DORA Compliance Starts with Data: A Resilience Roadmap for Mid-Tier Banks

In the world of modern finance, resilience is no longer optional - it’s regulated.

The Digital Operational Resilience Act (DORA), introduced by the European Union, sets a new standard for how financial institutions - including mid-tier banks must manage ICT risk, operational continuity, and data governance.

While the regulation takes full effect in early 2025, the impact is already being felt. Institutions must now prove they can withstand, respond to, and recover from technology disruptions - all while maintaining full compliance, transparency, and control over their data ecosystem.

For mid-market banks, this represents a turning point: a chance to move beyond legacy risk and build a more secure, scalable and future-ready digital core.

What Does DORA Actually Require?

DORA introduces five core pillars of responsibility for financial entities, their ICT service providers, and subsidiaries:

1. ICT Risk Management - Monitoring, identification, classification, and mitigation of technology risks
2. Incident Reporting - Documented processes to detect, manage, and report ICT-related incidents
3. Digital Resilience Testing - Regular threat-led assessments of systems and controls
4. Third-Party Risk Oversight - Clear governance over outsourced ICT providers
5. Information Sharing - Secure, voluntary exchange of cyber threat intelligence

At the heart of all five pillars is robust data control and governance - a clear understanding of where data lives, how it’s secured, and who has access to it.

Data Strategy: Why Architecture Matters

To meet DORA’s expectations, banks need more than compliance policies - they need infrastructure that supports:

• End-to-end traceability of data movement and usage
• Secure storage and access control
• Automated incident detection and audit trails
• Real-time monitoring and continuity assurance

The architecture that underpins this strategy can vary, but it often comes down to choosing between open-source and closed-source data platforms. Both offer benefits - but also carry risks that matter in a DORA context.

Open Source vs Closed Source: What Mid-Tier Banks Need to Know

Open Source Platforms

Open-source solutions offer flexibility, low upfront costs, and a thriving developer community. However, they may require heavy customisation, internal security hardening, and specialised in-house expertise to meet DORA’s requirements - particularly around:

• Cyber resilience
• Continuous uptime and service levels
• Built-in compliance automation

For banks with mature internal IT and compliance capabilities, open source can offer adaptability - but also requires a high degree of governance ownership.

Closed Source Platforms

Closed-source (or proprietary) platforms often come with embedded security, automated compliance tooling, and direct vendor support. These features can reduce operational overhead, particularly for smaller compliance teams, by offering:

• Pre-configured access controls and encryption
• Built-in incident response workflows
• Scalable deployment and vendor-backed support for financial regulations

That said, closed platforms may offer less flexibility for custom integration - so banks must weigh ease of compliance against long-term innovation flexibility.

Whichever Route You Choose - Resilience Must Be Built In

Whether your organisation is leaning open or closed, the success of your DORA strategy will come down to three things:

1. Data Control

You must be able to trace data across its full lifecycle - from creation and modification to access, retention, and disposal.

2. Security by Design

Encryption, authentication, threat detection and response cannot be bolted on. They must be embedded at the infrastructure level.

3. Compliance Automation

Manual compliance will not scale. From audit trails to incident logs, banks must embed automation to keep pace with evolving regulation.

DORA Today, AI Tomorrow

While DORA focuses on risk and resilience, it indirectly supports something broader: future-ready data environments.

Getting your data infrastructure compliant now also positions your bank to adopt technologies like AI and advanced analytics down the line - with the control and structure already in place.

Clean, secure, and governed data is the foundation of innovation.

Get DORA-Ready with Confidence

For mid-tier banks, DORA isn’t just another regulatory challenge. It’s an opportunity to build smarter, leaner, and more agile operations - underpinned by strong data governance and infrastructure.

Camwood’s data services help financial institutions go #BeyondApplications - preparing not just for compliance, but for growth, resilience, and intelligent transformation.

Explore Camwood’s AI Readiness and Data Governance Services