DORA and the Future of Digital Resilience: What It Means for ICT Providers Like Notabene

As the financial sector becomes increasingly digital, its dependency on resilient infrastructure is under the microscope. Cyber threats are rising, and regulators are responding. The EU’s Digital Operational Resilience Act (DORA), which took effect on January 17, 2025, establishes a new, binding standard for operational security across 20 categories of financial institutions and their third-party ICT (Information and Communications Technology) service providers.

What sets DORA apart is its shift from guidance to obligation. Operational resilience is no longer a best practice—it’s a legal requirement. Systems must be secure, regularly tested, and prepared to withstand real-world attacks and disruptions.

For ICT providers like Notabene, which supports financial institutions and VASPs with compliance infrastructure, the message is clear: trust begins with security, and resilience is now essential.

What DORA Means for ICT Providers

DORA introduces a unified framework that ensures every link in the financial services supply chain is built for resilience. Key requirements include:

• Resilience testing by default: ICT vendors must undergo penetration testing, simulated threat scenarios, and security assessments to demonstrate that they can handle operational disruption.
• Faster, clearer incident reporting: When incidents occur, financial institutions are required to report them promptly. Their ICT partners must support these disclosures with detailed technical input.
• Stricter oversight of third-party vendors: Institutions are expected to evaluate and continuously monitor their ICT providers to ensure alignment with both regulatory and contractual standards.

For companies serving banks, VASPs, and other regulated institutions, meeting these expectations signals more than compliance. It shows preparedness and earns trust.

Notabene’s Security-First Mindset

At Notabene, security isn’t an afterthought or a reactive measure—it has always been foundational. Long before DORA came into effect, we invested in the infrastructure, policies, and safeguards that operational resilience requires.

Here’s how we go beyond the baseline:

Bank-grade due diligence

Our infrastructure undergoes rigorous reviews by global financial institutions. We align with the same standards they apply to their own systems.

Third-party audits and continuous testing

We work with independent security firms to conduct regular penetration tests, vulnerability scans, and compliance checks. These audits help us proactively identify and mitigate risk.

Global compliance alignment

We maintain SOC 2 and ISO 27001 certifications, and follow industry-leading practices in encryption, access controls, and system integrity.

Resilient by design

Our incident response protocols are structured for speed and transparency:

• Real-time threat detection to identify anomalies early
• Streamlined escalation processes to coordinate responses internally and externally
• Client-facing communication tools to share timely updates and mitigation plans

We’ve built these systems not because regulations demanded it, but because our clients do.

Why DORA Compliance Matters for Financial Institutions & VASPs

With DORA now in force, regulated institutions are reevaluating their partnerships. Compliance checklists are no longer enough—they need demonstrable resilience, backed by action and transparency.

This shift will raise expectations across the board. Financial institutions will gravitate toward ICT providers who can prove operational readiness through certifications, audits, and clear governance.

At Notabene, we’re already there. Security and trust are embedded in everything we do. And as compliance becomes a foundational layer of financial infrastructure, we’re proud to support our clients in meeting and exceeding evolving standards.

DORA is reshaping how financial institutions and technology partners think about operational resilience. ICT providers that fail to meet its expectations will be left behind. But for those who embrace it, there’s an opportunity to lead with trust, security, and readiness.

For Notabene, DORA is not a challenge—it’s validation. The systems we’ve built were designed with this level of scrutiny in mind from the very beginning.

Let’s talk about how we can help your institution stay ahead of these expectations and build resilience that lasts.