DORA Compliance Guide and 10-Step Checklist for Fintech Startups

The financial technology (Fintech) sector is built on speed, flexibility, and heavy reliance on third-party cloud integrations (APIs, banking service providers, etc.). However, the European Union's Digital Operational Resilience Act (DORA - Regulation (EU) 2022/2554), which entered into force on January 17, 2025, has introduced very serious cybersecurity and operational resilience rules to this rapid growth model.

Payment institutions, electronic money institutions (EMIs), crypto-asset service providers (CASPs), and next-generation digital banks (neobanks) must now comply not only with financial regulations but also with these stringent standards for cybersecurity infrastructure. In this guide, we present the steps fintech startups need to take in their DORA compliance process with a 10-item checklist based on official regulation articles.

Importance of DORA Compliance for Fintechs

DORA applies largely the same rules that traditional banks follow to fintech startups as well. The biggest weakness of fintechs is their dependence on third-party technology (ICT) providers to carry out their operations. DORA aims to manage the risks created by this dependency and prevent the entire financial system from being paralyzed in case of a collapse of a single cloud provider (AWS, GCP, etc.).

10-Step Fintech DORA Compliance Checklist

Step 1: Determining Management Board Responsibility (Article 5)

Fintech management boards are directly responsible for IT (Information Technology) risk management. It is a legal requirement for management board members to receive formal IT risk management training to understand cybersecurity risks and manage approval processes.

Action: Organize certified cybersecurity training for the management board and make budget authorization processes for IT compliant.

Step 2: Establishing an ICT Risk Management Framework (Article 6)

A written ICT (Information and Communication Technology) Risk Management Framework proportional to the size and risk profile of fintechs must be established. This framework should include cybersecurity policies, data protection procedures, and business continuity plans.

Action: Prepare an IT risk management policy compliant with ISO 27001 or NIST standards.

Step 3: ICT Asset Inventory and Classification (Article 8)

All software, APIs, servers, and data flows used in the system must be inventoried. Systems supporting critical financial transactions (payment gateway, user authentication, etc.) should be marked as "Critical Assets."

Action: Create a detailed ICT asset inventory that is updated at least once a year.

Step 4: Establishing Anomaly Monitoring and Detection Systems (Article 9)

Continuous monitoring infrastructure must be in place to immediately detect unusual activities, potential cyber attacks, and disruptions occurring in systems.

Action: Automate log monitoring processes by completing SIEM (Security Information and Event Management) and SOC (Security Operations Center) integrations.

Step 5: Integration of IT Incident Reporting Process (Articles 17-20)

DORA requires critical IT incidents to be reported instantly to national supervisory authorities and customers.

Action: Design a 3-stage (early warning, interim report, final report) emergency reporting flow for detection, classification, and reporting of cyber incidents to official institutions.

Step 6: Basic Operational Resilience Testing (Article 24)

All fintechs must conduct security tests at least once a year to measure the stability of their systems.

Action: Have independent external audit firms perform vulnerability assessments and network penetration tests once a year.

Step 7: Threat-Led Penetration Testing - TLPT (Article 26)

Large-scale payment institutions and fintechs with systemic impact are required to conduct TLPT (Threat-Led Penetration Testing / Red Team Testing) at least every 3 years. These tests simulate real cyber attack scenarios.

Action: Conduct your volume and transaction number analyses to determine whether your company falls within the scope of the TLPT obligation.

Step 8: Third-Party (Supplier) Risk Management (Article 28)

The cybersecurity postures of all external suppliers such as banks to which the fintech provides APIs, cloud services, and KYC (Know Your Customer) verification tools must be audited.

Action: Request cybersecurity certificates (SOC2, ISO 27001) demonstrating DORA compliance from all active technology providers and conduct risk scoring.

Step 9: Legal Compliance in Supplier Contracts (Article 30)

Contracts with suppliers receiving critical services must include clauses mandated by DORA (SLA commitments, data storage locations, disaster recovery scenarios, and exit strategies).

Action: Revise your existing AWS, Azure, or private data center contracts and add DORA Article 30-compliant addendums.

Step 10: Information Sharing Agreements (Article 45)

Fintechs are encouraged to share their cyber threat intelligence among themselves and with the financial community.

Action: Join financial cyber intelligence sharing platforms (e.g., FS-ISAC) and participate in sectoral cyber threat information exchange processes.

Frequently Asked Questions (FAQ)

Question 1: Are small-scale or newly established fintech startups outside the scope of DORA?

Answer: No. There is no scale exemption among financial institutions within the scope of the DORA regulation. However, the regulation considers the principle of proportionality by offering a simplified ICT Risk Management Framework (Article 16) for micro-enterprises (fewer than 10 employees and less than €2 million turnover).

Question 2: What happens if our critical technology (ICT) suppliers are not DORA compliant?

Answer: Under DORA Article 28, financial institutions cannot work with suppliers that do not comply with cybersecurity standards or do not accept audit authority. If necessary, it is mandatory to legally terminate these contracts (triggering the exit strategy).

Question 3: What is the cyber incident reporting period under DORA?

Answer: According to DORA Article 19, when a critical IT incident occurs, financial institutions must make the initial notification no later than the end of the relevant business day (or within 4 hours after detection of the incident). An interim report should be sent within 24 hours and a final report within one week.

Conclusion and Recommendations for Fintech Managers

For fintech startups, DORA compliance is not just an audit checklist; it is a condition for being able to exist in the EU market. Especially managing third-party risks (Articles 28 and 30) and automating incident reporting processes are the most complex stages for startups using the cloud ecosystem. Therefore, it is critically important for fintechs to carry out compliance processes in coordination with technical and legal advisors without leaving them to the last minute.