Digital Resilience: How SMEs Can Successfully Implement the DORA Regulation in 2026

The Digital Operational Resilience Act (DORA) is an EU regulation designed to ensure that all participants in the financial system have the safeguards needed to withstand and recover from ICT disruptions.

Unlike many previous directives (such as NIS2), which often left room for interpretation, DORA as a regulation is directly applicable. Its goal is to create a uniform security level across Europe – protecting consumer trust in digital financial services.

DORA casts a very wide net. It applies to:

Financial entities

• Credit institutions
• Payment institutions
• E-money institutions
• Investment firms
• Insurance companies
• Crypto-asset service providers

ICT third-party service providers

• SMEs providing SaaS, cloud computing, or data analytics to the financial sector

Important: Even if your business is small, you fall under DORA as soon as you perform a critical function for a regulated financial entity.

DORA is built on five strategic areas that every SME must cover:

• ICT risk management: Building a framework to identify and protect systems
• Incident reporting: A standardized process for classification and reporting
• Operational resilience testing: Regular checks to confirm defenses hold up under stress
• Third-party risk: Monitoring the entire digital supply chain
• Information sharing: Voluntary exchange of threat intelligence with other institutions

For SMEs, this pillar usually creates the largest operational workload. You need to establish an ICT risk management framework that is reviewed annually.

• Identification: Which systems are critical for business operations? (inventory and classification)
• Protection and prevention: Modern encryption, MFA, and network segmentation
• Detection: Systems that immediately flag anomalous behavior in the network
• Recovery: Backup strategies that ensure operations can be restored quickly after a ransomware attack

DORA significantly tightens reporting obligations. While the GDPR allows 72 hours, DORA may require an initial notification for major ICT incidents within just a few hours.

Classification: Define criteria for when an incident is considered “major” (e.g., number of affected customers or data volume)

Reporting chain:

• Initial report: within 4–24 hours
• Interim report
• Final report after root-cause analysis

For many SMEs, this is hard to manage without automated monitoring solutions.

This is where DORA reaches beyond your own organization. SMEs must ensure their service providers (e.g., cloud vendors) meet the same security standards.

• Information register: Maintain a list of all contracts with ICT service providers
• Contract updates: Contracts must include specific clauses on –
  • access rights
  • audit and inspection rights
  • termination periods in case of security deficiencies
• Concentration risk: Avoid dependency on a single provider – a “single point of failure”

DORA makes IT security a top-level responsibility. Executive management can no longer simply delegate accountability.

• Training obligation: Leadership must regularly participate in IT security training
• Liability: In cases of gross negligence, personal liability and significant fines may apply (up to 1% of average worldwide daily turnover for critical providers)

How should SMEs get started?

• Gap analysis: Compare your current IT setup with DORA requirements
• Clarify responsibilities:
  • Who is the ICT risk owner?
  • Who coordinates incident reporting?
• Emergency drills: Simulate a system outage – do the backups actually work?
• Contract review: Check your ICT provider contracts – do you need to add standard clauses?

Conclusion: Resilience as a quality marker

DORA is a challenge – but also an opportunity for SMEs. A certified or clearly demonstrable DORA-compliant IT management approach becomes a powerful argument for winning new customers in the financial sector in 2026. If you can prove your organization is digitally resilient, you secure your place in tomorrow’s economy.

Are there any simplifications for very small companies?

Yes. DORA follows a “proportional approach.” Micro-enterprises face simplified requirements for the risk management framework.

Does DORA replace the NIS2 Directive?

In the financial sector, DORA is considered the more specific legal framework (lex specialis). If you comply with DORA, the NIS2 requirements are typically largely covered as well.

How long do login data need to be stored for DORA?

DORA requires appropriate documentation so incidents can be traced. In practice, retaining records for at least 3–5 years is often recommended.