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Is the financial sector ready for DORA?

Source: Finance Derivative

Wayne Scott, Regulatory Compliance Solutions Lead at leading software escrow company, Escode, delves into the Digital Operational Resilience Act (DORA), exploring the key challenges financial organisations are facing and what they can do to prepare themselves for the upcoming legislation.

With just three months to go until the enforcement of the Digital Operational Resilience Act (DORA), the clock is ticking for those financial services organisations operating in the European Union. Businesses that do not comply could face serious consequences, including fines of up to 2% of global daily revenue and potential personal liabilities such as fines or jail time for executives, so thorough preparation is crucial.

So how ready are organisations for DORA, and what challenges might be facing them on the road to compliance?

DORA: A new era in financial regulation

DORA isn’t just regulation; it’s legislation. This distinction underscores the European Union’s intent to enforce it with absolute rigour, addressing growing concerns around third-party risk. DORA advocates for the inclusion of stressed exit plans in all ICT third party license agreements to prevent supplier failure majorly disrupting the financial service sector.

As financial institutions increasingly rely on external tech providers, the threat of a single point of failure has never been more pertinent. Recent high-profile global tech collapses have shown just how vulnerable the system is, making DORA’s focus on digital resilience timelier than ever.

The financial landscape is already turbulent, made fragile by ongoing issues such as rising global borrowing costs. So, the last thing financial services need is more risk exposure from poorly managed third-party relationships.

How does the regulation stack up across the globe?

While DORA is the EU’s latest regulation, it’s not just European companies that need to pay attention. Interest in DORA is rapidly growing in the US and UK, particularly among companies with significant EU operations. Yet, many non-EU firms are still unsure whether they’ll fall under DORA’s rules.

Adding to the pressure is the looming deadline for the UK’s SS221 regulations, coming in March 2025. The overlap between DORA and SS221 has left many organisations frustrated, facing compliance with not one but two significant regulatory frameworks.

Globally, DORA represents a new chapter in digital resilience. While the EU is leading the charge, the rest of the globe is following very closely behind.

Despite the growing urgency for robust third-party risk management, many organisations remain alarmingly underprepared for DORA’s implementation. In fact, a recent report commissioned by Escode in collaboration with international research organisation CeFPro, revealed that only 20.8% of financial professionals report having stressed exit plans in place within most of their third-party agreements, including software suppliers.

These figures indicate that many financial institutions still have considerable work to do in preparation for DORA. With the new legislation set to take effect from January 2025, it’s important to look at the challenges facing businesses when it comes to ensuring compliance.

The risk of overconfidence

A common pitfall for large institutions is assuming they are DORA-ready. Many discover major gaps when they conduct deeper assessments, particularly in areas like third-party escrow agreements, which can take months to finalise. This becomes even more risky when organisations lack clarity on the penalties for non-compliance.

So, in the lead up to DORA, organisations need to build a defensible position. While complete compliance by January 2025 may be a long shot for many, organisations can start to demonstrate progress. A clear roadmap, identifying regulatory gaps and planned actions for improving processes, could make all the difference in helping the financial sector to prepare for the changes.

Navigating ambiguity

There’s currently a lack of clarity around whether critical third-party providers will be directly regulated under DORA. Many tech companies, who are often blindsided by regulatory updates in the financial sector, are also ill-prepared for the many compliance requests about to come their way.

The cost of compliance is another challenge. As reactive compliance kicks in, companies are discovering that ticking all the regulatory boxes isn’t just time-consuming—it’s expensive. Many are scrambling to implement reactive solutions, which only add layers of complexity.

What’s really needed is standardisation – a clear path that helps third-party tech providers understand and meet regulatory expectations. Until that happens, confusion will remain a barrier for both financial businesses and tech providers alike.

What should organisations do now?

With only months left until DORA comes into play, its clear organisations need to act now to ensure a smooth transition.

Here are key steps organisations can take to make the process of becoming DORA-ready as easy as possible:

  • Mobilise cross-functional teams

Effective digital resilience requires collaboration, but in many cases, accountability is lacking. Some companies have assigned DORA compliance to legal departments, others to risk or IT teams. This often results in a fragmented approach to a problem that requires unity. Organisations need to mobilise cross-functional teams to tackle the challenge head-on and ensure a collaborative approach to risk management.

