1. Governance, Organization, Resources for ICT Risk

1. Governance, Organization, Resources for ICT Risk
The Digital Operational Resilience Act (DORA), adopted by the EU, establishes a unified regulatory framework to ensure financial entities in the EU are resilient to ICT (Information and Communication Technology) disruptions and cyber risks. This guide focuses specifically on "Governance, organization, resources for ICT risk", as required by DORA, while referencing related DORA themes for context.
SR
by Sylvan Ravinet
 
The StratOps way to accelerate DORA
This guide on Governance, Organization, Resources for ICT Risk can help you achieve DORA compliance. Faster. Part of my 12-capabilities cyber framework.
Before continuing, make sure you are subscribed to StratOps!
Get weekly insights in your email
My StratOps newsletter helps cybersecurity experts achieve more, faster.
Subscribe 🚀
It's Free! For now.
Have feedback? Connect with me on Linkedin
1. Overview of Governance, Organization, and Resources in ICT Risk
Governance, organization, and resources for ICT risk management refer to the establishment of a robust organizational structure, governance framework, and resource allocation within financial entities to manage ICT-related risks effectively. These components are foundational under DORA and serve as the backbone for operational resilience in financial institutions.
Key regulatory sources:
DORA Regulation (EU) 2022/2554
Regulatory Technical Standards (RTS) on ICT Risk
2. Governance for ICT Risk Management
Effective governance under DORA emphasizes accountability at the highest levels of an organization and mandates strong leadership and oversight for managing ICT risks.
2.1. Responsibilities of the Management Body
The management body (e.g., board of directors) has ultimate responsibility for ensuring ICT resilience and must approve the ICT risk management framework.
Ensure ICT risks are integrated into the overall risk management strategy and business continuity planning.
Regularly review ICT risk reports and monitor adherence to DORA requirements.
2.2. ICT Risk Management Strategy
Define a documented ICT risk management strategy aligned with DORA's principles. The strategy must:
Outline the entity's approach to identifying, managing, and mitigating ICT risks.
Be reviewed and updated regularly, reflecting new threats, technological advancements, and regulatory updates.
Ensure ICT risk management objectives are integrated into the broader operational and business objectives of the organization.
2.3. Policies, Standards, and Procedures
Develop ICT risk management policies addressing:
Risk identification, assessment, and mitigation.
Incident response and management.
Disaster recovery and operational continuity (see Business Continuity and Disaster Recovery).
Align policies with secure SDLC principles and security by design (details in the Secure SDLC Guide).
3. Organization for ICT Risk Management
3.1. Establishing an ICT Risk Management Function
Create a dedicated ICT risk management function responsible for:
Managing, monitoring, and reporting ICT risks.
Collaborating with other risk management functions (e.g., operational, cyber, and third-party risk).
Ensure the function is independent from operational ICT units to maintain objectivity.
3.2. Organizational Structure
Maintain a clear, well-defined structure that identifies roles and responsibilities related to ICT risk management.
Assign specific responsibilities for:
ICT systems ownership (aligned with ICT asset classification. (see ICT Asset Classification Guide).
Data security and privacy (aligned with Data Classification Guide).
Third-party risk management (aligned with TP(S)RM Guide).
4. Resources for ICT Risk Management
4.1. Human Resources
Allocate sufficient, skilled personnel to oversee and manage ICT risks effectively.
Provide ongoing training and awareness programs for all employees to understand their roles in maintaining ICT resilience.
Upskill ICT personnel to maintain "state of the art" operational security (see State of the Art Operational Security Guide).
4.2. Financial Resources
Ensure the organization allocates adequate financial resources for:
ICT system maintenance and upgrades.
ICT risk assessments, audits, and resilience testing (details in Resilience Testing Guide).
Implementation of security tools (e.g., identity access management, encryption technologies).
Development and maintenance of disaster recovery and continuity plans (see Business Continuity Guide).
4.3. Technical Resources
Maintain an up-to-date inventory of all ICT assets, classified by criticality and importance to business functions.
Invest in advanced monitoring tools for proactive detection, response, and threat-sharing capabilities (details in Proactive Cyber Threat Detection Guide).
Ensure robust systems for data encryption, backup, and restoration (details in Data Security Guide).
5. Reporting and Oversight
5.1. Reporting to the Management Body
Establish periodic reporting mechanisms to the management body on:
ICT risk exposure.
Incident management and recovery efforts (see Incident Reporting Guide).
Results of resilience testing and vulnerability management.
5.2. Regulatory Reporting
Comply with DORA's requirements for ICT-related incident reporting to competent authorities (details in Incident Reporting Guide).
6. Key Takeaways
Governance and organization under DORA focus on strong leadership, clear accountability, and integration of ICT risks into broader business operations.
Adequate resources, human, financial, and technical are crucial for managing ICT risks and achieving operational resilience.
ICT risk management must be a continuous process, evolving alongside emerging technologies, threats, and regulatory changes.
Links to Related DORA Compliance Themes
For a comprehensive understanding of DORA compliance, this guide aligns with the following related topics:
ICT Governance
ICT Risk Management Framework
Incident Response
Critical and Important Business Functions
Business Continuity
Resilience Testing and TLPT
Third-Party Risk Management
ICT asset Management
Crisis Communication
Threat management
Data security
Security Operations
For detailed implementation guidance, refer to DORA's RTS and ITS documentation and related guides within this compliance series.
The StratOps way to accelerate DORA
Sylvan Ravinet
CISO & Advisor | My StratOps newsletter helps cybersecurity experts achieve more, faster.

I hope this guide on Governance, Organization, Resources for ICT Risk will help your team achieve DORA compliance.
Have feedback? Let’s connect on LinkedIn
Not yet a member? Get insights & more resources in the StratOps newsletter
🚀 Accelerate your DORA implementation with StratOps Implementation kits are a great start, but real resilience requires structured execution.
Join my StratOps trainings to master DORA’s 12 capabilities and fast-track compliance.