The introduction of the European Digital Operational Resilience Act (DORA) marks a major shift for ICT providers working in the financial sector. Although these suppliers are not directly regulated, they now form a critical link in their clients’ compliance chain — whether banks, insurers, asset managers, or fintechs.

To remain competitive and credible, providers must demonstrate their ability to support clients’ operational resilience while aligning with increasingly rigorous standards.

DORA. A silent shift, with lasting impact

What DORA represents in finance echoes what TISAX has brought to the automotive industry. In both sectors, buyers no longer accept good intentions. They expect proof. Verifiable guarantees. Partners who can show that their practices meet demanding, sector-specific expectations.

This is no longer just about regulation. It is reshaping how business relationships start, grow, or end.

In one recent RFP, a tech supplier failed to clearly define the scope of their information system during the negotiation. The signed contract went far beyond the services initially discussed. Their entire shared infrastructure was pulled under the buyer’s compliance perimeter.

The consequences were serious. Sovereign hosting was imposed. Encryption policies had to be rebuilt. Auditing had to be enabled end to end. Tools had to be replaced. The cost ran into hundreds of thousands of euros. And there was no way to pass it on in the short term.

This isn’t an isolated case. Many providers are exposed to similar risks. If you don’t define your scope upfront, others will do it for you.

Anticipation is the only way to stay in control. Structuring your DORA posture is how you protect your business.

Five strategic actions to turn DORA into an opportunity 

1. Prepare your organization for your clients’ compliance

Your clients now maintain a formal register of their critical ICT providers. These registers are updated, verified, and monitored. They include the services provided, the level of dependency, assigned responsibilities, and oversight measures.

You are — or will be — on that list. You’ll be assessed. You’ll be classified. Any weakness in your continuity plans, escalation processes, or service levels will be visible.

This isn’t a threat. It’s a chance to strengthen what you already do. To revisit the fundamentals. To clarify your governance. To document your procedures. To identify your areas for improvement.

A well-executed DORA maturity review positions you as a reliable, transparent, and resilient partner.

2. Negotiate DORA-compliant contracts tailored to your business model

Contracts sit at the heart of DORA. They reflect the requirements of your clients — audit rights, reporting, security expectations, termination clauses, incident handling.

These clauses are no longer optional. They are reviewed. Shared. Enforced.

Failing to negotiate the terms can turn the contract into a liability. Too vague, too rigid, or simply unfit for your services. But a clear, tailored agreement protects your interests and strengthens the client relationship.

It all starts with preparation. Know what you accept. Know what you can’t commit to. Know what you can prove.

3. Take back control of your existing contracts

Many providers assume that DORA only applies to future agreements. That’s a mistake. Existing contracts are in scope. Your clients are required to update them. They will contact you.

This is your chance to review the terms. To regain control over what was signed, sometimes too quickly. To map what already aligns with DORA. To prioritize gaps. To manage the conversation, point by point, without overreacting.

You also need to assess the operational and financial impacts. Each new clause can trigger technical changes, additional costs, or governance adjustments.

This is not a formality. It’s risk management.

4. Adopt a risk-based approach with FAIR™

DORA is built on a clear principle: act according to real, quantified risk — not generic models.

FAIR™ helps you do just that. It allows you to evaluate cyber scenarios in business terms. To assign realistic probabilities. To measure the financial impact. To move from assumption to calculation.

This clarity speaks to decision-makers. It resonates with CEOs. It informs the CIO. It gives the CISO visibility and structure. It helps everyone make the right call.

Adopting FAIR™ is how you move from a reactive stance to risk-driven resilience.

5. Align your teams

Compliance isn’t the job of one person. It’s not just a project. It requires every function. Legal, sales, operations, IT. Everyone has a role.

A poorly understood request can stall a deal. A missed escalation can weaken trust. An untested process can delay a delivery.

Training matters. Awareness matters. Alignment matters. Everyone should know what to do, and why. This is what transforms static compliance into living practice.