Understanding the Fifth Chapter of DORA

The Digital Operational Resilience Act (DORA), introduced by the European Union, is a critical piece of legislation designed to strengthen the operational resilience of financial entities in the face of growing digital threats. Within this framework, Chapter 5 stands out as a key component, focusing specifically on the oversight of third-party Information and Communication Technology (ICT) service providers. This chapter is crucial as it ensures that the external partners financial entities rely on are held to the same stringent standards of security and resilience as the entities themselves.

The Oversight Framework for ICT Third-Party Providers

Chapter 5 of the DORA Act is dedicated to the establishment of an oversight framework for critical ICT third-party service providers. These providers, which supply essential services to financial institutions, play a vital role in the sector’s digital infrastructure. Given their importance, the DORA Act mandates that these third-party providers are subject to strict oversight to ensure they adhere to the necessary security and resilience standards.

Key Provisions:

  1. Oversight Authority: Chapter 5 empowers designated oversight authorities to monitor and assess the activities of critical ICT third-party providers. These authorities are responsible for ensuring that these providers comply with the same operational resilience standards required of financial entities.
  2. Risk Management Requirements: Third-party providers must implement robust risk management practices. This includes identifying and mitigating potential risks that could impact the services they provide to financial entities. The providers are expected to have security measures that are at least equivalent to those of the financial entities they serve.
  3. Right to Audit: Financial entities are granted the right to audit their critical ICT third-party providers. This provision ensures that financial entities can verify that the third-party providers are meeting the required standards. The audits can include reviewing security controls, resilience measures, and any incidents that may have affected service delivery.
  4. Self-Assessments: ICT third-party providers are required to conduct regular self-assessments of their security and resilience measures. These self-assessments help in identifying any gaps or weaknesses in their systems, allowing them to take proactive steps to address these issues.
  5. Audit Reports: Financial entities can request audit reports from their ICT third-party providers, including SOC II Type 2 reports and Information Security Management System (ISMS) Statements of Applicability (SoA). These reports provide an in-depth look at the provider’s controls and practices, giving financial entities greater assurance of their reliability.
  6. Enforcement and Penalties: The oversight authorities are empowered to take enforcement actions if third-party providers fail to meet the required standards. This can include penalties, restrictions on services, or other measures designed to protect the integrity of the financial sector.

 

Practical Implications for Businesses: Managing Third-Party ICT Risk

The requirements outlined in Chapter 5 have far-reaching implications for both financial entities and their ICT third-party providers. The chapter’s focus on third-party risk management underscores the importance of ensuring that external service providers are as secure and resilient as the financial institutions they support.

  1. Strengthening Third-Party Risk Management:

Financial institutions must enhance their third-party risk management strategies to comply with Chapter 5. This involves not only selecting ICT service providers that meet high standards of security and resilience but also continuously monitoring and assessing these providers. Regular audits and assessments become essential tools in this process, allowing financial entities to verify that their providers are maintaining the required standards.

  1. Ensuring Compliance through Audits:

The right to audit, as granted under Chapter 5, is a powerful tool for financial entities. By conducting audits, financial institutions can gain direct insights into the security and operational practices of their ICT third-party providers. These audits should be thorough, covering all aspects of the provider’s operations that could impact the financial entity. This includes reviewing security controls, incident response plans, and business continuity measures.

  1. Leveraging Self-Assessments and Audit Reports:

ICT third-party providers are expected to conduct regular self-assessments and provide detailed audit reports upon request. Financial entities should actively seek these reports, as they offer valuable information on the provider’s adherence to security and resilience standards. Specifically, SOC II Type 2 reports and ISMS SoA documents are crucial as they outline the provider’s control environment and how it aligns with industry standards.

  1. Enhancing Governance and Oversight:

For financial entities, Chapter 5 emphasises the need for strong governance over third-party relationships. Senior management and boards of directors must be involved in overseeing third-party risk management activities. This includes reviewing audit findings, assessing the effectiveness of third-party controls, and ensuring that any identified risks are promptly addressed.

