DORA in the Fintech Sector: Understanding the Digital Operational Resilience Act and the DORA Register of Information

The Digital Operational Resilience Act (DORA) is one of the most significant regulations to impact the European financial and fintech sector in recent years. As financial services continue shifting to the digital space, dependency on cloud providers, APIs, and external IT infrastructures creates new risks. Cybersecurity incidents, ICT failures, or third-party outages can directly affect millions of customers and the financial system’s stability. To address these challenges, the European Union has introduced DORA, together with the DORA Register of Information, as a harmonized framework for operational resilience.

This article explores the importance of DORA, its impact on the fintech sector, and why the Register of Information is a critical compliance requirement.

What is the Digital Operational Resilience Act (DORA)?

The Digital Operational Resilience Act, commonly known as DORA, was adopted in January 2023 as part of the EU’s Digital Finance Package. It has been enforceable since January 2025, giving financial institutions and fintech companies a unified set of rules across the EU for how they must prepare for and manage ICT risks.

DORA focuses on five key areas:

• ICT Risk Management – Strong governance structures to detect, prevent, and mitigate ICT incidents.
• Incident Reporting – Standardized requirements to report major incidents to regulators in a timely manner.
• Resilience Testing – Penetration testing, scenario-based stress testing, and audits to prove readiness.
• Third-Party Risk Oversight – Clear contractual and operational requirements for outsourcing ICT functions.
• Information Sharing – Secure sharing of cyber threat intelligence within the financial ecosystem.

This broad scope ensures that banks, insurance firms, crypto exchanges, trading venues, and fintech startups are aligned under one EU-wide operational resilience standard.

DORA and the Fintech Sector

The fintech industry has rapidly transformed the way consumers interact with money, from digital wallets and mobile banking to peer-to-peer lending and cryptocurrency services. However, this digital-first approach also makes fintechs highly reliant on external ICT providers, such as cloud services, cybersecurity vendors, and data processors.

For fintechs, DORA introduces both challenges and opportunities:

• Challenges: Smaller startups may face higher compliance costs, as they will need to formalize risk frameworks, negotiate stricter contracts with ICT providers, and implement regular resilience testing.
• Opportunities: Early and thorough compliance can serve as a competitive differentiator, demonstrating to customers and investors that the company is secure, trustworthy, and aligned with EU financial standards.

Ultimately, DORA compels fintechs to embed cyber resilience into their core operations, rather than treating it as an afterthought.

The DORA Register of Information Explained

Among DORA’s most practical obligations is the Register of Information on ICT third-party arrangements. This register is not optional—it is a mandatory compliance tool designed to bring transparency to how financial and fintech firms use ICT providers.

What the Register Must Include

The Register of Information should contain detailed records of:

• All ICT-related contracts with third-party providers.
• Classification of critical vs. non-critical providers.
• Subcontracting and supply chain structures.
• Data processing and storage locations (including cross-border risks).
• Exit strategies and contingency planning.

Why It Matters

The Register of Information helps regulators identify systemic risks. For example, if several banks and fintechs depend on a single cloud provider, any outage could disrupt the entire sector. By maintaining this register, fintechs also gain better control of their own vendor risks, ensuring they have alternatives if a provider fails.

Failure to maintain an up-to-date register could lead to fines, reputational damage, and regulatory penalties. On the other hand, well-prepared companies will demonstrate operational resilience and regulatory alignment.

Preparing for DORA Compliance in Fintech

With DORA now in force, fintechs should ensure they have:

• A robust ICT risk management framework overseen by the board.
• A full review of third-party vendor contracts to ensure compliance with DORA requirements.
• A maintained DORA Register of Information with complete and accurate records.
• Resilience testing such as penetration tests and scenario simulations.
• Staff training on incident response protocols and regulatory reporting standards.

If you want to manage these tasks in one place, CyberUpgrade can help centralize DORA compliance activities—from vendor oversight and the Register of Information to incident workflows—without adding heavy operational overhead.

Conclusion

The Digital Operational Resilience Act (DORA) represents a major shift in how financial services approach ICT risk management. For the fintech sector, it is both a compliance obligation and an opportunity to strengthen trust and long-term stability. The introduction of the DORA Register of Information ensures transparency in third-party ICT arrangements and provides regulators with the tools to monitor systemic risks.

As fintech continues to expand, operational resilience will become a competitive edge, not just a legal requirement. Companies that maintain strong controls and documentation will be better equipped to thrive in a digital financial ecosystem where security and reliability are essential.