  • Focus on supplier management

Equally important is supplier management. It’s not just about ensuring your direct tech providers are resilient—what about their providers? A key question every organisation should be asking its suppliers is: “What’s your stressed exit plan?” Proactive due diligence is critical, but it’s not happening fast enough. The message for C-suites is clear—get your teams together, assess the financial, contractual, and technical barriers, and act before it’s too late.

  • Conduct gap analysis

Regular gap analysis will be a crucial tool in this process. Continual assessment of your current compliance status will not only identify areas that need attention but will also help shape the defensible position that could save you from regulatory pressures. This is key for taking a proactive approach to managing risks and regulation and can help to avoid challenges in the long run.

The countdown is on

Three months may feel like a lifetime in the corporate world, but when it comes to DORA compliance, it’s the blink of an eye. The message for financial services is simple: if you’re not already well on your way to compliance, you’re behind.

Now is the time to mobilise your teams, collaborate across departments, and prepare for the legislation. For the financial sector, DORA marks the beginning of a new regulatory era—one where digital resilience isn’t just a buzzword, but a non-negotiable imperative. The time to act is now.

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Business

Why Resilience Is Replacing Prevention as the Defining Cybersecurity Strategy

by Manuel Sanchez, Information Security and Compliance Specialist, iManage

For decades, cybersecurity centered around prevention. Build the right walls around your perimeter, deploy the right tools, train your people not to click the wrong links, and you could keep the bad actors out.

Today, the question driving security strategy is no longer “how do we stop a breach?” but “how do we survive one?” It is a subtle but profound shift in philosophy, and it is reshaping everything from how IT and Security leaders structure their teams to how they select their vendors and deploy AI.

Rehearsing for the worst

The practical expression of this shift is visible in how security teams are being restructured. Organisations are establishing dedicated disaster recovery teams – not to prevent incidents, but to contain and recover from them when they occur. These teams maintain detailed, regularly updated playbooks covering everything from backup restoration to stakeholder communications, with roles pre-assigned and procedures rehearsed well in advance.

In many ways, this mirrors the logic behind disaster drills: fire alarms matter, but knowing the evacuation routes and the post-incident recovery plan determines how well an organisation survives. Critically, responsibility cannot rest with the CISO alone. Business continuity after a cyber incident is a whole-company challenge – which means every core part of the organisation is involved to sustain critical business operations.

Governance in the gray areas

Running alongside this shift is a governance crisis that is easy to underestimate until it becomes a serious risk. As organisations adopt more applications across more vendors and hosting services, the shared responsibility model that was supposed to keep cloud accountability clear has become increasingly difficult to enforce.

The sheer volume of cloud applications in use at any given enterprise is too vast for consistent governance under current approaches – and bad actors have become skilled at identifying exactly where vendor responsibility ends, and customer accountability begins, then operating precisely in that “gray area”. Being aware of this risk and putting preventative measures in place is important, but recognising the role these cloud applications play and the impact to key business operations if these applications were compromised, is critical.

Meanwhile, data volumes continue to grow exponentially, and unstructured data continues to accumulate in the background across many digital systems. Why is this important? If you don’t know what data you have, where it is stored, who has access to it, and, most importantly, how it is protected – onsite or cloud backup – this makes the recovery process a lot harder.

AI agents on the rise – and with it new risks

Although the focus of this article is on resilience, prevention must still remain an essential part of your defences. On that front, the accelerating adoption of autonomous AI in cyber defence tasks is reshaping security operations as visibly as anything else happening in the field right now. The volume, speed, and sophistication of modern threats have simply outpaced what human analysts can manage in real time.

The shift is toward AI that doesn’t just flag anomalies for human review, but actively detects, analyses, and neutralises threats as they emerge, even using predictive models to anticipate attacks before they fully materialise. This frees human experts to focus on strategic decisions and complex defence work rather than spending their days firefighting.

Autonomous AI does, however, introduce risks of its own. When AI agents operate across systems – accessing sensitive repositories, triggering actions, sharing data – they expand the attack surface in ways that aren’t always immediately visible.

