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Software for DORA Regulation

  • Writer: Aboli Maske
    Aboli Maske
  • 7 days ago
  • 13 min read

The DORA Regulation makes ICT resilience a board‑level obligation for EU financial institutions and their critical ICT providers, with full application from 17 January 2025 and direct, uniform effect across all member states. For most firms this is less about buying a new tool and more about redesigning IT, security, and vendor‑risk operating models around five regulatory pillars, using platforms like ServiceNow, HaloITSM, Freshworks, and ManageEngine as execution engines.​​


Mind map of DORA Regulation with branches: Scope, Five Pillars, ITSM Platforms, and Implementation Guidance. Blue text boxes on white background.

What is the DORA Regulation and why does it exist?

The DORA Regulation is Regulation (EU) 2022/2554, designed to ensure financial entities can withstand, respond to, and recover from ICT‑related incidents by harmonizing digital operational resilience rules across the EU. Unlike directives, it is directly applicable in every member state, so firms cannot rely on national gold‑plating or delays to defer compliance obligations.​


DORA emerged from the EU Digital Finance Package and treats cyberattacks, ICT outages, and third‑party failures as systemic financial‑stability risks rather than purely IT issues. Around 22,000 financial entities are in scope, making it one of the largest operational‑resilience initiatives the sector has faced, with enforcement now active from 17 January 2025.​



How is DORA structured around five pillars?

DORA’s requirements are typically grouped into five pillars: ICT risk management, ICT‑related incident management and reporting, digital operational resilience testing, ICT third‑party risk management, and information‑sharing arrangements. Each pillar contains specific obligations for governance, processes, data, and evidence, which together form a continuous resilience cycle rather than a point‑in‑time checklist.​


For technology leaders, these pillars provide a practical blueprint for configuring ITSM, ITOM, GRC, and vendor‑risk tooling so that day‑to‑day operations automatically generate the registers, dashboards, and reports supervisors will expect to see. DataLunix’s EchoViz framework, for example, maps these pillars into a unified information model and API layer that connects platforms like ServiceNow, HaloITSM, Freshworks, and ManageEngine into DORA‑ready registers of assets, risks, incidents, third parties, and tests.​​


Who does the DORA Regulation apply to?

DORA covers a wide range of regulated financial entities, including banks, investment firms, payment and e‑money institutions, insurers, reinsurers, central securities depositories, trading venues, and many other categories explicitly listed in the regulation. Smaller firms are also in scope, although the principle of proportionality allows supervisory expectations to scale with size and risk exposure rather than enforcing a single “big‑bank” template.​

Crucially, ICT third‑party service providers—including cloud, SaaS, and managed service platforms outside the EU—may fall under a separate oversight regime if designated as critical to EU financial stability. The European Supervisory Authorities (EBA, ESMA, EIOPA) can directly supervise such critical ICT third‑party providers, impose remediation, and recommend fines or contractual restrictions for serious non‑compliance.​


What makes the DORA Regulation different from previous ICT rules?

DORA consolidates fragmented national and sectoral ICT rules into a single, horizontal framework that applies consistently across the EU financial sector. It explicitly links digital operational disruptions to financial‑stability and consumer‑protection objectives, which means supervisors will look beyond “paper” policies to evidence of real resilience in production environments.​


The regulation also introduces a formal oversight regime for critical ICT third‑party providers and requires standardized registers of information covering assets, incidents, third parties, and testing. This pushes financial entities to integrate cybersecurity, IT operations, business continuity, and vendor‑risk management into a single, data‑driven operating model rather than separate silos.​​


How can you use DORA as a catalyst rather than a checkbox exercise?

Treating DORA as a compliance minimum leads to tactical projects and fragmented tooling, whereas using it as a design blueprint can modernize your ITSM, ITOM, and risk stack. Many firms are using the deadline to rationalize duplicate tools, standardize workflows, and build a unified ICT asset‑risk‑incident data layer feeding both operations and regulatory reporting.​​

Platforms such as ServiceNow, HaloITSM, Freshworks, and ManageEngine become more than ticketing tools: they are process engines that, when configured correctly, continuously generate DORA‑required evidence and resilience metrics. DataLunix positions DORA programs around this “operating‑model first, tooling‑second” approach to maximize long‑term value from each implementation.​​


How does DORA define ICT risk management and what capabilities do you need?

