DORA Compliance Guide: 5 Key Challenges and How to Address Them

Digital Operational Resilience Act (DORA) compliance has become a critical priority for financial and insurance institutions across Europe. Even though the implementation deadline has passed, many organizations still face significant challenges in meeting these new regulatory requirements.

This comprehensive guide examines the top 5 DORA compliance challenges and provides practical solutions for banks, insurance companies, and investment firms operating in the EU.

Challenge 1: When Standard Operating Procedures Meet Operational Reality

DORA mandates that Standard Operating Procedures (SOP) meet specific requirements for data processing (e.g. checks and approvals). At a glance, it seems like something finance and insurance companies already do: document steps, protect client data, and ensure protocols are met.

Yet we all know under tight deadlines and pressure to meet performance demands, employees may rely on efficiency shortcuts like skipping optional validations or using unauthorized tools for faster execution.

The challenge for you? These ‘shortcuts’ do not appear in your SOPs, even though they happen more often than many would like to admit.

It’s far beyond employee shortcuts – it’s about the natural evolution of operations meeting real-world demands. These undocumented variations create a dangerous blind spot in your DORA compliance. While your documentation suggests perfect adherence to ICT risk management frameworks, the reality could harbor dozens of unauthorized process variants.

Bridging the Gap: Continuous Process Intelligence

Modern financial institutions are embracing a fundamental shift in compliance monitoring. Rather than relying on periodic checks, they implement continuous process intelligence to maintain real-time visibility (as well as an additional layer of documentation) into their operations.

This approach reveals:

Actual process execution patterns versus documented SOPs

Unauthorized process variations as they emerge

Hidden compliance risks in real-world operations

Process efficiency opportunities within compliance boundaries

The key lies in automated, continuous process intelligence, which captures the ground truth of your operations. By maintaining constant visibility into actual process execution, organizations can:

Detect and assess process variations in real-time

Understand why variations occur and their impact on compliance

Identify necessary SOP updates based on operational realities

Maintain continuous evidence of compliance adherence

This intelligence-driven approach transforms compliance from a documenting exercise to an operational advantage. It provides the visibility needed to ensure both operational efficiency and regulatory compliance. It helps employees gain efficiency while staying compliant DORA regulations.

Moving Forward: From Documentation to Intelligence

The path to true DORA compliance requires moving beyond static documentation. Financial institutions need real-time visibility into their actual operations. With process intelligence, you can bridge the gap between SOPs and reality, find new efficiencies, and hone a competitive advantage.

After all it’s about understanding and managing the dynamic nature of modern financial operations while maintaining regulatory compliance.

Challenge 2: The Multi-Tool Maze – When Software Sprawl Meets Compliance

Walk through any financial or insurance institution’s operations floor. You’ll find authorized enterprise systems running alongside a shadow universe of productivity tools.

Each unauthorized tool represents a concern for your ICT risk management framework. Every unmonitored application could be the weak link in your operational resilience.

Traditional software asset management falls short. Annual license audits can’t capture the dynamic nature of modern tool usage. Security scans might detect installed applications but miss cloud-based tools. Meanwhile, the technology landscape evolves weekly, introducing new risks and compliance gaps.

From Simple Tool Control to Real-Time Intelligence

Progressive financial institutions are adopting a more sophisticated approach to tool compliance. Instead of periodic inventories, they implement continuous software usage intelligence that reveals:

Actual patterns of application usage across operations

Interactions between authorized and unauthorized tools

Data flow patterns between applications

Process-tool relationships and dependencies

This intelligence-driven approach transforms tool compliance from a checklist exercise into operational insight. It provides the visibility needed to:

Detect unauthorized tool adoption in real-time

Understand why teams seek alternatives to approved solutions

Identify gaps in official tooling that drive shadow IT

Maintain continuous compliance with DORA’s ICT requirements

The key lies in understanding tool usage in the context of business processes. Rather than focusing solely on application inventory, modern process intelligence platforms provide:

Real-time visibility into tool usage patterns

Process context for application adoption

Risk assessment of tool interactions

Compliance impact analysis of software usage

This contextual understanding allows organizations to:

Maintain compliance without stifling innovation

Guide teams toward approved alternatives

Identify opportunities for tool consolidation

Build a more resilient operational technology stack

Managing tool compliance in modern financial operations requires more than restrictive policies. It demands intelligent monitoring that understands the relationship between processes, workforce, and technology.

Challenge 3: The Mirage of Manual Compliance Monitoring – When Human Eyes Aren’t Enough

Think of monitoring compliance manually as trying to track every raindrop in a storm. Your compliance teams work tirelessly – reviewing logs, checking processes, validating controls. Yet between each check, between each audit, between each validation, countless operations flow through your systems unmonitored.

Morning arrives. Compliance analysts review yesterday’s transaction logs. By noon, they’re investigating process exceptions. The afternoon brings compliance reports. Evening closes with documentation and planning tomorrow’s checks. By the time your team finishes reviewing Monday’s operations, Tuesday’s potential violations are already history. This reactive approach creates a dangerous illusion of effectiveness.

Where Traditional Monitoring Falls Short

Critical process deviations lurk undiscovered for days or weeks. Compliance checks capture moments, not continuous operations. Your teams exhaust themselves preparing for audits instead of monitoring active risks. Sampling-based reviews miss crucial exceptions that multiply in the shadows.

In the age of digital operations, manual monitoring simply cannot keep pace with the velocity and volume of modern financial activities.

