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ICT Information Sharing Frameworks: A DORA Compliance Review
The Digital Operational Resilience Act (DORA) has changed the game for European financial institutions. Organizations can no longer treat information sharing as an optional courtesy; it's now a regulatory imperative with teeth.
You've likely noticed the flurry of activity as banks and financial service providers scramble to align their ICT frameworks with these new requirements. I certainly have. After reviewing dozens of implementation strategies, I've identified critical gaps and overlaps that demand immediate attention.
The DORA Reality Check
DORA demands mandatory incident reporting. Not when you feel like it or it's convenient, but within strict timeframes that many existing frameworks weren't built to accommodate.
CISOs of financial organizations may assume their FS-ISAC membership had them "fully covered" for DORA compliance. It doesn't. Their sharing protocols may lack the granularity and speed DORA requires.
The truth? Most organizations operate with information-sharing frameworks that were designed for a pre-DORA world.
Regulatory Frameworks: Close But No Cigar
The EU-CSIRT Network provides a solid foundation for information exchange but falls short on several DORA-specific requirements:
Gap: While the network facilitates information sharing, it lacks the specific focus of the financial sector that DORA demands. Financial entities need sector-specific threat intelligence that general CSIRT networks don't prioritize.
ENISA's mechanisms offer valuable threat intelligence but create a potential overlap problem:
Overlap: Organizations following both ENISA guidelines and ECB/SSM protocols often report identical incidents through multiple channels, creating unnecessary duplication and inconsistency.
The ECB/SSM protocols come closest to DORA alignment but still miss a critical element:
Gap: These frameworks lack standardized severity assessment methodologies, leaving financial entities to determine incident criticality using inconsistent criteria—a compliance risk under DORA's standardized approach.
Industry-Led Frameworks: Strong But Incomplete
FS-ISAC represents the gold standard for financial sector information sharing, but even it has DORA alignment issues:
Gap: FS-ISAC operates on voluntary participation principles, while DORA establishes mandatory reporting requirements with regulatory consequences for non-compliance.
Overlap: Organizations participating in FS-ISAC and CIISI-EU often develop redundant reporting processes, creating inefficiency and potential inconsistencies.
CIISI-EU shows promise with its European focus, but:
Gap: The initiative lacks the comprehensive technical standards for information classification that DORA requires, creating compliance uncertainty.
Cross-sector initiatives create another challenge:
Overlap: Financial entities participating in multiple cross-sector groups often receive conflicting guidance on information sharing protocols, creating compliance confusion.
Technical Standards: The Devil in the Details
STIX/TAXII provides an excellent structure for threat intelligence but:
Gap: These standards weren't designed with DORA's specific reporting timeframes, potentially creating compliance challenges during critical incidents.
OpenC2 offers automation benefits but:
Gap: The standard lacks specific financial sector extensions to address DORA's unique requirements for ICT third-party risk.
MISP shows strong potential for DORA alignment:
Overlap: Organizations implementing MISP and API-based sharing mechanisms often create duplicate data flows, increasing complexity without adding compliance value.
Implementation Realities
Be mindful when investing heavily in information-sharing governance models. Although the documentation is impeccable, sharing capabilities may be practically non-existent.
This highlights a common gap:
Gap: Many frameworks emphasize governance documentation over operational capability, creating a dangerous illusion of compliance without actual resilience.
Technical infrastructure requirements present another challenge:
Gap: Most frameworks fail to specify the minimum technical capabilities needed to meet DORA's strict reporting timeframes, leaving organizations vulnerable to compliance failures.
Human resources considerations reveal another blind spot:
Gap: Few frameworks address the specialized skills needed to interpret and act on shared information, a critical requirement under DORA's emphasis on actionable intelligence.
Evaluation Framework: The Missing Piece
The most glaring gap across all frameworks is the absence of a comprehensive evaluation methodology:
Gap: Organizations lack standardized ways to assess their information sharing maturity against DORA requirements, creating compliance uncertainty.
The compliance assessment methodology needs:
Specific metrics tied to DORA requirements
Regular testing protocols
Independent validation mechanisms
Gap analysis approaches must include:
Baseline capabilities assessment
Regulatory requirement mapping
Remediation prioritization framework
Practical DORA Alignment Strategy
Based on my analysis, the most effective approach combines elements from multiple frameworks:
Use FS-ISAC as your foundation, but supplement with DORA-specific reporting protocols
Implement MISP with financial sector extensions to meet technical requirements
Adopt ECB/SSM severity classifications to ensure regulatory alignment
Develop cross-framework mapping to eliminate redundant reporting
Create a DORA-specific maturity model to measure compliance progress
I recently helped a financial services client implement this hybrid approach. Within three months, they reduced reporting time by 64% while increasing compliance confidence by establishing clear metrics tied directly to DORA requirements.
The Hard Truth About DORA Compliance
No single existing framework fully satisfies DORA's information sharing requirements. The regulation demands a level of operational resilience that exceeds current industry practice.
You must customize your approach based on your organization's specific risk profile and existing capabilities. The good news? You don't need to start from scratch.
By identifying the gaps and overlaps in your current frameworks, you can develop a targeted enhancement strategy that achieves compliance without unnecessary duplication.
Next Steps for Your Organization
Conduct a DORA-specific gap assessment of your current information sharing capabilities
Map your reporting workflows to identify redundancies and compliance gaps
Develop standardized severity assessment criteria aligned with DORA requirements
Implement technical standards that support required reporting timeframes
Create clear metrics to measure your information sharing effectiveness
The financial institutions that thrive under DORA won't be those with the most elaborate frameworks or extensive documentation. Success will come to those who build practical, efficient information sharing capabilities that deliver real operational resilience.
The clock is ticking. DORA compliance isn't just about avoiding regulatory penalties, it's about building genuine resilience in an increasingly interconnected financial system.
Your customers, shareholders, and regulators expect nothing less.