“DORA is not just regulation—it’s a signal that digital resilience has become a prerequisite for insurability.”

4/27/2026

The digital operation of the financial sector is no longer a competitive advantage — it is a condition for existence. Payments, trading systems, customer services, risk management — all rely critically on ICT. In this environment, one thing has become clear: Traditional IT security is no longer enough.

For years, ICT risk management focused on prevention:

  • avoiding cyberattacks
  • preventing data loss
  • blocking unauthorized access

But digital transformation has fundamentally changed the question: It is no longer whether an incident will occur — but how well you can survive it.

Financial institutions now operate in complex, interdependent ecosystems, heavily reliant on third-party providers. A single disruption can trigger systemic consequences.

“From an underwriting perspective, the question is no longer whether an incident happens—but whether the institution can absorb and recover from it.”

Before DORA:

  • regulatory expectations were fragmented
  • national approaches differed
  • systemic digital risk was not consistently addressed

At the same time, major incidents in the early 2020s revealed a critical truth: Digital vulnerability is not an institutional issue — it is systemic.

This led to the creation of the Digital Operational Resilience Act (DORA), which:

  • establishes a unified EU framework
  • is directly applicable (not a directive)
  • targets the digital stability of the financial system

DORA is not another compliance exercise. It is a regulatory recognition that digital operations are now critical infrastructure.

The 5 Pillars of DORA

  • ICT Risk Management: Structured, management-driven frameworks
  • Incident Management & Reporting: Standardized classification and escalation
  • Resilience Testing: Including threat-led penetration testing (TLPT)
  • Third-Party Risk Management: Stronger control over ICT providers
  • Information Sharing Strengthening collective resilience

The common denominator: Maintaining operations even under extreme digital stress

Ádám Kalina
Chief Underwriting Officer, Hungarian branch