The Digital Operational Resilience Act (DORA) is no longer a distant regulatory goal—financial organisations must now demonstrate that their operational resilience programs are robust, especially when it comes to managing third-party risks. The reality is, many organisations underestimate how critical vendor visibility is.
However, recent ransomware attacks within retail, Harrods, Co-op, M&S, Collins Aerospace & European Airport and closer to DORA focused industries; Allianz Life Insurance have all suffered substantial operation stopping attacks as a result of 3rd parties, which should tell us all one thing; Without a clear picture of your third-party ecosystem, you’re not truly managing risk—you’re hoping that your vendors are doing what they say.
Here are five signs your third-party risk management (TPRM) may not meet DORA expectations, and why addressing them matters now:
- You don’t have a complete inventory of critical third parties
DORA requires financial organisations to identify all third-party providers delivering critical or important services. If your records are scattered across spreadsheets or siloed systems, you may miss vendors whose failure could disrupt operations. For example, a seemingly minor software provider handling payment processing might be a single point of failure—if they go down, your services could grind to a halt.
How to fix it: Conduct a comprehensive mapping of all vendors, including subcontractors. Categorise them by criticality and document the services they provide. This visibility is the foundation for effective monitoring and compliance.
Top Tip: This will need collaboration from across the whole business – engage key stakeholders as soon as possible and ensure you cover every area of the business to unearth all vendors no matter how irrelevant you think they are.
- You can’t track vendors’ cyber or operational health in real-time
Simply knowing your vendors exist is not enough. DORA emphasises continuous oversight. If your vendor assessments happen only annually or during onboarding, emerging risks can go unnoticed until it’s too late. Imagine a cloud provider suffering a breach: without real-time monitoring, you might only learn of the impact after your own systems are compromised.
How to fix it: Implement tools that continuously monitor vendor performance, cyber security posture, and operational stability. Automated alerts for incidents or compliance deviations give your team time to act before small problems escalate.
Top Tip: It’s still unclear how far DORA expects organisations to go in monitoring third-party relationships—whether you’ll need visibility into your vendors’ own vendors. As a starting point, make sure you have a clear, up-to-date list of your vendors and their key third-party partners. This provides a solid foundation for tracking and managing risk effectively.
- Contractual obligations and SLAs are inconsistent or missing
DORA expects clear contractual obligations covering security, reporting, and incident response. If these are missing or inconsistent across vendors, you’re leaving operational resilience—and compliance—up to chance. For instance, some vendors may not be required to notify you of breaches within a defined time, creating gaps in your incident response plan.
How to fix it: Review and standardise contracts, ensuring all critical vendors have DORA-aligned clauses, including reporting obligations, audit rights, and response timeframes.
- Vendor risk assessments aren’t integrated into your wider risk framework
Third-party risk cannot exist in isolation. DORA requires that vendors’ risk profiles inform your broader enterprise risk management. If vendor data is siloed, leadership lacks the holistic view necessary for informed decision-making, leaving blind spots in your resilience strategy.
How to fix it: Integrate third-party risk data into your enterprise dashboards. Link vendor performance, compliance status, and operational metrics with your IT and business risk frameworks. This unified view ensures leadership can prioritise risk and respond strategically.
- You cannot demonstrate remediation or escalation workflows
DORA mandates timely action on identified risks. If your organisation lacks structured remediation and escalation processes, or cannot provide audit-ready evidence, you risk non-compliance and operational exposure. For example, if a critical vendor fails an audit, you must have documented steps for mitigating the risk immediately.
How to fix it: Establish clear remediation workflows and escalation paths. Ensure all actions are logged and auditable. This not only satisfies regulators but also improves organisational resilience by ensuring nothing slips through the cracks.
Why visibility matters
At the heart of DORA compliance is visibility. When you know who your critical vendors are, monitor them continuously, and integrate this insight into your enterprise risk strategy, you’re not just ticking boxes—you’re strengthening operational resilience. Visibility enables proactive management, faster response to incidents, and audit-ready reporting that regulators now expect.
Next steps
Third-party risk is complex, but addressing gaps doesn’t have to be overwhelming. Start by mapping your critical vendors, implement continuous monitoring, standardize contracts, integrate risk assessments, and formalize remediation workflows.
Find out what DORA expects from third-party risk management and how to fix gaps—fast. 👉 Download the white paper Download it now.
