DORA Article 16: Who Qualifies for the Simplified Framework
DORA Article 16 exempts four named entity types from Articles 5-15, but not from incident reporting, testing, or third-party rules. Updated October 2026.
Practical guides, regulatory news, and analysis for compliance teams working through DORA. Sourced and dated, like everything else on this site.
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DORA Article 11 requires a business impact analysis, RTO/RPO targets, and annually tested continuity and disaster recovery plans. Updated October 2026.
Read guideOctober 12, 2026
DORA Article 16 exempts four named entity types from Articles 5-15, but not from incident reporting, testing, or third-party rules. Updated October 2026.
How to classify a critical or important function under DORA, and what changes once you do: contracts, exit strategy, notification. Updated September 2026.
The ESAs' Autumn 2026 risk update (23 September 2026) warns on non-EU ICT provider dependency and AI-accelerated cyber risk, pointing back to DORA's third-party risk and ICT risk management rules.
The EU Digital Omnibus proposes routing DORA incident reports through one ENISA portal shared with NIS2 and CER. Updated September 2026.
The EBA's 18 September 2026 Guidelines extend a DORA-style third-party risk framework to non-ICT services for banks, with a two-year transition. Published September 2026.
EIOPA's 2026 work programme puts insurers' ICT registers, incident classification, and third-party governance under scrutiny. Updated September 2026.
DORA Articles 24-25 require a testing programme from vulnerability scans to penetration tests, annually for critical ICT systems. Updated September 2026.
DORA Article 6 requires eight documented policies, from asset identification to crisis communication, not one combined risk policy. Updated August 2026.
DORA Article 30 lists the mandatory clauses every ICT contract needs, with a stricter tier for critical or important functions. Updated August 2026.