DORA · Digital Operational Resilience Act · Financial Sector

DORA pentest:
Resilience evidence for the financial sector

DORA has been in force since 17 January 2025 — the transition period has ended and regulators are actively checking compliance.

DORA has been in force since January 2025. Banks, insurers, payment service providers, and their critical IT suppliers must regularly demonstrate digital operational resilience through technical testing. Our penetration test delivers exactly this evidence — per Art. 25 and 26 DORA, auditable and ready for direct use.

Art. 25 & 26 DORA covered Report delivered within 5 working days Free initial consultation
What DORA requires of you
Regular security testing
Art. 25 DORA mandates annual testing of digital operational resilience — penetration tests are the recognised evidence instrument.
Documented test evidence
Your report must contain findings, risk assessments, and remediation measures — ready for use in regulatory audits and internal compliance.
Supply chain in scope
DORA extends to critical IT service providers. Even as an IT supplier to a bank, you may be subject to DORA obligations.
No TLPT required
Threat-Led Penetration Testing (TLPT) applies only to systemically important large institutions. For everyone else, a structured pentest per Art. 25 & 26 is sufficient.
Our DORA pentest report is designed for direct use in regulatory audits, internal compliance evidence, and board-level reporting.
DORA explained

What is DORA and who does it affect?

The Digital Operational Resilience Act (DORA) is an EU regulation that has applied directly in all EU member states since 17 January 2025. It requires financial companies and their critical IT service providers to systematically test and demonstrate digital operational resilience. DORA replaces and harmonises previously fragmented national requirements — directly affecting more than 22,000 organisations across the EU.

DORA has been in force since 17 January 2025 — the transition period has ended and regulators are actively checking compliance.

The regulation applies directly without national implementing legislation — the BaFin and ECB are monitoring compliance.

IT service providers, cloud providers, and data centres may also be DORA-obligated if they provide critical functions for financial entities.

Art. 25 vs. Art. 26 DORA

Which DORA requirement applies to you?

Criterion Art. 25 DORA Art. 26 DORA (TLPT)
Target group All DORA-obligated entities Systemically important institutions
Test type Penetration test / VA TLPT (TIBER-EU framework)
Frequency Annual Every 3 years
Our service Fully covered Outside our scope
Effort Manageable, plannable Very high, accredited team required
The vast majority of the market — banks, insurers, payment providers, fintechs, and IT service providers — falls under Art. 25 DORA. That is exactly what our pentest covers.
Who is affected?

DORA applies to these organisations in the financial sector

DORA covers virtually the entire financial industry and its IT service providers. If your organisation operates in one of the areas below, you are very likely subject to DORA obligations.

🏦Banks & credit institutions
🛡️Insurers & reinsurers
💳Payment service providers
📈Investment firms
💼Investment funds & asset managers
Crypto-asset service providers (MiCA)
📱Fintechs & neobanks
💻Critical ICT third-party providers
📊Exchanges & trading venues

What are the consequences of missing DORA evidence?

Regulatory action: supervisory authorities can impose requirements, restrict operations, or issue fines where evidence of compliance is missing.
Fines up to €10 million: DORA provides for fines of up to €10 million or 5% of annual turnover for non-compliant financial entities.
Personal liability: directors and board members are personally liable for DORA compliance — with individual fines of up to €1 million.
Reputational damage: security incidents without proven protective measures put banking licences, customer trust, and business partnerships at risk.
Assessment areas

DORA requirements we test technically

Art. 25 DORA defines specific requirements for the scope and content of security tests. Our pentest covers all relevant areas and maps every finding directly to the corresponding DORA articles.

ART. 25 DORA

Network & system security

Segmentation, firewall configurations, exposed services, and privileged access — we test whether your network meets the requirements for digital operational resilience.

Art. 25 DORA · Infrastructure pentest
ART. 25 DORA

Access management & identities

Active Directory, privileged accounts, MFA enforcement, and lateral movement opportunities — central attack vectors in the financial sector.

Art. 25 DORA · AD pentest
ART. 25 DORA

Application security

Web applications, banking portals, APIs, and internal tools: we test against OWASP Top 10 and financial-sector-specific vulnerabilities.