DORA expects a comprehensive ICT risk‑management framework that covers governance, roles, risk appetite, asset and configuration inventories, change and release controls, business‑impact analysis, and continuity planning. The management body remains accountable for defining risk tolerance, approving the framework, and overseeing implementation, with an emphasis on resilience by design.​


In practice, firms need accurate, dynamic inventories of ICT assets and services, clear mappings to business processes, and workflows that embed risk checks into everyday changes and deployments. Without this foundation, proportional risk assessments and impact‑based prioritization—core expectations under DORA—become extremely difficult to evidence.​​


How can ServiceNow support DORA‑aligned ICT risk management?

ServiceNow offers enterprise‑grade CMDB, ITOM, and GRC modules that can map services, infrastructure, and business processes into a single system of record. Financial institutions can link risks, controls, policies, and issues directly to configuration items and services, enabling traceability from a regulatory requirement through to specific systems and changes.​​

For large banks and insurers, automated discovery, service‑mapping, and risk‑control workflows make ServiceNow a strong backbone for DORA’s ICT risk‑management pillar. DataLunix commonly layers its EchoViz information model on top of ServiceNow to feed DORA Registers of Information with curated asset, risk, and control data.​​


How can HaloITSM and Freshworks help mid‑market firms with ICT risk?

HaloITSM and Freshservice (Freshworks) provide ITSM platforms with CMDB and asset capabilities suitable for smaller banks, regional insurers, and fintechs that need structure without enterprise complexity. Change, problem, and request workflows can be adapted to include risk impact assessments, approvals, and standard templates aligned to DORA governance expectations.​​


When combined with targeted ITOM integrations or third‑party monitoring, these platforms deliver proportional visibility for organizations with leaner teams and budgets. DataLunix often uses HaloITSM or Freshworks as the primary ITSM layer, then connects them to EchoViz via APIs to normalize asset and incident data for DORA reporting.​​


Where does ManageEngine fit into ICT risk and configuration?

ManageEngine combines ITSM, CMDB, and strong ITOM capabilities such as OpManager and Applications Manager, making it attractive for infrastructure‑centric environments. Its monitoring and asset‑discovery tools help populate accurate inventories, while change and incident modules provide the process layer required for governance and traceability.​​


For many mid‑sized financial institutions, ManageEngine offers a cost‑effective way to meet DORA’s need for end‑to‑end visibility across networks, servers, and applications without sacrificing operational depth. DataLunix typically extends this with standardized risk fields and mappings so infrastructure events can be rolled up into DORA‑aligned risk metrics.​​


How should you design incident management and DORA reporting using ITSM platforms?

DORA requires firms to detect, classify, and report major ICT‑related incidents using standardized criteria and timelines, including initial, intermediate, and final reports to competent authorities. It also expects structured post‑incident reviews, root‑cause analysis, and lessons‑learned processes that feed back into risk, controls, and continuity planning.​

ITSM platforms excel at centralizing incident intake, triage, SLA tracking, and escalation, which can be configured to align with DORA’s incident classification and reporting taxonomy. The key is to embed regulatory data points—such as impact on critical or important functions, customers affected, and root cause—into incident records and workflows from the outset.​​


How can ServiceNow streamline DORA incident processes?

ServiceNow’s major‑incident and problem‑management capabilities allow firms to define DORA‑aligned incident categories, priority matrices, and standardized runbooks. Automated notifications can be configured to alert risk, compliance, and legal teams when incidents cross predefined thresholds that may trigger external reporting.​​


Post‑incident review templates and knowledge articles ensure that systematic lessons‑learned and remediation tasks are captured and tracked through change or project workflows. DataLunix designs incident‑to‑report pipelines where ServiceNow data automatically populates EchoViz’s DORA incident register, reducing manual effort and error.​​


How do HaloITSM, Freshworks, and ManageEngine support structured incident reporting?

HaloITSM and Freshservice provide intuitive incident and problem modules that can be tailored with DORA‑specific fields and classification rules. For example, standardized impact categories, tagging of critical services, and out‑of‑the‑box automation rules can drive consistent escalation and documentation for major events.​​


ManageEngine’s tight integration between monitoring and ServiceDesk data helps capture rich technical context (alerts, performance metrics, logs) that supports root‑cause analysis and evidencing to supervisors. DataLunix typically adds standardized templates and dashboards to these platforms to produce regulator‑ready incident packs without offline spreadsheets.​​


How should you manage ICT third‑party and supply‑chain risk under DORA?

