Meeting DORA’s operational resilience expectations requires deeper cross-functional collaboration and a reconfiguration of traditional ICT risk management frameworks.
The Challenge
As regulatory expectations for digital resilience increase, insurance firms must ensure their ICT frameworks align with the Digital Operational Resilience Act (DORA). With cyber threats growing more sophisticated and regulators tightening oversight, failure to comply could expose firms to operational breakdowns, financial penalties, and loss of client trust.
One such insurance group, operating across multiple jurisdictions, recognised that compliance was not just a regulatory hurdle but an opportunity to strengthen their digital resilience. The group needed expert guidance to integrate these requirements into their operations while minimising disruptions. Without a structured approach, they risked prolonged DORA implementation, potential regulatory scrutiny, and reputational damage—critical concerns in an industry where client confidence is non-negotiable.
Identifying the Gaps
During our initial assessment, several challenges emerged:
- Clarifying how DORA applies specifically to the insurance sector.
- Improving ICT governance to ensure ongoing compliance.
- Managing third-party risks from ICT service providers.
- Implementing a robust incident reporting mechanism aligned with regulatory requirements.
BDO Malta’s Approach: A Tailored Implementation Plan
We worked closely with the client to design a practical and sustainable compliance strategy.
1. Assessing Readiness & Identifying Risks
- Assessing their ICT risk management , policies, and controls.
- Highlighted areas needing enhancement to meet DORA requirements.
2. Strengthening Governance & Policies
- Assisted in updating/creating new internal policies to reflect regulatory requirements.
- Advised on governance improvements to clarify accountability for ICT risk oversight.
3. Enhancing ICT Risk Management & Resilience
- Developed an ICT risk management framework document and a digital operational resilience strategy.
4. Managing Third-Party Risks
- Evaluated critical ICT service providers to ensure they met DORA’s compliance obligations.
- Helped integrate contractual safeguards and monitoring mechanisms to oversee external risks effectively.
5. Building a Strong Incident Response Framework
- Designed a structured reporting framework for ICT-related incidents.
- Provided training on incident classification, response protocols, and regulatory notification requirements.
Client Testimonial
“I am pleased to say that we have completed what we set out. This is in no small part due to the extensive engagement, expert advice, and a lot of support and collaboration from our partners at BDO Malta. You did exactly what we had hoped for, and a lot more. It was just right, the right balance, the right partnering, and the right expertise.” - CTO and Head of Transformation at multinational insurance group.
Outcomes & Business Benefits
- Regulatory Compliance Achieved: The insurance group successfully met DORA requirements ahead of schedule.
- Stronger Operational Resilience: Cybersecurity defences and business continuity measures were significantly improved.
- Clearer Governance & Accountability: A structured governance model ensured compliance remained a priority at all levels.
- More Effective Incident Response: Faster and more efficient incident reporting minimised operational disruptions.
- Third-Party Assurance: Enhanced oversight of ICT service providers ensured ongoing compliance across external dependencies.
Lessons Learned
Meeting DORA’s operational resilience expectations requires deeper cross-functional collaboration and a reconfiguration of traditional ICT risk management frameworks. Financial entities must engage all departments in a unified strategy, ensuring that resilience is not just an IT function but a core element embedded throughout the organization. This holistic approach allows for more robust defense mechanisms, streamlined operations, and the ability to swiftly adapt to unforeseen challenges, ensuring that the entity remains resilient and competitive in a dynamic digital landscape.
Future Digital Resilience
Beyond meeting regulatory obligations, this transformation has positioned the insurance group for sustained digital resilience in an increasingly digital-driven sector. With strengthened ICT governance, proactive risk management, and a clear compliance framework, they are now equipped to handle future challenges with confidence.
At BDO Malta, we work closely with firms to embed digital resilience into their operations, helping them move beyond mere compliance to build stronger, future-ready digital frameworks. Our expertise ensures that regulatory obligations become a foundation for improved risk management, operational efficiency, and competitive strength.
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