What does DORA require for ICT risk management?
DORA requires EU financial entities to operate a documented ICT risk management framework under Articles 5 to 16: management-body accountability for ICT risk, identification of ICT assets and dependencies, protection and prevention measures, continuous detection of anomalous activity, response and recovery plans, backup and restoration policies, and post-incident learning. Hardened baseline configurations with continuous drift monitoring form the technical evidence layer for the protection, prevention, and detection articles.
The longer answer.
DORA applies to banks, insurers, investment firms, payment institutions, crypto-asset service providers, and other EU financial entities, and extends to critical ICT third-party providers. The regulation has been fully applicable since January 17, 2025, and supervisors expect the ICT risk framework to be demonstrable, not aspirational.
The configuration-heavy obligations sit in Articles 9 to 11: protection and prevention require systems to be securely configured and kept that way; detection requires the ability to spot anomalous changes. Continuous CIS benchmark scanning satisfies both halves, producing a running record that configurations remained hardened and that deviations were detected and remediated.
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