Tag: DORA: How to Organize Governance

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DORA: How to Organize Governance, Roles, and Operational Responsibilities

Practical Guide for Companies and Consultants in Managing Digital Resilience

The European Regulation DORA (Digital Operational Resilience Act, EU 2022/2554) clearly states: digital resilience is not just an IT issue. It is an organizational, strategic, and cross-functional duty.

To ensure the continuity of essential services in the event of adverse ICT events, it is necessary to establish solid governance, clearly define roles and responsibilities, and make digital resilience an integral part of the company’s operating model.

In this article, we explore how to structure DORA governance, what to do operationally, and how a consultant can support the process.

Governance: Who Leads Digital Resilience?

DORA establishes that the ultimate responsibility lies with the management body (Board of Directors).
This is not a technical compliance to be entirely delegated to the IT department, but a strategic asset under the direct control of the top management.

The Role of Top Management:

✅ Approve the ICT strategy and risk management plans
✅ Allocate resources, roles, and responsibilities
✅ Monitor incidents and testing activities
✅ Ensure that digital resilience is integrated into the company culture

Decisions cannot be merely formal: the Board must receive periodic reports, updates, and dashboards.
An expert consultant can help create clear and decision-oriented reporting models.

Key Roles to Define (Internally or Outsourced)

Effective DORA governance requires the explicit and documented assignment of roles. Here are the main ones:

ICT Risk Manager

Responsible for assessing, classifying, and monitoring risks related to information systems.

Information Security Officer (CISO / ISO)

Coordinates the implementation of security measures, participates in audits, and promotes a security culture.

Business Continuity Manager

Oversees business continuity and disaster recovery plans, including resilience testing.

Incident Reporting Officer

Manages the detection, recording, classification, and internal/external communication of ICT incidents.

Third-Party ICT Provider Manager

Evaluates critical suppliers, manages due diligence, coordinates contractual controls, and audits.

⚙️ Operational Responsibilities: What to Do and Who Does It

DORA requires companies not only to write procedures but also to demonstrate that roles are effectively operational.

Here are the activities that must be assigned and overseen:

Activity Involved Role Frequency
Mapping critical ICT assets ICT Risk Manager, IT Annually or upon changes
Assessing ICT risks ICT Risk Manager Annually or after significant events
Drafting and updating ICT policies ISO/CISO Annually
Simulating business continuity tests Business Continuity Manager Annually
Reporting significant ICT incidents Incident Reporting Officer Within 24h (internal), as per thresholds for external
Evaluating critical ICT suppliers Third-Party ICT Manager + Legal Pre-contract and periodically

How a DORA Consultant Can Act

An expert DORA consultant should:

  • Support in building governance (organizational chart, delegations, decision-making flows)

  • Draft or review policies and job descriptions related to DORA roles

  • Train responsible parties and the Board on minimum competencies required by the Regulation

  • Help create dashboards, reports, checklists for continuous monitoring

A common mistake? Limiting to updating the organizational chart. The real difference lies in making governance operational, active, and verifiable.

Conclusion

The DORA Regulation requires organizations to shift from an isolated ICT model to digital resilience integrated into corporate governance.

To achieve this, it is necessary to:

✅ Clearly define roles and responsibilities
✅ Involve the management body
✅ Assign operational tasks with traceable evidence
✅ Continuously monitor, test, and improve