DORA places different demands on financial entities and their ICT service providers.
Are you a financial entity or an ICT service provider?

What is a financial entity according to DORA?
DORA applies across the entire financial sector. According to Art. 2 (1) DORA, the following financial entities are covered by the scope of application:

  • CRR credit institutions,
  • payment institutions,
  • account information service providers,
  • e-money institutions,
  • investment firms,
  • providers of crypto services authorized under the Regulation of the European Parliament and of the Council on Markets in Crypto Assets (MiCAR) and issuers of asset-referenced tokens,
  • central securities depositories,
  • central counterparties,
  • trading venues,
  • trade repositories,
  • managers of alternative investment funds,
  • management companies,
  • data reporting service providers,
  • insurance and reinsurance undertakings,
  • insurance intermediaries, reinsurance intermediaries and insurance intermediaries in ancillary activity,
  • institutions for occupational retirement provision,
  • credit rating agencies,
  • administrators of critical benchmarks,
  • crowdfunding service providers,
  • securitisation repositories

What is an ICT service provider?
“ICT services” stands for internet and communication services. According to the definition in Art. 3 No. 21 DORA, ICT services are:

digital and data services provided through ICT systems to one or more internal or external users on an ongoing basis, including hardware as a service and hardware services which includes the provision of technical support via software or firmware updates by the hardware provider, excluding traditional analogue telephone services.

This includes:

  • ICT project management
  • ICT development (business analysis, software design and development, testing)
  • ICT help desk and first level support in the event of ICT incidents
  • ICT security management services (protection, detection, response and recovery, including security incident handling and forensics)
  • Provision of data (digital data service)
  • Services to support data analysis (digital data service)
  • Provision of ICT infrastructure, facilities and hosting services (this includes the provision of utilities (energy, heat management, etc.), telecommunications access and physical security, excluding cloud services)
  • Computation (Provision of digital processing capabilities (including data computation). This excludes the computation services performed in the context of a cloud environment
  • Provision of a data storage platform (excluding cloud services)
  • Operating telecommunications systems and managing data flows (traditional analog telephone services are excluded under Article 3 (21) DORA, but virtual telephony is not)
  • Provision of network infrastructure
  • Provision of workstations, telephones, servers, data, storage devices, appliances, etc. as a service
  • Provision of software on premise / software licensing
  • Provision of services related to IT infrastructure (systems and hardware other than network), configuration, maintenance, installation, capacity management, business continuity management, etc., including managed service providers (MSP)
  • ICT advice / ICT consulting / ICT expertise services
  • ICT Risk Management such as verification of compliance with the ICT risk management requirements of Art. 6 para. 10 DORA
  • Cloud: Infrastructure-as-a-service, Platform-as-a-service and Software-as-a-service