Are Your ICT Vendor Contracts DORA Compliant?
DORA is now in force (since 17 January 2025). Most financial entities still have legacy contracts missing the mandatory clauses - leaving them exposed.
A regulation that already applies
Since 17 January 2025, the Digital Operational Resilience Act (Regulation (EU) 2022/2554) has been fully in force across the European Union. It applies to every bank, insurance company, payment service provider, investment firm and crypto‑asset service provider operating within the EU. The law demands robust ICT controls that can prevent, withstand and recover from cyber or technical disruptions, obliges firms to report major incidents within strict timelines and requires regular resilience testing. It also tightens oversight of critical third‑party technology and cloud vendors, creating a single, harmonised standard for digital stability throughout the entire European financial sector.
A readiness gap you cannot ignore
A fresh Censuswide survey shows 96 percent of EMEA financial‑services organisations admit they are not yet resilient enough to meet DORA requirements.
The hidden blocker: Contracts
" But more then 80% of companies that are DORA Compliant, are still uncompliant when it comes to their Contracts."
Deloitte Legal warns that most institutions still have thousands of ICT and cloud contracts without the mandatory DORA clauses on audit rights, data residency, incident escalation and exit support. Every missing clause is now a compliance gap that can trigger supervisory fines or even service interruptions.
How Alaro.AI can help
Alaro.ai ingests your ICT service agreements and addenda. Our AI maps clause language against DORA Article 30 requirements and flags omissions, weak SLAs, or conflicting terms. Non‑compliant contracts are routed to EU financial‑regulatory lawyers who provide redlined wording to close every gap - fast.
Complimentary DORA Contract Compliance Assessment
If your contract is already compliant, you pay nothing. If it isn’t, our lawyers fix it, saving you far more than supervisory penalties or traditional legal fees.
Consequences if you are uncompliant
• Significant financial penalties – fines can reach 2 % of total annual worldwide turnover or €10 million, whichever is higher.
• Daily punitive payments – regulators may levy 1 % of average daily worldwide turnover for up to six months until full compliance is achieved.
• Business restrictions or licence suspension – supervisory authorities can halt specific services, freeze outsourcing arrangements or revoke an authorisation to operate until deficiencies are fixed.
• Costly, mandatory remediation programmes – enforced audits, resilience tests and urgent contract renegotiations divert resources and inflate operational budgets.
• Public “name and shame” disclosures – regulators may publish enforcement actions, driving negative media coverage and long‑term reputational damage.
• Civil litigation and compensation claims – outages or data losses linked to non‑compliance expose firms to lawsuits from customers, investors and counterparties.
• Higher cyber‑insurance premiums or loss of cover – underwriters raise rates or tighten terms once a compliance breach signals elevated operational risk.
• Lost business opportunities and blacklisting – non‑compliant entities and their vendors can be excluded from tenders or partnerships, and critical ICT providers may be prohibited from future contracts.
Since 17 January 2025 the Digital Operational Resilience Act (DORA) has bound every EU bank, insurer, payment provider, investment firm and crypto‑asset platform to tough rules on ICT security, rapid incident reporting, resilience testing and third‑party oversight. Many organisations are racing to upgrade firewalls and run penetration tests, yet overlook the biggest weakness: thousands of cloud and software contracts that still lack DORA‑mandated clauses on audit rights, data residency and exit support. These silent gaps invite multimillion‑euro fines, licence curbs, public “name and shame” notices and lost deals. A focused contract audit closes the risk quickly. Request your complimentary DORA Contract Compliance Assessment today.