  1. Preparing for Regulatory Scrutiny:

Given the oversight powers granted to regulatory authorities under Chapter 5, both financial entities and their ICT third-party providers must be prepared for potential scrutiny. This includes having all necessary documentation and evidence of compliance readily available. Providers should be ready to demonstrate their adherence to the required standards, while financial entities must ensure they have conducted sufficient due diligence on their providers.

 

Steps to Ensure Compliance with Chapter 5

To effectively meet the requirements of Chapter 5, financial entities should consider the following steps:

  1. Understand the Criteria: The European Supervisory Authorities (ESAs) have specified criteria for designating ICT third-party service providers as critical, which includes: systemic impact of a failure; the importance of the functions supported; and the number of important institutions relying on the provider.
  2. Gain assurance from ICT third-party providers: Financial entities must ensure that their ICT third-party providers comply with DORA’s requirements. This includes managing ICT risks, ensuring continuity and recovery, and reporting incidents2.
  3. Consider Oversight Fees: The ESAs have also proposed oversight fees for critical ICT third-party providers, which are calculated based on the turnover of the critical ICT third-party service provider. These fees cover the costs of monitoring and ensuring compliance.

 

Meet Our Leadership Team.

At CRMG, our senior leadership team brings a rich history and deep expertise in cyber security. Spearheaded by consultants who are influential figures in the industry, our leaders are highly networked and well-established, with backgrounds in the ‘Big- Four’ firms.

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Simon Rycroft

CO-FOUNDER AND CEO

Former Head of Consulting at the ISF. On a journey to bring accessible risk management to growing enterprises.

Nick Frost

CO-FOUNDER AND CHIEF PRODUCT OFFICER

Former Group Head of Information Risk, PwC. Motivated by the need to implement cyber risk principles for the real world!

Dan Rycroft

DELIVERY DIRECTOR

Former Head of Delivery, Cyber Security at DXC. Delivers risk-based cyber security programmes with maximum efficiency.

Matt Brett

DELIVERY LEAD – CYBER RISK SOLUTIONS

Former Portfolio Director, Tech Security & Risk, GSK. Specialises in implementing efficient, pragmatic cyber risk solutions.

Martin Tully

DELIVERY LEAD – GOVERNANCE AND COMPLIANCE

Twenty years’ experience in delivering fit-for-purpose cyber governance initiatives.

Ryan Hides

DELIVERY LEAD – THIRD PARTY RISK MANAGEMENT

Project Management and Six Sigma expertise. Specialises in turning effective third party risk management into a scalable reality.

Tom Everard

Director Risk Services

Director of Risk Services with a passion for people-focused cyber security, crisis management, and tackling insider risk.

Rebecca Stanley

Finance Manager

Focussed on ensuring everything continues to run smoothly, Rebecca collaborates across teams and with clients to manage budgets, reporting, and all things finance.

Securing What Matters Most: A Practitioner’s View

Most organisations are doing plenty of cybersecurity. The bigger question is whether they’re securing the right things. As regulatory expectations shift towards demonstrable, risk-based decision-making, understanding what matters most to the business has never been more important.

The Fundamentals Haven’t Changed – The Context Has

I’ve been having versions of this conversation in security for the 25 years I’ve worked in cyber (or what was IT security when I first started in this area), and parts of it will sound familiar. The fundamentals haven’t changed much. What has changed is the context around them, and for me, that’s worth paying attention to.

We still must comply with regulations, standards, and control frameworks, and that isn’t going away, but there’s diminishing value in aligning with controls purely for the sake of compliance, which is something we’ve been pointing out for years, even as we struggle to break away from the well-trodden approach we’ve followed for decades. Regulators, boards, and customers now expect more: evidence of a risk-based approach. They want to see that we know which parts of the business are most critical (ie your minimal viable organisation), what could disrupt them (threat and risk scenarios), and how we’re prioritising security and resilience activity accordingly.

Why Is This Still So Difficult?

That’s the right direction, and we all agree, but it’s hard to do in practice. Why? Because most security functions are still consumed by day-to-day activity, stretched resources and competing priorities. And too often we lack a clear line of sight between what the team is doing and the business processes, services, assets and dependencies that matter most. From my perspective, without that line of sight, risk assessments, penetration testing, control reviews, etc., become too generic, lack strong direction and purpose, or, even worse, focus on areas of the business that just aren’t that critical and may benefit from applying baseline controls.

