Cloud Resilience Assessment for DORA
A cloud resilience assessment evaluates the operational and concentration riska financial entity carries from its cloud and other ICT providers under DORA's third-party risk pillar. Cloud is often the largest single source of ICT third-party dependency.
What the assessment reviews
It examines which cloud services support critical or important functions, contractual coverage of access, audit and exit rights, sub-outsourcing chains, and whether over-reliance on one provider or region creates concentration risk. Findings feed the register of information.
Why it matters under DORA
Cloud providers that are designated critical ICT third-party providers fall under a new EU oversight framework, and financial entities remain accountable for managing their exposure, including credible exit strategies.
Spotting single points of failure
A cloud resilience assessment looks past the concentration-risk question of how many providers an entity uses and asks a narrower one: does any single component, region, or provider have no working alternative if it fails? A single point of failure can be a cloud region with no failover pair, a key-management service run by one operator, or a sub-processor buried three layers into a subcontracting chain nobody mapped. Article 29 requires this kind of assessment before and during outsourcing, and the same logic drives which providers get designated for direct EU oversight: a provider that is a single point of failure for many entities at once is a systemic risk, not just the assessed entity's own problem. A useful test during the assessment is substitutability: if this cloud arrangement failed today, how long would restoring the service actually take, and does that match the recovery time objective already set for the function it supports.
Frequently asked questions
Does DORA regulate cloud providers directly?
Cloud providers designated as critical ICT third-party providers are subject to direct EU oversight; others are managed through the financial entity's contracts and controls.
What is a single point of failure in a cloud resilience assessment?
Any component, region, or provider whose failure alone would disrupt a critical function with no working alternative in place, for example a cloud region with no failover pair or a key-management service run by one operator. See the glossary definition.
What is concentration risk under DORA?
Risk arising from over-reliance on a single ICT provider or a small number of providers. See the glossary definition.
Does DORA require a cloud exit strategy?
Yes. Contracts for critical or important functions must include documented exit strategies and transition arrangements.