🇪🇺 Automated Compliance with the Digital Operational Resilience Act (DORA)

The Wake Up Call One Year After DORA Enforcement

The first year of the Digital Operational Resilience Act, Regulation 2022/2554, has delivered a clear message across Europe. Many financial institutions were operationally confident, yet few could demonstrate the traceability, ICT visibility, and continuous evidence that DORA expects under Articles 8, 10, and 11. Early supervisory reviews and readiness assessments during 2025 have consistently highlighted gaps in ICT asset inventories, critical dependencies, software supply chains, and contract intelligence. Licenseware eliminates these weaknesses by producing verifiable DORA-compliant evidence within days, at a fraction of the time and cost of manual programmes, and with full coverage across EU and UK regulatory environments.

DORA’s deadline has passed, and it is now a permanent operational requirement for EU and UK-based companies.

One year into supervision, the expectation has evolved. Regulators now focus less on whether firms have begun their programmes and more on whether they can produce evidence on demand. Continuous monitoring is no longer an aspiration; it is a necessity.

Why So Many Firms Fall Short in 2025

Organisations can easily underestimate the volume of evidence required under DORA and the speed at which supervisors expect it to be produced. The following weaknesses appeared repeatedly across European supervisory interactions:

⚠️ Asset inventories that were incomplete or outdated
⚠️ Critical function mappings that did not trace dependencies to technology components
⚠️ Inconsistent categorisation of software and third-party services
⚠️ Contract clause obligations that were not interpreted correctly
⚠️ Fragmented reporting that required manual consolidation
⚠️ Limited ability to demonstrate ICT visibility at a moment’s notice
⚠️ Traditional methods cannot support continuous evidence.
⚠️ Manual reconciliation collapses under scale.
⚠️ Spreadsheet-based inventories fall out of sync within hours almost immediately.
⚠️ Contract reviews become bottlenecks rather than governance controls.
⚠️ Dependency mapping becomes static and unusable for real operational risk scenarios.

This has simulataneously created a new set of organisational risks:

🔴 Regulatory risk.
🔴 Operational risk.
🔴 Reputational risk.

Board-level accountability is now activated.

The Cost of Not Being Compliant

The financial sector is already seeing these consequences. The institutions that have succeeded in 2025 are those that embraced operational visibility early and transformed their governance model.

The cost profile includes:

  • supervisory findings that trigger mandatory remediation
  • increased insurance premiums due to elevated operational risk
  • potential administrative penalties by national competent authorities
  • disruptions that exceed seven million euros per major ICT incident
  • loss of customer trust when operational failures become public
  • increased board scrutiny and personal accountability for senior management

Using Licenseware for DORA Evidence Collection

Licenseware provides the fastest path from fragmented ICT data to verifiable regulatory evidence, and it does so without requiring major transformation programmes. The platform enables organisations to achieve more than ninety-five % ICT visibility within days by combining their existing discovery sources, CMDBs and procurement data through APIs or static uploads.

From this point, Licenseware automates governance processes that map directly to DORA expectations:

📀 Golden Record Accuracy

Using the Software Inventory Manager app in Licenseware you can produce a single verified inventory that consolidates data from all discovery tools and procurement systems. This supports Article 8 and Article 11 requirements for ICT asset visibility and traceability.

🤖 AI-Driven Governance and Clause Interpretation

NEO Insights and NEO Context interpret contract clauses, identify operational obligations, classify vendor risk and contractual risk and highlight third-party dependencies that affect critical functions. This supports Article 10 and Articles 28 to 30.

🔁 Continuous Evidence Generation

Licenseware creates automated evidence cycles that update within twenty-four hours. These cycles ensure the organisation always has an up-to-date trail of ICT risks, assets, dependencies and contract positions. This supports Article 11 and continuous monitoring expectations.

☑️ Operational Governance at Scale

Licenseware becomes an operating model. It replaces manual reporting with real-time insight and supports strategic efficiency improvements across IT, procurement and risk management.

This is why the platform is now used as a foundation for DORA readiness programmes, supervisory reviews and operational resilience initiatives across the EU and UK.

DORA Outcomes and Time to Value

🔍 Visibility and Data Integrity

AppArticlesOutcomeKey DependencyTime to Value
Software Inventory Manager8, 11ICT inventory and coverageCMDB or discovery sources✓ Day 1
Golden Record Generator8Golden Record creationMultiple data exports✓ Instant (less than 1 day)
Infrastructure Mapper8, 24Dependency and topology mappingOptional observability tools✓ Day 1

🔦 Governance and Oversight

AppArticlesOutcomeKey DependencyTime to Value
License and Contracts Manager28 to 30Contract and clause registerLegal validation✓ Within Week 1
NEO Insights and NEO Context 10, 11AI governance and clause intelligenceSIM and LCM data✓ Less than 1 day
Self Assessment Service: ITAM Maturity Assessment5, 13Governance scoring and roadmapPolicy and process inputs✓ 2 to 4 hours

Each module directly maps to DORA outcomes and provides measurable progress within days. This is why many organisations now use Licenseware to produce evidence during supervisory reviews.