DORA mandates robust management of ICT third‑party risk across the entire lifecycle, including due‑diligence, contract negotiation, concentration‑risk analysis, ongoing monitoring, and exit planning. Contracts with ICT providers must include specific clauses around security, audit and access rights, incident reporting, data location, and termination/portability.​


The regulation also requires harmonized registers of third‑party providers and their subcontractors, with clear identification of critical dependencies. ICT third‑party risk is expected to be embedded within the broader ICT risk framework, rather than handled as a separate silo or one‑off procurement exercise.​​


How can ServiceNow support DORA‑aligned vendor and contract oversight?

ServiceNow’s Vendor Risk Management, third‑party risk, and SRM modules allow firms to maintain a centralized inventory of ICT providers, services, contracts, and risk assessments. Risk scoring, questionnaires, and issue‑tracking workflows can be aligned to DORA expectations, while contract records capture required audit, reporting, and exit clauses.​​

For large financial institutions with complex outsourcing chains, ServiceNow provides the breadth to link vendors to CMDB services, incidents, and business processes, enabling end‑to‑end dependency mapping. DataLunix uses EchoViz APIs to export this data into DORA Registers of Information for ICT third‑party providers and critical dependencies.​​


How do HaloPSA, HaloITSM, Freshworks, and ManageEngine help with third‑party monitoring?

HaloPSA and HaloITSM can track external service providers, SLAs, and contracts, making them suitable for MSP‑style environments and smaller financial entities. Freshworks supports integrations and apps for monitoring external SaaS and cloud services, consolidating status and SLA data in a single workspace.​​


ManageEngine’s strength in monitoring and asset inventories provides concrete evidence of third‑party performance and outages that can be linked to vendor records. DataLunix typically standardizes vendor records, SLAs, and incident tags across these platforms to build a unified view of third‑party risk, then maps it into EchoViz’s third‑party register for DORA compliance.​​


How do you operationalize digital resilience testing, TLPT, and DR exercises under DORA?

DORA expects firms to run “sound and comprehensive” digital operational resilience testing programs, from basic vulnerability assessments through to advanced threat‑led penetration testing (TLPT) for significant institutions. The scope must be risk‑based, focusing on critical or important functions and the ICT assets supporting them.​

Disaster‑recovery, business‑continuity, and failover exercises remain essential, with documented plans, clear success criteria, and tracked remediation actions. Supervisors will expect evidence that test results feed into changes, risk registers, and board reporting rather than remaining as static reports.​​


How can ServiceNow, Freshworks, and ManageEngine orchestrate resilience testing?

ServiceNow can manage test campaigns as change or project records, with workflows covering planning, approvals, execution, and remediation tasks. Combined with ITOM and CMDB data, this makes it easier to prove that critical services and their dependencies are within the testing scope.​​


Freshservice and ManageEngine can be used to plan DR tests, track test tickets, and log issues that then transition into change or problem records. DataLunix’s EchoViz solution offers pre‑built testing registers and templates, enabling automated extraction of test metadata (scope, dates, results, remediation status) from these platforms into DORA evidence packs.​​


How can you improve information and intelligence sharing in line with DORA?

DORA promotes participation in information‑sharing arrangements on cyber threats, vulnerabilities, and indicators of compromise, while respecting confidentiality and competition rules. Supervisors expect firms to use shared intelligence to adjust controls, update detection content, and refine scenarios rather than treating it as an inbox feed.​

Enterprise platforms can help distribute relevant intelligence internally, linking it to incidents, problems, and knowledge‑base articles. DataLunix often integrates external ISAC or threat‑intel feeds into ServiceNow or ManageEngine, then uses automation rules to raise advisory tasks, update knowledge articles, or trigger preventive changes.​​


How do collaboration and knowledge features in these platforms support DORA?

