DORA and the Payments Stack: Resilience as a Licence Condition
Operational resilience testing has moved from an internal audit topic to a supervisory expectation with named accountable individuals.
Fintech Entrepreneur
Resilience is now examinable
The Digital Operational Resilience Act reframes third-party risk: your cloud provider, your card processor and your KYC vendor are inside your regulatory perimeter.
Practical obligations
- A maintained register of information on all ICT third parties.
- Scenario-based resilience testing with documented outcomes.
- Incident classification and reporting within defined windows.
Callout
Most payment institutions already hold the underlying evidence. What they lack is a register that a supervisor can read in one sitting.
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The briefing