DORA Regulations: ICT Incident Reporting

Insight into the European Banking Federation's influence on the Regulatory Technical Standards for ICT Incident Classification within the DORA Regulation. Highlights challenges in defining Critical Services and implementing Proportionality Principle.

DORA Regulations: ICT Incident Reporting
EU DORA and ICT Standards

Enhanced Review of DORA Regulations and ICT Incident Categorization: Insights and Perspectives from the EBF

European Banking Federation keywords DORA ICT Incident



Enhancing Digital Resilience in Finance: The Role of DORA and ICT Standards


The financial sector's resilience is becoming more and more important in today's dynamic digital world. The Digital Operational Resilience Act (DORA) is a proactive reaction to this growing demand that the European Union has introduced. With great care and attention to detail, this strong and progressive legal framework has been designed to greatly strengthen the Information and Communication Technology (ICT) infrastructure in the finance sector. The creation of the Regulatory Technical Standards (RTS) on ICT incident classification, which forms the cornerstone of DORA, is among the framework's most noteworthy innovations. This article offers a thorough overview of the RTS with a particular emphasis on the European Banking Federation's (EBF) crucial contribution to the creation of these important standards.




Strategic Significance of DORA in Contemporary Finance


1. Embracing a Proactive Stance in Addressing Digital Challenges:


  • Leadership in Digital Resilience: The European Union's (EU) leadership in digital resilience in the financial industry is demonstrated by DORA, which is an example of a visionary strategy. With this initiative, the European Union assumes a leading role in tackling and overseeing the digital threats that contemporary finance encounters.

  • Setting the Bar for International Financial Operations and Security Standards: By focusing on the resilience of ICT infrastructure, DORA is likely to set the bar for international financial operations and security standards, impacting practices outside of the EU.

2. Establishing a Comprehensive and Future-Ready Framework:


  • Wide Range of Operational Security: DORA's framework is all-inclusive, encompassing a number of digital operations' facets. This strategy makes sure that the financial industry is prepared to face both current and upcoming technological risks and improvements.

  • Constant Standards Evolution: The dynamic structure of DORA's framework permits constant upgrading and development, guaranteeing that the banking industry can keep up with the quick speed of digital transformation.

3. Enhancing Cross-Sector Collaboration and Compliance:


  • Unified Approach Across Financial firms: By encouraging a single strategy for digital operational resilience, DORA makes it easier for various financial firms to work together. This common framework contributes to the development of a stronger and more integrated financial environment.

  • Encouraging Compliance and Best Practices: DORA promotes a culture of compliance and excellence in the financial industry by setting a high standard and encouraging financial institutions to follow best practices in ICT management and security.

4. Advancing Risk Management and Mitigation Strategies:


  • Creative Risk Management Solutions: DORA's focus on digital resilience pushes financial institutions to create and employ creative risk management and mitigation plans in order to stay competitive in a world where technology is becoming more and more important.

  • Enhanced Focus on Preventative Measures: A more safe and stable financial climate is the result of the act's increased emphasis on preventative measures as opposed to reactive remedies.

5. Preparing for the Future of Digital Finance:


  • Adaptability to developing Technologies: Financial institutions can easily adopt developing technologies while preserving operational resilience thanks to DORA's flexible framework.

  • Securing Financial Operations in the Digital Age: DORA is essential to securing the future of financial operations in the digital age by making sure they stay resilient, adaptable, and secure by proactively tackling the issues posed by digitalization.



The RTS on ICT Incident Categorization: A Key Pillar of DORA:


  • Standardizing Incident Responses: To ensure uniformity and effectiveness throughout the financial industry, the RTS offers a standardized method for classifying and handling ICT problems.

  • Improving Risk Management: The RTS helps financial institutions better analyze and manage their risks, which results in more effective mitigation methods. It does this by providing distinct categories for ICT accidents.

EBF's Pivotal Contribution to the Development of the RTS:


  • Using Industry Knowledge to Influence Policy: The EBF's contribution to the RTS's development emphasizes the value of industry knowledge in the formulation of public policy. Their observations guarantee that the guidelines are realistic and relevant to the banking industry.

  • Combined Efforts for Higher Standards: The EBF's and other stakeholders' cooperation in creating the RTS serves as an example of a successful public-private partnership in financial regulation.