ServiceNow, HaloITSM, Freshworks, and ManageEngine all include knowledge bases, major‑incident records, and group workspaces where teams can document patterns, mitigations, and playbooks. When threat‑intel updates are linked to these artifacts, firms can quickly roll out guidance for similar incidents and capture evidence of continuous improvement.​​


From a DORA perspective, this creates a clear audit trail showing how external intelligence flows into internal controls and training, which supervisors will find more convincing than static PDFs. EchoViz can catalog these knowledge and advisory items as part of the broader information‑sharing and resilience evidence set.​​


How do ServiceNow, HaloITSM, Freshworks, and ManageEngine compare for DORA use cases?

Below is a simplified view of how the main platforms align to key DORA‑relevant capabilities for financial entities.


Platform capabilities for DORA‑relevant needs

DORA focus area

ServiceNow (enterprise)

HaloITSM / HaloPSA

Freshworks (Freshservice)

ManageEngine

ICT risk management & CMDB

Deep CMDB, discovery, service‑mapping, and GRC for large banks and insurers, ideal for complex DORA risk frameworks.​​

ITSM with CMDB and workflows tailored to mid‑market financial institutions seeking proportional governance.​​

ITSM with service catalog and asset tracking for growing institutions modernizing from legacy tools.​​

Strong CMDB and ITOM tools (OpManager, Applications Manager) for infrastructure‑centric risk visibility.​​

Incident management & DORA reporting

Advanced major‑incident, problem, and automation capabilities that can generate regulator‑ready incident packs.​​

Efficient ticketing and escalations for smaller/regional entities needing structured but lean reporting.​​

Modern UI, automation, and AI for improved detection, triage, and service transparency.​​

Tight integration between monitoring and ticketing for early detection and rich technical root‑cause data.​​

Third‑party/vendor risk & contracts

Vendor Risk and SRM modules for DORA‑aligned ICT‑provider oversight and contractual tracking.​

PSA capabilities to track ICT providers, contracts, SLAs, and project‑style engagements.​​

Integrations and apps for tracking external services and SLAs in a unified workspace.​​

Asset and service inventories plus monitoring metrics to evidence third‑party performance and outages.​​

Resilience testing & DR exercises

Workflows to plan, approve, and document DR tests, TLPT support, and remediation follow‑up.​

Project/change workflows to coordinate test activities for smaller operations.​​

Task and change management for technical and user‑acceptance tests on key services.​​

Native tools for failover tests, configuration rollbacks, and validating infrastructure resilience.​​

DataLunix uses this positioning to guide clients toward the most suitable platform or combination, depending on their scale, complexity, and existing investments. EchoViz then provides a consistent, regulation‑aligned data layer on top of whichever tools are selected.​


What realistic DORA scenarios should you design for?

One common scenario is a payments outage caused by a critical SaaS provider. Under DORA, your ITSM stack (for example, ServiceNow or Freshworks) should detect the incident quickly, route it as a major incident, trigger comms to business and risk teams, and capture full timelines and impact metrics for regulatory reporting.​​


Another scenario involves a cloud data‑center disruption impacting multiple critical services simultaneously. Here, CMDB service maps, DR runbooks, and TLPT‑informed scenarios help teams execute failover plans, while vendor‑risk modules track provider performance and contractual remedies. DataLunix typically encodes these scenarios into workflows, dashboards, and EchoViz registers to ensure repeatability.​​


How should you apply proportionality when choosing platforms and operating models?

DORA allows proportional implementation based on size, nature, and risk profile, which is essential for smaller banks, insurers, and fintechs. Using the same operating‑model blueprint, a large bank might implement enterprise‑grade ServiceNow plus extensive GRC modules, while a mid‑market lender uses HaloITSM or ManageEngine with carefully scoped processes.​​


Proportionality does not mean “light‑touch”; supervisors will still expect clear governance, coherent registers, and evidence of resilience testing. DataLunix focuses on right‑sizing capabilities—such as using simpler workflows, targeted automations, and curated data models—so smaller institutions can meet expectations without unsustainable overhead.​​


What is the shared‑responsibility model between financial entities and ICT providers?

DORA makes it clear that outsourcing ICT services does not transfer responsibility for resilience and compliance. Financial entities remain accountable for their DORA obligations, even when using globally recognized platforms or cloud providers.​


Vendors increasingly publish “DORA‑readiness” documentation and shared‑responsibility models, explaining which controls they provide and what customers must implement. Partners like DataLunix help institutions interpret these materials, configure platforms accordingly, and document the division of responsibilities in both internal policies and external contracts.​​


What should your first 90 days of DORA resilience modernization look like?