Data Collection and Collector Flexibility

Licenseware integrates with more than eighty discovery tools, including Lansweeper (our personal favorite), Microsoft System Center, BigFix, Intune, Tanium and CrowdStrike. The platform accepts static files, APIs and custom connectors for any additional source.

Organisations can Licenseware Collector with its software usage metering for secure, as a complementary low-impact telemetry across devices. There is no requirement to deploy agents across the estate.

These ensure full visibility regardless of the organisation’s current tooling landscape.

In environments with mixed data quality, the Golden Record Generator app validates and reconciles every dataset before any metric is published. This removes the largest obstacle to DORA compliance: data confidence.

Peace of Mind Metrics for Continuous Improvement

Licenseware proposes metrics that establish internal accountability for DORA evidence and governance quality.

MetricDescriptionTarget
Visibility CoveragePercentage of ICT assets reconciled into the Golden Record95% or more
Evidence LatencyAverage time for an ICT or contract change to appear in governance dashboards24 hours or less
Audit Readiness IndexWeighted balance of visibility, contract linkage and governance maturity90% or more

Example:

Visibility 98%, Contract Linkage 90%, and Maturity 88% result in a score of 92%, which is considered fully audit-ready.

Why Organisations Choose Licenseware

In 2025 the cost of manual DORA compliance can exceed one million euros for large institutions. Operational disruptions cost many times more. For a fraction of the cost, Licenseware provides a faster, more scalable and more accurate path to DORA alignment, continuous evidence and operational governance.

The result is not only regulatory compliance.

✅ It is operational confidence.

✅ It is board-level assurance.

✅ It is resilience you can prove.

High Level 100 Day Roadmap to DORA Compliance

TimeActionStakeholdersOutcome
Day 1Connect discovery and procurement dataIT Ops, Data Owner, CISOEstablish Golden Record
Day 2 to 3Visualise dependencies and reconcile contractsProcurement, LegalCentralise dependencies and contract register
Week 1Enable governance dashboardsCompliance, IT OpsEnable live governance
Week 2 to 3Complete Maturity AssessmentCISO, CFODeliver governance roadmap
Month 1Integrate evidence flows with GRC or SOCSecurity Operations, GRCInitiate Continuous Evidence Cycle
Month 2Review Peace of Mind MetricsCIO, Internal AuditConfirm resilience status
Day 100Present verified DORA dashboardExecutives or RegulatorPresent evidence pack

Ready to move from DORA risk to Board assurance in 100 days?
👉 Request a 30-minute DORA Readiness Diagnostic Today


📚 Further Reading and Supervisory References

CategorySourceLink
European Supervisory AuthoritiesEBA. Report on the Digital Operational Resilience of the EU Financial Sector, 2024https://www.eba.europa.eu/publications-and-media
European Supervisory AuthoritiesEBA. ICT and Security Risk Management Guidelineshttps://www.eba.europa.eu/regulation-and-policy/internal-governance/guidelines-ict-and-security-risk-management
European Supervisory AuthoritiesEBA. DORA Implementation Timeline and Readiness Assessment, 2024https://www.eba.europa.eu/dora
European Supervisory AuthoritiesESMA. Trends, Risks and Vulnerabilities Report, 2024https://www.esma.europa.eu/document/trv-report
European Supervisory AuthoritiesEIOPA. Opinion on ICT and Security Risk Management, 2024https://www.eiopa.europa.eu/document-library/opinion
European Supervisory AuthoritiesJoint ESAs Committee. Final Draft Regulatory Technical Standards for DORA, 2024 and 2025https://www.esrb.europa.eu/pub/pdf/other/esas-dora-technical-standards
National Competent AuthoritiesDNB. Supervisory Strategy and Priorities for 2025https://www.dnb.nl/en/publications
National Competent AuthoritiesBaFin. Supervisory Priorities 2025https://www.bafin.de/EN/Publications
National Competent AuthoritiesCentral Bank of Ireland. Cross Industry Guidance on Operational Resiliencehttps://www.centralbank.ie/regulation
National Competent AuthoritiesCSSF. Supervisory Priorities 2025https://www.cssf.lu/en/publications
National Competent AuthoritiesBanco de España. Supervisory Priorities 2025https://www.bde.es/bde/en/areas/supervision
National Competent AuthoritiesACPR. Operational Resilience Reviewhttps://acpr.banque-france.fr/publications
National Competent AuthoritiesFIN-FSA. Supervisory Priorities 2025https://www.finanssivalvonta.fi/en/publications-and-registers
IndustryEuropean Banking Federation. DORA Implementation Survey, 2024https://www.ebf.eu/publications
IndustryEACB. DORA Readiness Reflections, 2024https://www.eacb.coop/en/news
IndustryESBG. DORA Implementation Insights, 2024https://www.wsbi-esbg.org/publications

Shaun Ashbury

Shaun is an ITAM Community Champion. Dedicated to connecting the ITAM world together through shared knowledge and championing fellow ITAM professionals sharing knowledge to help others. Shaun is a Senior Consultant at Licenseware, helping customers reduce software spending. Shaun is also a podcaster at Off Menu IT [Alternative ITAM solutions] where he interviews start-ups, independent firms, and services who are not the typical go-to.