Complete Compliance Through Structured Documentation
DORA requires financial entities to maintain comprehensive documentation of their digital operational resilience.
The Digital Operational Resilience Act mandates structured documentation across five pillars: ICT risk management, incident reporting, resilience testing, third-party risk, and governance. Every document must demonstrate actual implementation - not just paper existence - and be available for regulatory inspection by BaFin and other supervisory authorities.
We provide comprehensive support in building and optimizing DORA-compliant documentation systems. Our approach combines regulatory expertise with practical documentation management experience for sustainable compliance solutions.
6 service modules
Bookable individually or as an end-to-end programme.
Development of comprehensive documentation frameworks that cover all DORA requirements while ensuring operational efficiency and user-friendliness.
Building comprehensive audit trail systems and compliance evidence that ensure complete documentation of all DORA-relevant activities and decisions.
Development of complete documentation systems for ICT risk management, including risk registers, assessment documentation, and mitigation evidence.
Implementation of structured incident documentation systems that meet all DORA requirements for incident reporting and management.
Building comprehensive documentation systems for critical ICT third parties, including due diligence documentation and continuous monitoring evidence.
Implementation of modern documentation management systems with automation features for efficient and consistent DORA documentation.
5 phases
We develop customized DORA documentation systems with you that integrate smoothly into your existing processes and build sustainable compliance capabilities.
Your contact
Sarah Richter
Head of Information Security, Cyber Security
10+ years of experience, CISA, CISM, Lead Auditor, DORA, NIS2, BCM, Cyber and Information Security
Structured documentation is the backbone of successful DORA compliance and enables organizations not only to meet regulatory requirements but also to continuously improve their operational resilience. Our experience shows that companies with solid documentation systems respond significantly more efficiently to supervisory reviews and can make informed risk management decisions.
DORA documentation is not just a compliance obligation, but a strategic instrument for effective risk management. Structured documentation enables informed decision-making and continuous improvement of digital operational resilience.
6 QUESTIONS, BRIEFLY ANSWERED
Required elements include a documented ICT risk management framework with policies and assigned responsibilities, a continuously maintained register of all ICT third-party contracts, and logs of completed resilience tests including their results. Documentation needs to do more than exist; under review it must be fully traceable which measure was taken when and with what outcome.
BaFin generally checks whether documentation goes beyond statements of intent: concrete logs, test results, and version histories of risk management documents rather than generic policy text. Particular focus falls on evidence that weaknesses identified in prior reviews or tests were actually remediated, not just documented as noted.
Suitable platforms support versioning, approval workflows, and automated reminders for due reviews rather than just storing documents centrally. What matters is whether changes to a document are fully traceable, since that's exactly what a review checks for. A plain file repository without version control generally doesn't meet this bar.
General documentation requirements cover the entire ICT risk management framework, including policies, test logs, and governance evidence. The information register is a specifically mandated, structured directory of ICT third-party contracts with defined required fields. Both are complementary but cover different parts of the documentation obligation.
A fixed review cycle, for example quarterly, with clearly assigned ownership for updates, works better than reworking documentation only before an announced review. Changes to ICT systems, third-party contracts, or organizational structure should directly trigger a check on whether the related documentation is still accurate.
A measure that isn't documented is effectively treated as not having happened during a review, even if it was actually carried out. Documentation should therefore not be treated as an administrative afterthought but as a fixed part of the measure itself, for example recorded immediately after a completed test or risk assessment.
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