Checklist
Here’s a simplified checklist to help you prepare for DORA and ensure continued GDPR alignment:
- Conduct an ICT risk assessment and identify critical systems.
- Review and update your incident response plan for both system failures and data breaches.
- Evaluate and manage third-party risks, especially ICT vendors and cloud providers.
- Perform penetration testing and resilience exercises regularly.
- Ensure data encryption, access controls, and audit trails are robust.
- Train staff on both cybersecurity hygiene and data privacy obligations.
- Review cross-border operations for potential DORA applicability.
- Document everything — logs, policies, and decisions matter for audits.
Looking Ahead: Preparing for Regulatory Convergence
While DORA is technically an EU regulation, it is expected to influence UK regulatory frameworks, especially as financial regulators globally aim for consistent standards. UK regulators like the FCA are already embedding operational resilience principles into their guidance.
Likewise, GDPR is not going away — in fact, its enforcement is becoming more stringent in 2025, with higher fines and more proactive investigations.
Businesses that integrate both cybersecurity and compliance into their operations — rather than treat them as checkboxes — will have the edge.
Final Thoughts
In the age of constant digital disruption, compliance isn’t just a legal requirement — it’s a business advantage. Understanding the difference between DORA and GDPR — and where they overlap — empowers your organisation to build not just resilience, but also trust.
Whether you’re safeguarding customer data or ensuring your systems bounce back from cyberattacks, 2025 is the year to go beyond reactive compliance. Make it part of your strategic foundation.
