The ICT Risk Management Framework is the foundation of DORA compliance. This comprehensive guide will help you build a framework that meets regulatory requirements while enhancing your organization's operational resilience.

Understanding the Requirements

DORA Article 6 requires financial entities to establish a comprehensive ICT risk management framework that covers:

  • ICT risk identification, assessment, and mitigation
  • Protection and prevention measures
  • Detection mechanisms
  • Response and recovery capabilities
  • Learning and evolving processes
  • Communication and reporting

Step 1: Governance and Organization

Establish Clear Accountability

Your framework must define:

  • Management Body Responsibility: The board must approve and oversee the ICT risk management framework
  • Senior Management: Designate executives responsible for ICT risk implementation
  • Three Lines of Defense: Define roles for business, risk management, and internal audit
  • ICT Risk Function: Establish a dedicated function or team

Documentation Requirements

Maintain comprehensive documentation including:

  • ICT risk management policy
  • Roles and responsibilities matrix
  • Decision-making processes
  • Escalation procedures

Step 2: Asset and Dependency Mapping

Create ICT Asset Inventory

Document all ICT assets supporting business functions:

  • Hardware infrastructure
  • Software applications
  • Data repositories
  • Network components
  • Third-party services

Map Critical Business Functions

For each critical business function, identify:

  • Supporting ICT systems
  • Data flows
  • Dependencies and interconnections
  • Recovery time objectives (RTO)
  • Recovery point objectives (RPO)

Step 3: Risk Assessment Process

Risk Identification

Implement systematic risk identification covering:

  • Internal threats (insider risks, system failures)
  • External threats (cyberattacks, natural disasters)
  • Third-party risks
  • Emerging technologies and innovations

Risk Analysis and Evaluation

For each identified risk, assess:

  • Likelihood: Probability of occurrence
  • Impact: Potential consequences on business operations
  • Risk Rating: Combined score determining priority
  • Current Controls: Existing mitigation measures
  • Residual Risk: Risk remaining after controls

Step 4: Protection and Prevention

Security Controls

Implement appropriate controls including:

  • Access management and authentication
  • Network security and segmentation
  • Encryption for data at rest and in transit
  • Patch management and vulnerability management
  • Endpoint protection
  • Security awareness training

Change Management

Establish procedures for:

  • Assessing ICT changes before implementation
  • Testing in non-production environments
  • Rollback capabilities
  • Documentation of changes

Step 5: Detection and Monitoring

Continuous Monitoring

Deploy capabilities to detect:

  • Anomalous activities and security events
  • Performance degradation
  • Compliance deviations
  • Unauthorized changes

Logging and Alerting

Implement comprehensive logging:

  • Centralized log management
  • Log retention policies
  • Real-time alerting rules
  • Security information and event management (SIEM)

Step 6: Business Continuity and Disaster Recovery

Business Continuity Planning

Develop and maintain:

  • Business impact analysis (BIA)
  • Continuity strategies for critical functions
  • Alternative processing arrangements
  • Communication plans

Disaster Recovery

Establish robust recovery capabilities:

  • Backup strategies (onsite and offsite)
  • Recovery procedures
  • Regular testing and validation
  • Documentation and runbooks

Step 7: Testing and Validation

Regular testing is essential:

  • Vulnerability assessments (quarterly minimum)
  • Penetration testing (annual minimum)
  • Business continuity exercises
  • Disaster recovery tests
  • TLPT for significant entities

Step 8: Learning and Improvement

Post-Incident Reviews

After significant incidents:

  • Conduct root cause analysis
  • Document lessons learned
  • Update procedures and controls
  • Share insights across organization

Continuous Improvement

Regularly review and update:

  • Risk assessments
  • Control effectiveness
  • Emerging threats and technologies
  • Regulatory requirements

Key Success Factors

  • Executive Support: Ensure board and senior management engagement
  • Integration: Align with existing risk management frameworks
  • Proportionality: Scale framework to organization size and complexity
  • Documentation: Maintain comprehensive evidence of compliance
  • Training: Ensure all staff understand their roles
  • Technology: Leverage tools and automation where appropriate

Common Pitfalls to Avoid

  • Treating DORA as purely an IT project
  • Underestimating documentation requirements
  • Neglecting third-party risks
  • Insufficient board involvement
  • Lack of integration with business continuity
  • Inadequate testing and validation

Measuring Effectiveness

Track key performance indicators (KPIs):

  • Number of identified vs. mitigated risks
  • Mean time to detect (MTTD) incidents
  • Mean time to respond (MTTR)
  • Percentage of assets with current risk assessments
  • Training completion rates
  • Test success rates