Art. 25 DORA · Web app pentest
ART. 25 DORA

Physical security

Access control for server rooms, data centres, and sensitive areas — physical attack vectors are also relevant under DORA.

Art. 25 DORA · Physical pentest
ART. 25 DORA

Social engineering & awareness

Phishing, vishing, and pretexting targeting your employees — human vulnerabilities are the most common entry point for attackers in the financial sector.

Art. 25 DORA · Social engineering
ART. 25 DORA

Third parties & ICT supply chain

DORA explicitly requires the review of critical IT service providers. We test remote access points, API interfaces, and third-party integrations.

Art. 25 DORA · Supply chain
Our approach

How your DORA pentest works

We guide you from scope definition to an audit-ready report — structured, on time, and fully mapped to the relevant DORA articles.

SCHRITT 01

Scope definition & DORA mapping

Joint definition of the systems, applications, and processes to be tested. We identify upfront which DORA articles apply to your scope.

SCHRITT 02

Reconnaissance & attack planning

OSINT on your organisation, network footprinting, and planning of realistic attack paths — the way real attackers in the financial sector operate.

SCHRITT 03

Technical penetration test

Manual testing within the agreed scope: infrastructure, Active Directory, web applications, physical security, and social engineering.

SCHRITT 04

Analysis & DORA article mapping

All findings are mapped directly to the corresponding DORA articles — for maximum auditability with regulators and internal reviewers.

SCHRITT 05

Report & handover

Detailed pentest report with CVSS ratings, DORA mapping, prioritised remediation recommendations, and an executive summary for the board and senior management.

22,000+
affected organisations across the EU
Since Jan. 2025
DORA in force — no transition period remaining
€10 million
maximum fine for financial entities
Annual
testing obligation under Art. 25
DORA-Pentest Report · Finanzinstitut GmbH DORA-konform ✓
Exposed admin interface without MFA
Art. 25 DORA
Active Directory: kerberoastable accounts
Art. 25 DORA
Banking portal: SQL injection in search field
Art. 25 DORA
Phishing: 38% of employees clicked
Art. 25 DORA
VPN: outdated TLS version (1.1)
Art. 25 DORA
Server room: tailgating without challenge
Art. 25 DORA
DORA Art. 25 & 26 mapped Digital Operational Resilience Act (EU) 2022/2554
Our services

DORA pentests from a single source

We combine all relevant attack vectors into a comprehensive DORA assessment — from infrastructure to the human factor, everything mapped to Art. 25.

Infrastructure & Active Directory

Network segmentation, firewall configurations, Active Directory security, and remote access: technically verified and directly mapped to DORA Art. 25.

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Web app & API pentest

Banking portals, customer applications, and internal APIs: we test against OWASP Top 10 and financial-sector-specific vulnerabilities including session hijacking and insecure direct object references.

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Social engineering & physical

Phishing simulations, vishing, and physical access tests: we verify whether your staff and access control systems withstand real-world attacks.

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Frequently asked questions

DORA & penetration testing — your questions answered

Very likely yes. DORA applies to virtually all regulated financial entities in the EU: banks, insurers, payment service providers, investment firms, fintechs, crypto-asset service providers, and critical IT service providers of these entities. The full list is set out in Art. 2 DORA.
No — Threat-Led Penetration Testing (TLPT per TIBER-EU) is only mandatory for systemically important financial institutions designated as significant by the ECB or national regulators. The vast majority of the market falls under Art. 25 DORA, where a structured penetration test is sufficient.
Art. 25 DORA mandates annual testing. We also recommend additional tests after significant changes to your IT infrastructure, after security incidents, or when new systems and applications are introduced.
Costs depend on scope, company size, and the test modules required. After a free initial consultation you will receive a transparent fixed-price offer — typically within 24 hours.
Yes. DORA requires financial entities to review their critical IT service providers. At the same time, IT service providers delivering critical functions to financial entities may themselves be classified as critical ICT third-party providers and be subject to their own requirements.
Art. 25 DORA requires testing of all ICT systems and applications that support critical or important functions. In practice this covers core banking systems, payment infrastructure, customer portals, internal networks, and remote access points.

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