When the Digital Operational Resilience Act (DORA) became law, many financial institutions – especially smaller insurers, cooperative banks, and pension funds – worried it would bury them under an avalanche of new rules. Unlike the big players, these organizations don’t have entire compliance departments at their disposal.
One such example comes from a German mutual insurance association (VVaG – Versicherungsverein auf Gegenseitigkeit). In a VVaG, the policyholders are the members and owners. This structure is very common in Germany, especially among smaller and mid-sized insurers.
• Overlap between DORA and national regulations.
• Regulators and authorities issued contradictory guidance — with BaFin and the ESAs interpreting rules differently, and DORA ITS, FAQs, and taxonomies often clashing with one another.
• Multiple layers of policies, IT documentation, audits, and reporting needed.
• DORA expects a detailed Register of Information (ROI) for every IT service provider and contract.
• No standard tools provided by ESAs or BaFin; BaFin Excel templates arrived late.
• The first dry run showed it could take 5–7 table entries per single contract – a nightmare for smaller institutions.
• Overlapping requirements with standards already implemented (e.g. ISO27001)
• Supply chain transparency was limited; big tech providers (AWS, Microsoft) refused to provide full supply chain data.
• Defining “critical functions” is left to the institution’s discretion, creating inconsistencies. Smaller insurers didn’t know how deep they had to go to stay compliant.
• Institutions must classify ICT incidents as “major” and report them quickly.
• Criteria for “major ICT incidents” include customer impact, downtime, reputational damage, geography, and financial thresholds.
• Criteria such as customer impact, downtime, and financial loss left smaller firms unsure: “What really counts as reportable?”
• Repeated minor incidents, when aggregated, also qualify as major.
• Dry-run reporting through BaFin’s MVP portal was slow and error-prone.
Challenge: Smaller institutions feared they had to build an entirely new compliance framework in parallel to existing procedures.
DORApp’s solution:
Helped VVaG reuse existing standards (ISO 27001, COBIT, internal IT governance) and only address the true “gaps” DORA added (like documenting threat identification and repeated minor incidents).
Impact: Avoided unnecessary work and kept compliance costs under control.
Challenge: The ROI required by DORA is complex and often managed manually in Excel, leading to errors.
DORApp’s solution:
• Imported existing contract data.
• Added missing information automatically from public sources (e.g. GLEIF).
• Checked everything against ESAs rules.
• Generated reports directly in the XBRL format supervisors require.
Impact: Turned a messy, manual task into a streamlined, automated workflow that supervisors would accept.
Challenge: How to align and enhance existing governance and risk management procedures with DORA requirements.
DORApp’s solution:
• Provided a single digital operational resilience management system (DOR-MS). The DOR-MS consists of policies, committees, processes, etc., that are compliant with widely adopted standards such as GDPR, ISO27001, COBIT5 and NIST CSF.
• DORA requirements are only mapped to the appropriate parts of the DOR-MS. This way a single system can serve ISO27001, NIST CSF, COBIT5 and DORA requirements without duplication and redundancy, Additional requirements such as the AI Act can be added easily.
Impact: Brought risk management fully in line with DORA without having to rebuild the whole system (DORApp covered not just additional DORA requirements but as well ISO 27001 and NIST CSF 2).
Challenge: Supplier contracts were hard to enter into the complex ROI data structures and hard to assess for DORA compliance. Providers didn’t reveal deep supply chains on time or not at all (i.e. big tech providers).
DORApp’s solution:
• Introduced a simplified and improved data model tailored to the needs of the financial institutions. The data is automatically converted to the data model of the regulator for reporting purposes.
• Added DORAssistant (AI Agent) to review existing and draft contracts for compliance issues.
• Enabled pragmatic supply chain management, focusing only on tier 2 suppliers for the first year of reporting.
Impact: Simplified oversight of critical suppliers and contracts, saving time and reducing legal uncertainty.
Challenge: Uncertainty about what really counts as a “major incident.”
DORApp’s solution:
Helped define simple, concrete thresholds:
• Outage longer than 24 hours.
• More than 100,000 customers affected.
• Repeated incidents with the same root cause.
Impact: Gave management a clear checklist, making incident reporting practical and reliable.
Outcomes:
DORApp allows your company to focus on the essentials, automate where it matters, and use proportionality to your advantage.
“I’m still thrilled. We were looking for a simple solution for the DORA Register of Information reporting. I initially doubted how quickly DORApp could be tailored to our needs and deliver such a polished and professional result. Instead of creating a maintenance burden, DORApp is precisely what we need — a streamlined reporting platform.”
Experience end-to-end DORA compliance in one platform: from reporting to risk management, incident handling to outsourcing registers — DORApp ensures your institution stays resilient, secure, and always regulator-ready.
Cover every DORA requirement: ROI, risk management, incident reporting, outsourcing, and audit trails — all in one place.
Guaranteed compliance, validated reporting, complete oversight — DORApp gives you peace of mind at every step.
Every action is logged immutably, risks are monitored, and dashboards give management and auditors instant visibility — so you can prove compliance at any moment.
Get in touch with our industry specialists today to see how DORApp can simplify DORA compliance for you.
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