EU DORA ICT Risk Management Framework

Detects DORA Article 6 ICT risk management framework documentation and the digital operational resilience strategy of financial entities — board-approved framework documents, risk tolerance statements, and internal audit reviews of the framework. These documents describe the entity's defensive architecture, control gaps, and risk appetite; disclosure hands attackers a map of weaknesses.

Type

keyword_proximity

Engine

universal

Confidence

medium

Confidence justification

Medium confidence: honest topic matcher. 'ICT risk management framework' and 'digital operational resilience strategy' are DORA Article 6 defined phrases, and the 85 tier additionally requires Article 6 vocabulary (risk tolerance level, information security objectives, key performance indicators, digital operational resilience testing). The phrases also appear across the DORA advisory ecosystem — consultancy and academic material is suppressed only by noise exclusions.

Jurisdictions

eu

Regulations

Regulation (EU) 2022/2554 (DORA)

Frameworks

ISO 27001

Data categories

financial, security, governance

Scope

wide

Risk rating

7

Pattern

(?i)\b(?:ICT\s+risk\s+management\s+framework|digital\s+operational\s+resilience\s+strategy)\b

Corroborative evidence keywords

ICT risk management framework, digital operational resilience strategy, risk tolerance level, ICT risk, information security objectives, key performance indicators, digital operational resilience testing, ICT-related incident, communication strategy, Regulation (EU) 2022/2554, DORA, financial entity, board, committee, governance, compliance, fiduciary, oversight, charter, bylaw (+7 more)

Proximity: 300 characters

Should match

• ICT Risk Management Framework — version 3.2, approved by the Board 12/06/2026. Scope: this framework is maintained as a sound, comprehensive and well-documented ICT risk management framework in accordance with Article 6 of Regulation (EU) 2022/2554 (DORA). Section 4 sets the risk tolerance level for ICT risk in line with the group risk appetite. Annex A defines information security objectives and key performance indicators. — Board-approved framework document with risk tolerance and KPIs
• Digital operational resilience strategy 2026-2028. Objectives: reduce mean recovery time for ICT-related incidents to under 2 hours; complete the digital operational resilience testing programme across all critical or important functions; maintain the communication strategy for ICT-related incidents requiring disclosure to clients and counterparts. — Multi-year resilience strategy with testing and communication objectives
• Internal audit review — ICT risk management framework. Findings: the risk tolerance level for ICT risk has not been reviewed since 2024; information security objectives lack measurable key performance indicators; the digital operational resilience strategy is not aligned with the current outsourcing register. Rating: partially effective. Remediation owners assigned. — Internal audit findings exposing framework control gaps

Should not match

• New on our blog post series: what is an ICT risk management framework under DORA, and where should firms start? Read the explainer and subscribe to the newsletter for part two. — Consultancy blog explainer about the framework requirement
• The supervisor's press release announces guidance on proportionate application of the ICT risk management framework requirements for smaller financial entities, following the consultation paper published in March. — Regulator press release about framework guidance
• Week 9 of the fintech regulation course covers DORA; the tutorial asks students to sketch a digital operational resilience strategy for a fictional payment institution. — Academic course tutorial with fictional strategy exercise

Known false positives

• Consultancy marketing, law-firm alerts, and academic writing about DORA Article 6 requirements Mitigation: Negative keyword exclusion: 'explainer', 'blog post', 'newsletter', 'press release', 'consultation paper', 'academic', 'training course'. Advisory content reuses the regulation's phrases; residual matches are expected for a topic classifier.
• Policy templates and vendor GRC-tool boilerplate containing framework headings Mitigation: Shared template-exclusion dictionary (template, boilerplate, sample, placeholder) as NOT evidence on every tier
• Generic enterprise risk-management documents that mention ICT risk without being the DORA framework Mitigation: Primary phrases require the full multi-word DORA terms of art, not 'ICT risk' alone; 85 tier requires Article 6 vocabulary in proximity
• Quoted regulation text in compliance gap assessments against other frameworks (e.g. ISO 27001 mappings) Mitigation: Accepted concept-class collision — such mappings genuinely describe the entity's framework posture and are usually similarly sensitive

References

• DORA Article 6 — sound, comprehensive and well-documented ICT risk management framework; digital operational resilience strategy (Art 6(8))