Many CFOs know that DORA compliance is essential, but they often underestimate what it really involves. Building digital operational resilience requires more than technical upgrades; it demands leadership, collaboration, and strong governance. Understanding where many CFOs go wrong is the first step to getting compliance right.
Summary: Building digital operational resilience under DORA
- Many CFOs still treat DORA as an IT project, missing its broader impact on governance, risk, and strategy.
- Solid documentation, clear governance, and good vendor risk management are essential for compliance.
- True operational resilience comes from planning, training, and teamwork, not just technology.
- Starting early helps close resource gaps, make better investments, and build stakeholder trust.
- DORA is more than a regulation; it’s a leadership opportunity for CFOs.
1. Treating DORA as an IT issue instead of a company-wide responsibility
A common mistake is assuming DORA is only an IT concern. While the regulation focuses on digital resilience, it also covers governance, incident response, vendor management, and decision-making.
CFOs play a key role in making sure their company can recover quickly from ICT disruptions. Treating DORA as purely technical leads to weak ownership and gaps in compliance. Instead, CFOs should drive a coordinated effort that involves finance, risk, operations, and compliance teams.
2. Governance and documentation gaps in DORA Compliance
DORA puts a strong emphasis on accountability and traceability. Yet many organisations don’t have clear frameworks for documenting controls, testing systems, or reporting incidents. Without structured governance, audits become stressful and error-prone.
To fix this, build a consistent DORA framework with clear roles, documented procedures, and regular updates. Using automation for control documentation and audit trails can cut down on manual work and mistakes.
3. Overlooking third-party and ICT vendor risk management under DORA
Outsourcing doesn’t mean outsourcing responsibility. Many CFOs overlook how dependent their business is on external service providers, cloud platforms, or software vendors.
DORA requires continuous monitoring of third-party risk, from identifying all providers to checking their resilience and including the right clauses in contracts. Integrating these checks into procurement and budgeting helps ensure compliance and financial stability.
4. Prioritising technology upgrades over true operational resilience
Buying new cybersecurity tools isn’t enough. DORA goes further – it’s about risk assessments, incident simulations, crisis communication, and business continuity.
CFOs who focus only on systems often miss the bigger picture of organisational readiness and culture. Resilience should be treated as a strategic goal, with investment in training, governance, and crisis exercises, not just technology.
5. Waiting too long to implement DORA compliance and resilience measures
With DORA deadlines approaching, some CFOs are still waiting to act. Waiting too long makes compliance more difficult and leaves little room to address issues properly.
Starting early helps identify resource gaps, plan smarter investments, and avoid compliance surprises. Acting ahead of time also builds confidence among stakeholders and regulators.
Conclusion: DORA compliance is a CFO-led leadership opportunity
For CFOs, DORA compliance isn’t about ticking boxes; it’s about building a stronger, more resilient organisation. By leading governance efforts, encouraging collaboration, and integrating resilience into the company’s strategy, CFOs can transform compliance obligations into sustainable business advantages.
FAQ: Understanding DORA and the CFO’s role
Below are answers to some of the questions we’re often asked by customers about DORA compliance and digital operational resilience.
Is DORA compliance mandatory for all financial institutions?
DORA compliance is mandatory for most financial institutions operating within the European Union, including banks, insurers, investment firms, and payment providers. The regulation aims to ensure that these organisations can effectively withstand and recover from digital disruptions.
For more detailed information on which entities are covered and any exemptions, visit the official EU website.
What role does the CFO play in digital operational resilience?
The CFO ensures DORA is built into business strategy and budgets. They allocate resources, align finance with risk management, and promote governance across teams, making resilience an ongoing leadership priority.
What are the long-term benefits of strong DORA compliance?
Beyond avoiding penalties, strong compliance improves risk management, continuity, and stakeholder trust. Organisations that take resilience seriously gain a competitive edge and reduce costly downtime.
