Financial regulation in the EU has taken a major step forward with DORA: the Digital Operational Resilience Act, which entered into application in January 2025.
If you work in a fintech startup, a payment platform, or any technology company operating within the European financial ecosystem, DORA is not something you can ignore. It goes beyond cybersecurity: its goal is to ensure that companies can withstand, respond to, and recover from digital incidents.
So, what does DORA really mean for the fintech industry?
What is DORA and who does it apply to?
DORA is part of the EU’s digital finance package and establishes a common framework to ensure that financial entities and their technology providers can withstand, respond to, and recover from digital-related incidents.
It applies both to traditional financial entities (banks, insurers, asset managers) and to fintech companies, payment platforms, and critical ICT providers serving the financial sector.
A technology startup may fall within DORA’s scope if it acts as a critical provider and delivers essential services to a regulated entity, forms part of the digital supply chain, or manages key processes for financial operations.
What does DORA require in practice?
Since its entry into force, affected companies must have a robust ICT risk management framework in place, one that goes beyond policies and controls and demonstrates effective implementation.
DORA requires:
- Identification of critical assets and clearly assigned responsibilities;
- The ability to detect, record and report digital incidents within short timeframes;
- Regular resilience testing, such as simulations, vulnerability assessments and recovery exercises;
- Active management of risks arising from technology providers, including specific contractual clauses;
- The ability to cooperate with supervisory authorities and share information on relevant threats;
What changes for fintech companies?
What sets DORA apart from other regulations is its focus on real digital operations. Having written policies is not enough: companies must be able to demonstrate that they are applied, reviewed and continuously improved.
For many fintechs, this means adopting a more formalised approach to areas such as business continuity, third-party management and incident response. Even companies that are not directly regulated may be affected if they work with banks or insurers and are required to meet DORA-related contractual requirements.
What happens if you don’t comply?
National supervisory authorities (such as the CNMV or the Bank of Spain) now have the power to conduct audits, request documentation and impose sanctions in cases of non-compliance. Fines are not the only consequence: client trust and access to strategic contracts are also at stake.
In an increasingly demanding environment, being unable to demonstrate DORA compliance can exclude your company from tenders, integration processes or agreements with major players in the financial sector.
What can your company do now?
DORA is already in force, and authorities expect companies to have adapted their structures and processes throughout this year. If you do not yet have a clear picture of your level of compliance, now is the time to act.
The most recommended steps are:
- Carry out a compliance assessment against DORA’s five pillars;
- Identify weaknesses in risk management, incident response or third-party oversight;
- Establish an action plan with clear priorities and assigned responsibilities.
How can PrivaLex help?
At PrivaLex Partners, we work with fintechs, tech scaleups and ICT providers within the financial ecosystem to ensure that DORA compliance is not a barrier, but an opportunity to strengthen internal processes and gain a competitive advantage.
We support companies from the initial assessment through to implementation, including documentation, team training, resilience testing and the review of contracts with technology providers.
If you’re not sure where to start, or if you want to validate what you already have in place, we can help you run a quick diagnostic and define a roadmap tailored to your organisation.
Want to ensure your fintech complies with DORA in a solid and efficient way? Book a free call with our team.