Beyond Periodic Checks

Forward-thinking enterprises embrace continuous compliance monitoring. They transform oversight from periodic snapshots to real-time intelligence. Modern platforms provide immediate visibility into compliance status. Violations trigger instant alerts. Documentation generates automatically. Risk assessment never sleeps.

Automated monitoring doesn’t replace human expertise – it amplifies it. Technology handles the routine, the repetitive, the continuous. Meanwhile, compliance professionals focus their expertise where it matters most: strategic risk assessment, pattern analysis, control framework improvement, and proactive risk mitigation.

Your compliance teams stop chasing yesterday’s data. Instead, they shape tomorrow’s resilience. They move from data collectors to strategic advisors. From reactive firefighters to proactive architects of operational integrity.

Many companies have already embraced an automated approach to compliance monitoring. Instead of on-demand audits, they capture end-to-end workflows at scale to see:

A digitized SOP that shows each step of every process

All variants that violate the SOP

Prioritization of variants by volume of occurrences

Pre and post process steps

Training or best practices gaps to leverage

This next-gen intelligence helps organizations to:

Identify automation and AI potential opportunities to increase efficiency and cost of compliance monitoring

Optimize pre-and-post SOP workflows

Proactively detect and address compliance risks before they become violations

Standardize processes across departments to ensure consistent compliance adherence

From Manual to Intelligent Monitoring

The future of compliance monitoring lies not in more human hours but in intelligent automation that provides continuous visibility into your operations. This shift transforms compliance from a periodic exercise into a continuous state of operational awareness.

What risks might be developing in your blind spots right now, between those manual checks?

Challenge 4: Third-Party Dependencies – The Hidden Fault Lines in Your DORA Compliance

Every morning, your institution’s operations depend on dozens of external providers. Each connection represents a potential fault line in your operational resilience.

Your compliance framework probably looks solid on paper. But in reality, third-party processes weave through your operations like invisible threads, creating compliance gaps you can’t see until they snap.

Breaking Through the Complexity

Leading institutions are fundamentally rethinking third-party compliance monitoring. They’re moving beyond traditional vendor assessment frameworks to implement continuous operational intelligence that reveals:

Deep Process Visibility

Your operations don’t stop at organizational boundaries. Neither should your compliance monitoring. Modern platforms track process execution across internal and external systems, exposing hidden dependencies and compliance risks.

Real-Time Risk Detection

When third-party processes deviate from approved patterns, you need to know immediately. Intelligent monitoring catches these deviations before they cascade into compliance violations.

Evidence-Based Compliance

Proving DORA compliance across complex third-party relationships requires more than contractual obligations. You need continuous evidence of
operational resilience across all integration points.

The Strategic Imperative

Your institution’s DORA compliance is only as strong as your weakest third-party link. Traditional vendor management can’t address this challenge. You need operational intelligence that spans organizational boundaries.

The path forward demands real-time visibility into how third-party services actually integrate with your operations. Not just what should happen according to contracts and SOPs, but what really happens in the daily flow of business.

Think of it as operational radar that cuts through organizational boundaries to expose the true patterns of your business processes. Every third-party interaction. Every data flow. Every process deviation. All monitored continuously.

This isn’t just about compliance – it’s about operational resilience in an interconnected world.

What hidden third-party dependencies might be creating compliance blind spots in your operations right now?

Challenge 5: Documentation and Evidence – Beyond the Paper Trail Paradox

We’ve noticed a consistent pattern: documentation becomes a security blanket. A false comfort. But in 2024, traditional evidence collection methods are proving dangerously inadequate for proving continuous compliance.

The Evidence Crisis

Let us paint you a familiar picture: your compliance team maintains meticulous records. Process documentation. Control attestations. Audit trails. All perfectly organized in your governance system. Yet when regulators ask for evidence of actual operational resilience, the gaps emerge.

Most financial institutions can prove what should happen, but struggle to demonstrate what actually happened.

The Reality of Modern Operations

Imagine such scenario: a Chief Compliance Officer at a major European bank and his team spent three weeks preparing for a routine audit. Three weeks of manually collecting evidence. Reconstructing process histories. Documenting control effectiveness. Meanwhile, current operations continued largely unmonitored.

It’s dangerous.

Breaking the Documentation Trap

The most sophisticated institutions are revolutionizing their approach to compliance evidence. They’re moving from periodic documentation to continuous operational intelligence. This shift fundamentally changes how they:

Capture Reality
Every process execution automatically generates compliance evidence. Every system interaction creates an audit trail. Every control validation records itself. No human intervention required.

Prove Compliance
When regulators ask questions, answers come from real operational data, not reconstructed histories. Evidence exists for every process, every deviation, every remediation action.

Maintain Readiness
Audit preparation transforms from weeks of manual effort into continuous readiness. Evidence collection becomes a natural byproduct of operational monitoring.

The Strategic Imperative

Consider this: Your institution executes thousands of processes daily. Each execution must prove compliance with DORA requirements. Traditional documentation methods simply cannot scale to this reality.

Modern process intelligence platforms transform this challenge. They create a continuous stream of operational evidence that proves compliance in real-time. No more reconstruction. No more gaps. No more uncertainty.

The Path Forward

The future of compliance documentation isn’t about better record-keeping. It’s about operational intelligence that automatically captures the ground truth of your operations. Every process. Every deviation. Every moment.

This isn’t just about satisfying regulators. It’s about having genuine confidence in your operational resilience. Real evidence. Real compliance. Real peace of mind.

Ask yourself: If regulators walked in tomorrow, could you prove your actual DORA compliance status right now?