Managing the digital identities of AI agents, much like managing employee access credentials, is becoming a critical security discipline. Accordingly, comprehensive traceability frameworks that log every action an agent takes are no longer optional; they are the foundation of responsible AI deployment in any security context.

The supply chain wake-up call

The case for moving from a “prevention” mindset to a “resilience” one is further bolstered by recent high-profile breaches via compromised managed service providers, which have forced a fundamental reset in how organisations evaluate their vendors.

The era of cost-first selection is over. Security credentials, demonstrated through continuous and verifiable evidence, are now non-negotiable for any provider hoping to retain enterprise clients – and what organisations are demanding goes well beyond point-in-time audits. They want real-time visibility into every third-party integration, every software update, and every vendor interaction – including the cloud services the vendors themselves use.

“Trust but verify” has become the operational standard, and providers who cannot demonstrate validated controls and live monitoring are finding themselves out of contention. It is a structural shift that will reshape the vendor landscape considerably — and it is already underway.

A new era demands a new approach

In the end, prevention still matters, but resilience – instilled via the key focus areas above – is what turns disruption into survivable events rather than existential crises. The organisations that are honest about the limits of prevention and embrace the shift towards resilience won’t just better withstand the next wave of attacks – they’ll be differentiating themselves from competitors still clinging to yesterday’s playbook.

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Adapting compliance in a fragmented regulatory world

Rasha Abdel Jalil, Director of Financial Crime & Compliance at Eastnets, discusses the operational and strategic shifts needed to stay ahead of regulatory compliance in 2025 and beyond.

As we move through 2025, financial institutions face an unprecedented wave of regulatory change. From the EU’s Digital Operational Resilience Act (DORA) to the UK’s Basel 3.1 rollout and upcoming PSD3, the volume and velocity of new requirements are constantly reshaping how banks operate.

But it’s not just the sheer number of regulations that’s creating pressure. It’s the fragmentation and unpredictability. Jurisdictions are moving at different speeds, with overlapping deadlines and shifting expectations. Regulators are tightening controls, accelerating timelines and increasing penalties for non-compliance. And for financial compliance teams, it means navigating a landscape where the goalposts are constantly shifting.

Financial institutions must now strike a delicate balance: staying agile enough to respond to rapid regulatory shifts, while making sure their compliance frameworks are robust, scalable and future-ready.

The new regulatory compliance reality

By October of this year, financial institutions will have to navigate a dense cluster of regulatory compliance deadlines, each with its own scope, jurisdictional nuance and operational impact. From updated Common Reporting Standard (CRS) obligations, which applies to over 100 countries around the world, to Australia’s new Prudential Standard (CPS) 230 on operational risk, the scope of change is both global and granular.

Layered on top are sweeping EU regulations like the AI Act and the Instant Payments Regulation, the latter coming into force in October. These frameworks introduce new rules and redefine how institutions must manage data, risk and operational resilience, forcing financial compliance teams to juggle multiple reporting and governance requirements. A notable development is Verification of Payee (VOP), which adds a crucial layer of fraud protection for instant payments. This directly aligns with the regulator’s focus on instant payment security and compliance.

The result is a compliance environment that’s increasingly fragmented and unforgiving. In fact, 75% of compliance decision makers in Europe’s financial services sector agree that regulatory demands on their compliance teams have significantly increased over the past year. To put it simply, many are struggling to keep pace with regulatory change.

But why is it so difficult for teams to adapt?

The answer lies in a perfect storm of structural and operational challenges. In many organisations, compliance data is trapped in silos spread across departments, jurisdictions and legacy platforms. Traditional approaches – built around periodic reviews, static controls and manual processes – are no longer fit for purpose. Yet despite mounting pressure, many teams face internal resistance to changing established ways of working, which further slows progress and reinforces outdated models. Meanwhile, the pace of regulatory change continues to accelerate, customer expectations are rising and geopolitical uncertainty adds further complexity.

