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Position paper - DORA: Potential overlaps with other legislation and implementation challenges

24 Jan 2023
Digital Economy
Financial Services


American Chamber of Commerce to the EU (AmCham EU) is a strong supporter of the Digital Operational Resilience Act (DORA), as it brings clarity to the applicable cybersecurity rules for the regulated financial services sector and its Information and Communication Technology (ICT) service providers. In order for the industry to adopt a consistent set of high-quality standards and practices globally in this regard, the European Commission and European Supervisory Authorities (ESAs) should foster international cooperation and collaboration.

The following document highlights the overlaps between DORA and other EU legislation, outlines industry concerns stemming from these links and explains the potential challenges that might arise during DORA’s implementation. Concerns of our members are particularly related to the following two aspects:

1. The overlap and potential inconsistencies between DORA and other existing or proposed EU cybersecurity legislation.

2. The lack of legal certainty and clarity on definitions when it comes to DORA’s implementation.