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DORA Auditor

DORA Incident Response Planning

Last updated: 3 authoritative sourcesDORA Auditor Editorial Team

DORA incident response planning establishes the processes a financial entity uses to detect, manage, classify, and report major ICT-related incidents under Articles 17–23. A tested plan is what lets an entity meet DORA's strict reporting deadlines under pressure.

What the plan must enable

The plan defines detection and triage, the criteria that make an incident major, escalation paths, and the three-stage reporting flow (initial, intermediate, and final report) to the competent authority. Use our incident classifier to check whether a given incident is reportable.

Testing and roles

Response plans should be exercised regularly and integrated with the ICT risk-management framework and business-continuity arrangements, with clear roles across ICT, compliance, and the management body.

Where incident reporting infrastructure is heading

Article 21 requires the ESAs to look beyond today's reporting flow and assess whether incident reports should ultimately move through a single EU channel rather than each entity notifying its own competent authority. In a joint report submitted to the European Parliament, the Council, and the Commission in January 2025, the ESAs concluded that further centralisation, including a single EU hub for major-incident reports, is feasible and would bring benefits such as more consistent data and less duplicated effort across authorities, but also raises risks from concentrating sensitive incident data in one place that a future design would need to control for. The report set out three models, from a lightly modified version of today's flow through to full centralisation, and found only the lightest-touch option realistic in the short term, within three years of DORA's January 2025 application date. For entities building or refreshing a response plan now, the practical takeaway is that the three-stage reporting flow described above is the process to design against today; a more centralised EU channel is a medium-term direction, not a near-term change to plan for. The same centralisation question resurfaced in the European Commission's November 2025 Digital Omnibus package, which proposes routing DORA incident notifications through a shared EU-wide portal alongside NIS2 and other regimes, see our analysis of that proposal for where it currently stands.

Frequently asked questions

What are DORA's incident reporting deadlines?
How do I know if an incident is reportable?
Does DORA require incident response testing?
Will DORA incident reports eventually go to a single EU authority instead of national regulators?

Sources

  1. Regulation (EU) 2022/2554 (DORA), EUR-Lex
  2. ESMA, Digital Operational Resilience Act (DORA)
  3. European Banking Authority, DORA