DORA ICT Third-Party Risk, Built Into Your Workflow.
RegAhead operationalises the Digital Operational Resilience Act's ICT third-party risk requirements — Articles 28 to 44 — turning the Register of Information, Article 30 contractual obligations, concentration risk, and sub-outsourcing controls into a live, audit-ready workflow inside PartnerHub.
Key takeaways
- Operationalises DORA ICT third-party risk (Chapter V, Articles 28–44).
- Maintains the Register of Information and maps Article 30 contractual provisions.
- Analyses concentration risk and sub-outsourcing exposure.
- DORA has been fully applicable since 17 January 2025.
What DORA Requires — and Where Third-Party Risk Sits
The Digital Operational Resilience Act — Regulation (EU) 2022/2554 — has been fully applicable across EU financial services since 17 January 2025. It harmonises digital operational resilience across five pillars: ICT risk management, ICT-related incident reporting, digital operational resilience testing, ICT third-party risk management, and information sharing.
It applies to more than 20 categories of financial entities — banks, insurers, investment firms, payment and e-money institutions, crypto-asset service providers, and more — and, critically, extends to their ICT third-party service providers.
- Articles 28–30 (Section I): management of ICT third-party risk, the Register of Information, pre-contractual assessment, and mandatory contractual provisions (Article 30)
- Articles 31–44 (Section II): EU oversight of Critical ICT Third-Party Providers (CTPPs) — designation, Lead Overseer, and supervisory powers
- Concentration-risk analysis and sub-outsourcing controls
- Supervisory access and resilience testing alignment
How RegAhead Maps to DORA
| DORA Requirement | How RegAhead Operationalises It | Module |
|---|---|---|
| Register of Information (Art. 28) | Maintained ICT third-party register with provider, function, criticality and contractual metadata — examination-ready | PartnerHub |
| Pre-contractual assessment & due diligence (Art. 28–29) | AI-led due diligence, materiality tiering, and risk assessment before commercial commitment | PartnerHub |
| Contractual provisions (Art. 30) | Contract-clause mapping and document analysis confirming SLA, security, data-protection, audit and exit terms | PartnerHub |
| Concentration risk (Art. 29) | Automated concentration-exposure analysis against thresholds across the ICT provider estate | PartnerHub |
| Sub-outsourcing chains | Fourth-party / sub-outsourcing tracking with dependency mapping and monitoring | PartnerHub |
| Supervisory & oversight access (Art. 31–44) | Auditor / supervisor read-only views and clause-traceable evidence for the Lead Overseer regime | PartnerHub |
| Regulatory change (RTS / ITS) | RegWatch ingests EBA/EC technical standards and flags affected controls automatically | RegWatch |
| Group-level ICT governance | Consolidated DORA posture and concentration aggregation across the financial conglomerate | ReGroup |
Primary sources: Regulation (EU) 2022/2554 on EUR-Lex and the European Supervisory Authorities (e.g. eba.europa.eu). This page is an implementation reference, not legal advice.
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