Cyber Risk Doesn’t Exist in Isolation…

It’s made harder by the fact that cyber risk rarely exists in isolation. The risks we deal with now are hybrid and cut across cyber, technology risk, operational resilience, physical security, third-party management, enterprise risk, compliance, and audit, and yet, many of these functions still report vertically, with little lateral sharing. That makes it genuinely difficult to build a joined-up picture of what’s truly critical, how it’s protected, where the dependencies run, and where we’re most exposed.

The uncomfortable truth is that no one can secure everything to the same standard. So, prioritisation isn’t optional; it’s our job to perform. Yet our assurance effort often follows the wrong triggers. A new application attracts a risk assessment, a pen test, or a code review simply because it’s new, while a mission-critical system that’s underpinned the business for a decade hasn’t been tested in years. The result is a mismatch between where we point assurance and where the real exposure lives.

Start with What Matters Most

The place to start is by identifying the business’s nucleus: the critical services, processes, data, systems, people, and third-party dependencies that must be protected and kept running at all costs. This requires discussion, challenge, and consensus across business, technology, risk, and resilience teams. It won’t be perfect the first time, but skipping it because it’s hard leaves us with no defensible basis for prioritisation at all.

Once we understand what’s most critical, risk assessment starts to earn its keep. The point isn’t to generate another risk register; it’s to work out what could realistically go wrong, how likely it is, what it would cost the business, and which controls we need to prevent, detect, and respond. That’s what connects business criticality to threat exposure, control effectiveness and remediation priorities.

It also gives us a far stronger story to tell regulators, boards, and auditors, which broadly follows a clear line from what matters most to the business, through the risks we’ve identified, to the controls we’ve put in place and the investment we’ve chosen to make. It’s the difference between security as a broad compliance exercise and security as focused business protection.

The Goal

This must ultimately be our goal now in cybersecurity: a cybersecurity programme that’s more practical, more connected, and more targeted. One that’s built around understanding what the business genuinely cannot afford to lose, how those critical services and assets are exposed, and where our time, effort and investment will have the greatest impact. That means moving beyond security activities driven primarily by compliance schedules or technology change and instead focusing assurance where it matters most.

We’ll never have unlimited resources, nor will we ever eliminate every risk. But by establishing a clear line of sight between business criticality, credible threat scenarios and the controls that protect them, we can make better decisions, justify investment more effectively and build resilience where it counts.

This is what good cybersecurity should be about: not trying to secure everything equally, but making informed, defensible decisions that protect what matters most to the organisation.

 

Third-Party Risk Management: The Human Behaviours Behind Persistent Exposure

While third-party risk management frequently appears robust in governance forums, ongoing exposure suggests a more complex reality. This article explores human behaviours that influence the practical management of third-party cyber risk beyond the intentions of formal frameworks.

Third-party risk management (TPRM) is now a well-established discipline within cybersecurity and GRC. Most organisations can demonstrate defined processes, contractual controls, and assurance mechanisms to manage supplier risk, but many still struggle to effectively implement these measures, leaving vulnerabilities that third parties can exploit. Regulatory expectations have further reinforced the need for formal oversight of third parties, particularly in ensuring compliance with data protection laws and industry standards.

Yet incidents involving third parties remain a persistent threat. This suggests the challenge extends beyond framework maturity or technological capability. Human behaviour, organisational culture, and commercial pressures significantly influence the effectiveness of TPRM in practice, shaping the assessment and resolution of risks.

This two-part series explores behavioural dynamics that frequently undermine third-party cyber risk management practices.

The pressure to appear ‘secure’

Third parties operate in competitive environments where demonstrating security maturity has become a commercial necessity. Suppliers therefore face implicit pressure to present themselves as operationally robust, even when controls may still be evolving or inconsistently applied.

As a result, self-assessment questionnaires and maturity declarations can sometimes reflect aspirational practices rather than actual control effectiveness. Cultural factors reinforce this dynamic when internal teams feel compelled to align responses with contractual commitments or service-level agreements (SLAs).

