The German Federal Financial Supervisory Authority (BaFin) has published a detailed overview to help financial entities meet documentation requirements under the European Union’s Digital Operational Resilience Act (DORA), which took effect on January 17, 2025.
DORA aims to strengthen the cybersecurity and operational resilience of the EU financial sector by introducing uniform rules on managing information and communication technology (ICT) risks. BaFin’s new two-page overview outlines the minimum documentation obligations required by DORA and its related regulatory and implementing technical standards (RTS and ITS).
While the guidance is designed to simplify compliance, BaFin clarified that using the overview is voluntary and does not replace legal obligations. The document organizes requirements by DORA’s structure, mapping policies, procedures, and reporting expectations across key areas such as ICT risk management, incident reporting, and third-party oversight. It highlights where specific documents are required and provides references to corresponding chapters and articles.
However, BaFin’s overview stops short of prescribing content or format for required documents. Companies are expected to prepare materials in a clear and comprehensive manner, applying the proportionality principle outlined in Article 4 of DORA. Additional documentation may also be necessary in some cases, depending on an organization’s size and complexity.
BaFin emphasized that the guidance is intended as a practical tool, particularly for supervised financial institutions, but it does not constitute a binding interpretation of the regulation. For firms operating across the EU, the overview provides a structured starting point for navigating DORA’s extensive technical requirements and ensuring alignment with the new regulatory framework.
The full documentation overview and supporting guidance are available for download on BaFin’s website.
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