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8. ICT Asset Classification, Security & Resilience
The Digital Operational Resilience Act (DORA) emphasizes the need for financial entities to classify, secure, and build resilience for their ICT assets (including applications and infrastructure). DORA requires a comprehensive inventory of ICT assets, classification by criticality, and robust security measures to mitigate risks. This guide provides a detailed overview of DORA compliance requirements related to ICT asset management at the asset level.

by Sylvan Ravinet

The StratOps way to accelerate DORA
This guide on ICT Asset Classification, Security & Resilience can help you achieve DORA compliance. Faster. Part of my 12-capabilities cyber framework.
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1. Regulatory Foundation
Regulatory Foundation
DORA Regulation (EU 2022/2554): Articles 5, 6, 8, 11, 13, and 15
RTS 2024/1774, Articles 4-5: ICT asset management specifics
RTS 2024/1774, Articles 11-12: Data and system security requirements
The classification and management of ICT assets are foundational elements of operational resilience under DORA. Financial entities must:
  • Identify and classify all ICT assets based on criticality to business operations
  • Implement security measures proportional to the asset's importance and risk level
  • Build resilience by ensuring assets can recover or continue functioning during disruptions
2. Asset Management Framework
2.1 Asset Inventory Requirements
Per RTS 2024/1774 Article 4, financial entities must maintain a comprehensive inventory including:
1
Unique asset identification
2
Location information (physical and logical)
3
Asset classification level
4
Owner identification and responsibilities
5
Business function mapping
6
Recovery time and point objectives
7
Network exposure status
8
Interdependency mapping
9
Support status and lifecycle tracking
The inventory must cover:
1
Applications (e.g., core banking systems, customer-facing platforms)
2
Infrastructure (e.g., servers, networks, cloud services, on-premises data centers)
3
Supporting tools (e.g., monitoring, backup, and recovery tools)
2.2 Critical Asset Requirements
Per RTS 2024/1774 Article 5, entities must implement:
3. Security Controls Framework
3.1 System Security
Per RTS 2024/1774 Article 11, implement:
  • Access restrictions and privilege management
  • Secure configuration baselines
  • Software authorization controls
  • Advanced malware protection
  • Data storage controls
  • Comprehensive endpoint security
Security controls must be proportionate to the asset's classification:
  • Critical Assets:
  • Advanced security measures (MFA, encryption, real-time monitoring, redundancy)
  • Important Assets:
  • Robust controls (RBAC, regular patching, vulnerability scanning)
  • Non-Critical Assets:
  • Standard security measures for basic protection
3.2 Data Protection
Per RTS 2024/1774 Article 12, ensure:
  • Data classification implementation
  • Protection measures aligned with sensitivity
  • Complete lifecycle management
  • Encryption at rest and in transit
  • Data masking or pseudonymization techniques
(See Data Security Guide for detailed requirements)
3.3 Identity and Access Management (IAM)
  • Enforce least privilege and role-based access control (RBAC)
  • Use MFA for critical applications and infrastructure
(See Security Operations Guide for details)
3.4 Asset Resilience
  • Redundancy and High Availability:
  • Implement failover mechanisms for critical assets
  • Use load balancing and clustering for essential functions
  • Backup and Recovery:
  • Regular backups stored in diverse locations
  • Automated testing of backup integrity
  • Restoration procedure validation
3.5 Continuous Monitoring
  • Deploy real-time monitoring tools
  • Implement SIEM systems for threat detection
  • Regular vulnerability scanning and penetration testing
4. Implementation Requirements
4.1 Asset Management Policy
Develop and maintain:
  • Comprehensive policy documentation
  • Regular review procedures
  • Update processes
  • Integration with ICT risk framework
4.2 Security Implementation
Establish:
  • Control mapping to asset criticality levels
  • Continuous monitoring requirements
  • Regular testing and validation
5. Integration Points
5.1 Risk Management
  • Integrate asset management with risk assessment
  • Monitor control effectiveness
5.2 Third-Party Management
  • Track provider assets and dependencies
  • Enforce security requirements
  • Include third-party services in asset inventory
  • Enforce SLAs for security and resilience
5.3 Incident Management
  • Define asset-related incident procedures
  • Establish response protocols
  • Ensure rapid identification and mitigation
5.4 Business Continuity
  • Define recovery priorities
  • Implement resilience requirements
  • Integrate with disaster recovery planning
5.5 Testing Requirements
  • Conduct regular asset security testing
  • Validate resilience measures
  • Perform penetration testing
  • Run disaster recovery simulations
  • Execute incident response drills
5.6 Threat Management
  • Implement asset threat monitoring
  • Maintain vulnerability management
6. Common Challenges and Solutions
6.1 Asset Discovery
Challenge: Maintaining complete asset inventory
Solution:
  • Deploy automated discovery tools
  • Conduct regular inventory reviews
  • Establish clear ownership assignment
  • Implement automated dependency mapping
6.2 Classification Consistency
Challenge: Ensuring accurate classification
Solution:
  • Define clear classification criteria
  • Conduct regular reviews
  • Implement automated monitoring
  • Align with data classification framework
6.3 Control Implementation
Challenge: Implementing appropriate security controls
Solution:
  • Apply risk-based approach
  • Conduct regular validation
  • Monitor control effectiveness
  • Ensure proportional security measures
6.4 Legacy Systems
Challenge: Older systems lacking modern security features
Solution:
  • Prioritize upgrades
  • Implement compensating controls
  • Plan system phase-out where appropriate
7. Key Success Factors
Key Success Factors
To achieve effective ICT asset management under DORA:
Maintain complete and accurate asset inventory
Implement clear classification scheme
Deploy appropriate security controls
Conduct regular validation
Maintain comprehensive documentation
Ensure integration with other capabilities
Build resilience through redundancy and monitoring
Implement proportional security measures
Integrate with broader compliance framework
Links to Related DORA Compliance Themes
For a comprehensive understanding of DORA compliance, this guide aligns with the following related topics:
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
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