Detailed Exploration of DORA and the RTS on ICT Incident Categorization


In terms of digital resilience in banking, DORA—which was formally formed as Regulation (EU) 2022/2554—is a significant advancement. Its broad scope extends to a diverse range of financial institutions, such as FinTech startups, insurance providers, investment houses, and commercial banks. This regulation requires that stringent protocols be put in place for handling and documenting events using ICT.


The RTS on ICT incident classification is required for DORA to operate. This framework component lays out the criteria for categorizing ICT incidents according to their overall impact and severity. Because it enables financial institutions to manage ICT risks more skillfully, this classification is essential.




Proactive Mitigation Strategies and Potential Impact


To keep ahead of the competition, financial institutions should actively engage in the consultation process and begin revising their ICT incident management protocols. This means ensuring that staff members are up to date on the latest procedures and standards and that they fully understand what is meant by "Critical Services." It could be necessary to fully rethink the current ICT incident response systems in order to incorporate the Proportionality Principle and Risk-Based Approach, among other adjustments.


Timeline and Future Steps


The RTS released its first round of consultation documents on June 19, 2023. EBF members are required to submit their feedback to the European Commission by January 17th, 2024. The results and suggestions drawn from this input are expected to be very important in deciding on the final RTS requirements.




Future Implications and Prospects: The Impact of DORA Regulations on the Financial and Regulatory Landscape


The introduction of the Regulatory Technical Standards (RTS) on ICT incident classification and the execution of the Digital Operational Resilience Act (DORA) are ushering in a new age in finance and regulation. This section examines the potential long-term effects and features of these developments, with a focus on how they might alter the regulatory compliance and financial operations environment.


1. Enhanced Digital Resilience in the Financial Sector:


  • Long-Term Stability: DORA is anticipated to significantly improve the digital resilience of financial institutions. This increased resilience is expected to contribute to the long-term stability and reliability of the financial sector, particularly in resolving ICT-related difficulties.

  • Adaptation to Digital Threats: Effective operational resilience in the digital sphere is crucial as financial institutions rely more and more on digital solutions. DORA's laws encourage the use of cutting-edge methods to stop digital dangers, which will ultimately lead to a safer financial environment.

2. Changing Regulatory Compliance Dynamics:


  • Increased Requirements: As a result of the RTS on ICT incident classification, financial institutions will need to adhere to new and more stringent standards. This shift will likely result in these banks taking a different approach to regulatory compliance, emphasizing proactive risk management more.

  • Emphasis on Incident Reporting and Management: By placing a strong emphasis on correct reporting and efficient management of ICT concerns, the new standards will allow incident response methods to grow in complexity.

3. Broader Impact on Financial Services and Products:


  • Innovation in Financial Products: The introduction of DORA may encourage innovation in financial services and products as institutions strive to maintain their competitive edge while adhering to the new laws.

  • Enhanced Customer Confidence: Improved operational resilience helps bolster the financial industry's reputation for dependability and security, which can boost consumer trust in financial services and goods.

4. Global Influence and Harmonization:


  • Establishing a Global Standard: A more cohesive global approach to digital operational resilience in the banking sector might be achieved by using the EU's plan as a template for other sectors.

  • Cross-Border collaboration: By encouraging more alignment and coordination of cross-border regulatory practices, DORA may foster international collaboration in the field of financial regulation.

5. Challenges and Opportunities for Financial Institutions:


  • Training and System Adaptation: In order to comply with the new RTS criteria, organizations must make changes to their current systems. System redesigns and extensive staff training might be necessary for this.
  • Potential for technological advancement: As organizations adopt state-of-the-art systems to adhere to DORA, this process of adaptation presents an opportunity for technological advancement within those organizations.



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DORA | RTS on ICT Incident Classification based on EBF’s Position
The European Supervisory Authorities (ESAs) have published a batch of Consultation Papers for the technical standards mandated by the Digital Operational Resilience Act (DORA). The European Banking Federation (EBF) and Deloitte held a joint workshop to gather feedback on the Consultation Paper for the RTS on ICT incident classification. The EBF members raised concerns about the unclear definition of Critical Services, the application of the Proportionality Principle and Risk-based Approach, and the challenges in the notification of significant threats. The EBF is the voice of the European banking sector and is committed to a stable and inclusive financial ecosystem.




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