A practical 90‑day roadmap is essential now that DORA is fully applicable. The steps below reflect how DataLunix typically structures an initial engagement for financial entities and critical ICT providers.​


How do you assess your current state and priorities?

  • Map your critical and important functions, supporting services, and ICT assets using existing CMDBs and monitoring tools, even if imperfect.​

  • Perform a high‑level gap assessment across the five pillars, focusing on governance, data completeness, and evidence generation rather than only policies.​​

  • Identify “hotspots” where fragmented tooling, manual reporting, or unclear ownership could jeopardize DORA compliance or resilience outcomes.​


How do you align DORA requirements with your ITSM and ITOM stack?

  • For each pillar, map DORA requirements to specific capabilities in ServiceNow, HaloITSM, Freshworks, and ManageEngine, noting where configuration or integrations are needed.​​

  • Prioritize incident management/reporting and ICT third‑party risk first, as these areas are highly visible to supervisors and customers.​

  • Define a target operating model that specifies roles, workflows, data standards, and platform responsibilities rather than focusing solely on new tools.​


How do you deliver quick wins while building a long‑term roadmap?

  • Implement standardized incident categories, major‑incident workflows, and DORA‑aligned fields in your ITSM platform within weeks, not months.​​

  • Stand up a basic ICT asset and third‑party register by consolidating existing data into EchoViz or a similar model, then improve quality iteratively.​​

  • Design a 12‑month roadmap that expands into advanced testing, integrated vendor‑risk management, and board‑level dashboards, with measurable “return on resilience” metrics.​​


DataLunix’s EchoViz framework is purpose‑built to accelerate this journey by providing pre‑defined information models, registers, and integration patterns for DORA and similar frameworks. Combined with hands‑on expertise across ServiceNow, HaloITSM, Freshworks, and ManageEngine, this allows institutions to move from reactive compliance to proactive, intelligence‑driven resilience.​


FAQ

How does the DORA Regulation differ from other EU cyber frameworks?

DORA focuses specifically on financial entities and their ICT providers, with detailed obligations for operational resilience rather than general data protection or cybersecurity. It complements, rather than replaces, frameworks like NIS2 and GDPR, and often requires aligning multiple regimes within a single operating model.​


Does the DORA Regulation apply to non‑EU ICT providers?

Yes, non‑EU ICT providers can be designated as critical if they support EU financial entities, bringing them under the ESAs’ oversight regime. Even when not designated critical, these providers must sign DORA‑compliant contracts and cooperate with risk‑management and testing expectations.​


Can smaller institutions use HaloITSM, Freshworks, or ManageEngine to comply with the DORA Regulation?

Smaller banks, fintechs, and insurers can absolutely use tools like HaloITSM, Freshservice, and ManageEngine to implement proportional, DORA‑aligned processes. The key is designing fit‑for‑purpose workflows, data models, and integrations rather than copying large‑bank templates.​​


How does DORA impact cloud and SaaS contracts?

DORA requires specific contractual clauses covering security, logging, audit rights, data location, incident notifications, and exit strategies for ICT and cloud providers. Financial institutions should systematically review and renegotiate key contracts, using vendor‑risk tools to track compliance and gaps.​​


Why should we work with DataLunix on DORA Regulation programs?

DataLunix combines deep ITSM/ITOM expertise across ServiceNow, HaloITSM, Freshworks, and ManageEngine with a dedicated EchoViz framework designed for DORA and similar regimes. This allows your teams to translate complex regulatory language into concrete, platform‑backed workflows and data structures that supervisors can verify in practice.​


What should you do next with the DORA Regulation?

If you lead IT, security, risk, or operations in a DORA‑in‑scope institution—or support them as an ICT provider—your next move is to turn regulatory text into an actionable, platform‑backed operating model. Start by mapping your current tools and processes across the five pillars, then prioritize two or three high‑impact use cases such as major‑incident handling and ICT third‑party oversight.​


From there, engage DataLunix and EchoViz to co‑design a DORA‑aligned architecture on top of ServiceNow, HaloITSM, Freshworks, or ManageEngine, with a clear 90‑day plan and a 12‑month roadmap. This approach not only reduces regulatory risk and potential sanctions but also strengthens your organization’s digital trust, customer confidence, and long‑term resilience.​

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