At the same time, institutions are facing a growing compliance talent gap. As regulatory expectations become more complex, the skills required to manage them are evolving. Yet many firms are struggling to find and retain professionals with the right mix of legal, technical and operational expertise. Experienced professionals are retiring en-masse, while nearly half of the new entrants lack the right experience needed to step into these roles effectively. And as AI tools become more central to investigative and decision-making processes, the need for technical fluency within compliance teams is growing faster than organisations can upskill. This shortage is leaving compliance teams overstretched, under-resourced and increasingly reliant on outdated tools and processes.

Therefore, in this changing environment, the question suddenly becomes how can institutions adapt?

Staying compliant in a shifting landscape

The pressure to adapt is real, but so is the opportunity. Institutions that reframe compliance as a proactive, technology-driven capability can build a more resilient and responsive foundation that’s now essential to staying ahead of regulatory change.

This begins with real-time visibility. As regulatory timelines change and expectations rise, institutions need systems that can surface compliance risks as they emerge, not weeks or months later. This means adopting tools that provide continuous monitoring, automated alerts and dynamic reporting.

But visibility alone isn’t enough. To act on insights effectively, institutions also need interoperability – the ability to unify data from across departments, jurisdictions and platforms. A modern compliance architecture must consolidate inputs from siloed systems into a unified case manager to support cross-regulatory reporting and governance. This not only improves accuracy and efficiency but also allows for faster, more coordinated responses to regulatory change.

To manage growing complexity at scale, many institutions are now turning to AI-powered compliance tools. Traditional rules-based systems often struggle to distinguish between suspicious and benign activity, leading to high false positive rates and operational inefficiencies. AI, by contrast, can learn from historical data to detect subtle anomalies, adapt to evolving fraud tactics and prioritise high-risk alerts with greater precision.

When layered with alert triage capabilities, AI can intelligently suppress low-value alerts and false positives, freeing up human investigators to focus on genuinely suspicious activity. At the more advanced stages, deep learning models can detect behavioural changes and suspicious network clusters, providing a multi-dimensional view of risk that static systems simply can’t match.

Of course, transparency and explainability in AI models are crucial. With regulations like the EU AI Act mandating interpretability in AI-driven decisions, institutions must make sure that every alert or action taken by an AI system is auditable and understandable. This includes clear justifications, visual tools such as link analysis, and detailed logs that support human oversight.

Alongside AI, automation continues to play a key role in modern compliance strategies. Automated sanction screening tools and watchlist screening, for example, help institutions maintain consistency and accuracy across jurisdictions, especially as global lists evolve in response to geopolitical events.

Similarly, customisable regulatory reporting tools, powered by automation, allow compliance teams to adapt to shifting requirements under various frameworks. One example is the upcoming enforcement of ISO 20022, which introduces a global standard for payment messaging. Its structured data format demands upgraded systems and more precise compliance screening, making automation and data interoperability more critical than ever.

This is particularly important in light of the ongoing talent shortages across the sector. With newer entrants still building the necessary expertise, automation and AI can help bridge the gap and allow teams to focus on complex tasks instead.

The future of compliance

As the regulatory compliance landscape becomes more fragmented, compliance can no longer be treated as a tick-box exercise. It must evolve into a dynamic, intelligence-led capability, one that allows institutions to respond to change, manage risk proactively and operate with confidence across jurisdictions.

To achieve this, institutions must rethink how compliance is structured, resourced and embedded into the fabric of financial operations. Those that do, and use the right tools in the process, will be better positioned to meet the demands of regulators today and in the future.

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Why Shorter SSL/TLS Certificate Lifespans Are the Perfect Wake-Up Call for CIOs

By Tim Callan, Chief Compliance Officer at Sectigo and Vice-Chair of the CA/Browser Forum

Let’s be honest: AI has been the headline act this year. It’s the rockstar of boardroom conversations and LinkedIn thought leadership. But while AI commands the spotlight, quantum computing is quietly tuning its instruments backstage. And when it steps forward, it won’t be playing backup. For CIOs, the smart move isn’t just watching the main stage — it’s preparing proactively for the moment quantum takes center stage and rewrites the rules of data protection.


