Position paper - First batch of draft regulatory technical standards under DORA

The European Supervisory Authorities (ESAs) have launched a public consultation on the first batch of policy products under the Digital Operational Resilience Act (DORA), including draft regulatory technical standards (RTS) and draft implementing technical standards (ITS), which are crucial to ensure a smooth implementation of DORA and digital operational resilience in the financial sector. The ESAs are making positive efforts to build a constructive dialogue with stakeholders on these new legislations, but certain concerns are yet to be addressed. Amongst others, the ESAs should aim to prevent extra-territorial implications (which are not included in the primary DORA regulation) and consider refinements of the approach to ICT risk management, the prescriptiveness in contractual arrangements, incident reporting, third party registers and the use of existing reporting frameworks.

Read our consultation response below.