The organisations issuing these questionnaires typically do so in a standardised format designed to streamline the process, recognising they may not have the capacity to review large volumes of supporting evidence or conduct detailed follow-ups with every supplier.

Consequently, customer organisations often rely heavily on declared security postures unless assurance processes include operational validation along with documentation.

Third-party providers may also feel pressure to avoid disclosing operational weaknesses, particularly when doing so could threaten contractual relationships. Without evidence-based validation or contractual audit rights, responses to control-maturity questionnaires may present an overly optimistic view of the security posture.

Ransomware and asymmetric exposure in third-party relationships

Ransomware has become the dominant third-party cyber risk scenario for many organisations. Suppliers often serve as a more accessible point of compromise, particularly when security investment and maturity differ significantly between the customer and the provider.

Compromising a single supplier can also provide attackers with access to multiple client environments, creating the potential for widespread disruptions or simultaneous extortion across several organisations.

The challenge is not purely technical. Cultural and behavioural dynamics also play a part. Suppliers may hesitate to disclose emerging threats or early-stage incidents due to concerns about reputational harm, commercial repercussions, or contractual penalties. At the same time, customer organisations may implicitly expect suppliers to resolve issues independently until escalation becomes unavoidable.

This dynamic discourages early transparency, even though earlier collaboration could significantly reduce the impact of incidents.

In practice, ransomware exposure in third-party relationships can manifest in several ways: service outages, attackers pivoting through trusted connections, weak recovery capabilities, or delayed incident disclosure driven by fear of contractual consequences.

Encouraging more open information sharing requires organisations to move beyond purely compliance-driven oversight to shared risk ownership. Maturity-based assessments, collaborative exercises, shared threat intelligence, and environments that encourage early disclosure all contribute to stronger relationships and greater resilience.

Criticality, certification and misplaced assurance

Tiering suppliers by criticality is a common feature of mature TPRM programmes. Certifications and third-party attestations are frequently used as indicators of security maturity within these tiers.

However, certifications are ultimately interpreted and implemented by individuals. The presence of a recognised standard can therefore create a sense of assurance that does not always reflect the real risk associated with a specific service, environment, or delivery model. Over time, this can lead to reduced scrutiny of suppliers whose formal credentials appear strong, even when operational exposure remains significant.

A graduated approach to attestation enables suppliers to provide assurance proportional to their criticality. Subsequently, high-impact suppliers must demonstrate stronger control maturity and provide more substantial supporting evidence, while lower-criticality suppliers are subject to proportionately lighter assurance requirements. This tiered approach aligns oversight with risk while avoiding unnecessary burden on smaller vendors.

Relationships, legacy, and reduced scrutiny

Long-standing supplier relationships, particularly those supported by strong personal connections at senior levels, often benefit from a degree of trust not afforded to newer providers. Over time, this trust can reduce the frequency or depth of security scrutiny.

This rarely reflects deliberate negligence. Instead, it demonstrates how human relationships influence organisational behaviour. Although governance frameworks may mandate consistent oversight, in practice, scrutiny is seldom applied uniformly across all suppliers.

Legacy contracts can further increase exposure. Many were written before today’s cyber, operational, and regulatory expectations existed and therefore lack modern security clauses, clear incident-reporting requirements, defined recovery obligations, or meaningful audit rights. These gaps can leave organisations with limited leverage during an incident.

A clear example occurred in mid-2023 when a zero-day vulnerability in MOVEit Transfer, a widely used secure file-transfer product, was exploited by the Clop ransomware group. Attackers breached servers operated by hundreds of service providers, exposing sensitive data belonging to thousands of organisations that had no direct relationship with the compromised software.

“The greatest enemy of knowledge is not ignorance, it is the illusion of knowledge.” — Daniel J. Boorstin.

The continued presence of third-party cyber risk does not necessarily indicate that frameworks are ineffective. Instead, it highlights how behavioural dynamics and organisational incentives shape how those frameworks operate in practice.

Many of the most significant drivers of exposure sit outside formal processes and control structures. For boards and senior leaders, it is essential to recognise that human behaviour fundamentally shapes the effectiveness of third-party risk management.

Part 2 will explore how these behavioural dynamics influence real-world resilience when critical third parties experience cyber incidents or operational disruptions.