Quantum computing is no longer a distant science project. NIST has already published standards for quantum-resistant algorithms and set a clear deadline: RSA and ECC, the cryptographic algorithms that protect today’s data, must be deprecated by 2030. We’re no longer talking about “forecasts;” we are talking about actual directives from government organizations to implement change. And yet, many organizations are still treating this like a future problem. The reality is that threat actors aren’t waiting. They’re collecting encrypted data now, knowing they’ll be able to decrypt it later. If we wait until quantum machines are commercially viable, we’ll be too late. The time to prepare is before the clock runs out and, unfortunately, that clock is already ticking.

For CIOs, this is an infrastructure and risk management crisis in the making. If your organization’s cryptographic infrastructure isn’t agile enough to adapt, the integrity of your digital operations and the trust they rely on could very soon be compromised.

The Quantum Threat Is Already Here

Quantum computing’s potential to disrupt global systems and the data that runs through it is not hypothetical. Attackers are already engaging in “Harvest Now, Decrypt Later” (HNDL) strategies, intercepting encrypted data today with the intent to decrypt it once quantum capabilities mature.

Recent research found that an alarming 60% of organizations are very or extremely concerned about HNDL attacks, and 59% express similar concern about “Trust Now, Forge Later” threats, where adversaries steal digitally signed documents to forge them in the future.

Despite this awareness, only 14% of organizations have conducted a full assessment of systems vulnerable to quantum attacks. Nearly half (43%) of organizations are still in a “wait and see” mode. For CIOs, this gap highlights the need for leadership: it’s not
enough to know the risks exist, you must identify which systems, applications, and data flows will still be sensitive in ten or twenty years and prioritize them for PQC migration.

Crypto Agility Is a Data Leadership Imperative

Crypto agility (the ability to rapidly identify, manage, and replace cryptographic assets) is now a core competency for IT leaders to ensure business continuity, compliance, and trust. The most immediate pressure point is SSL/TLS certificates. These certificates authenticate digital identities and secure communications across data pipelines, APIs, and partner integrations.

The CA/Browser Forum has mandated a phased reduction in certificate lifespans from 398 days today to just 47 days by 2029. The first milestone arrives in March 2026, when certificates must be renewed every six months, shrinking to near-monthly by 2029.

For CIOs, it’s not just an operational housekeeping issue. Every expired or mismanaged certificate is a potential data outage. That means application downtimes, broken integration, failed transactions and compliance violations. With less than 1 in 5 organizations prepared for monthly renewals, and only 5% fully automating their certificate management processes currently, most enterprises face serious continuity and trust risks.

The upside? Preparing for shortened certificate lifespans directly supports quantum readiness. Ninety percent of organizations recognize the overlap between certificate agility and post-quantum cryptography preparedness. By investing in automation now, CIOs can ensure uninterrupted operations today while laying a scalable foundation for future-proof cryptographic governance.

The Strategic Imperative of PQC Migration

Migrating to quantum-safe algorithms is not a plug-and-play upgrade. It’s a full-scale transformation. Ninety-eight percent of organizations expect challenges, with top barriers including system complexity, lack of expertise, and cross-team coordination. Legacy systems (many with hardcoded cryptographic functions) make this even harder.

That’s why establishing a Center of Cryptographic Excellence (CryptoCOE) is a critical first step. A CryptoCOE centralizes governance, aligns stakeholders, and drives execution. According to Gartner, by 2028 organizations with a CryptoCOE will save 50% of costs in their PQC transition compared to those without.

For CIOs, this is a natural extension of your role. Cryptography touches every layer of enterprise infrastructure. A CryptoCOE ensures that cryptographic decisions are made with full visibility into system dependencies, risk profiles and regulatory obligations.

By championing crypto agility as an infrastructure priority, CIOs can transform PQC migration from a technical project into a strategic initiative that protects the organization’s most critical assets.

The Road Ahead

The shift to 47-day certificates is a wake-up call. It marks the end of static cryptography and the beginning of a dynamic, agile era. Organizations that embrace this change will not only avoid outages and compliance failures, but they’ll be also prepared for the quantum future.

Crypto agility is both a technical capability and a leadership mandate. For CIOs, the path forward to quantum-resistant infrastructure can be clear: invest in automation, build cross-functional alignment, and treat cryptographic governance as a core pillar of enterprise resilience.

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