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EU DORA Operational Excellence
Willy Danenberg
DORA Compliance Series
Progress11/73
1 Introduction πŸ”’ Dedication πŸ”’ Copyright Page πŸ”’ Trademark Protection and Legal Notices πŸ”’ Regulatory Reference Disclaimer πŸ”’ No Legal, Regulatory, or Professional Advice πŸ”’ Limitation of Liability πŸ”’ About the Author πŸ”’ Why I Wrote This Book πŸ”’ Consulting Services πŸ”’ PART I - DORA AS AN OPERATIONAL REGULATION πŸ”’ Chapter 1: DORA’s Legal Logic - From Regulation to Daily Operations πŸ”’ Chapter 2: Management Accountability, Evidence and the Burden of Proof πŸ”’ Chapter 3: Why Checklists, Logs and Calendars Are Legally Implied under DORA πŸ”’ Chapter 4: Corrective and Preventive Actions under EU DORA πŸ”’ PART II - PRACI: ROLES, EXECUTION AND ACCOUNTABILITY πŸ”’ Chapter 5: The PRACI Model Explained - Why the Performer Is a Regulatory Necessity under DORA πŸ”’ Chapter 6: PRACI Mapping Across a Financial Institution πŸ”’ Chapter 7: PRACI and Legal Exposure - Civil, Regulatory and Criminal Risk πŸ”’ Chapter 8: Training as an Operational Control under DORA πŸ”’ Chapter 9: PRACI Matrices for Supervisory Inspections πŸ”’ PART III - THE 53 DORA POLICIES AS THE STRUCTURAL BACKBONE πŸ”’ Chapter 10: Structuring the 53-Policy DORA Framework πŸ”’ Chapter 11: Policy Ownership, Lifecycle, Review and Approval Logs πŸ”’ Chapter 12: Linking Each Policy to Checklists, Logs and Corrective and Preventive Actions πŸ”’ Chapter 13: Policy Exceptions, Risk Acceptance and Escalation πŸ”’ Chapter 14: Policy-Driven Training Obligations by PRACI Role πŸ”’ PART IV - MANDATORY DORA CHECKLISTS πŸ”’ Chapter 15: Governance and Management Body Checklists πŸ”’ Chapter 16: ICT Risk Management and Security Checklists πŸ”’ Chapter 17: Identity, Access and Privileged Account Checklists πŸ”’ Chapter 18: Systems, Architecture, Backup and Disaster Recovery Checklists πŸ”’ Chapter 19: Incident Detection, Classification and Response Checklists πŸ”’ Chapter 20: Major Incident Reporting and Regulatory Communication Checklists πŸ”’ Chapter 21: Third-Party, Cloud and Supply Chain Checklists πŸ”’ Chapter 22: Data Location, Sovereignty and Cloud Transparency Checklists πŸ”’ Chapter 23: Interdependency and Recovery Sequencing Checklists πŸ”’ Chapter 24: Testing, Scenario Analysis and Advanced Resilience Testing Checklists πŸ”’ Chapter 25: Logging, Monitoring and Audit Trail Checklists πŸ”’ Chapter 26: Operational Calendars and Recurring Control Activities πŸ”’ Chapter 27: Corrective and Preventive Action Tracking Checklists πŸ”’ Chapter 28: Management Reporting, Dashboards and Escalation Checklists πŸ”’ Chapter 29: Audit, Assurance and Independent Review Checklists πŸ”’ Chapter 30: Documentation, Record-Keeping and Retention Checklists πŸ”’ PART V - AUTOMATION, INTEGRATION AND SCALE πŸ”’ Chapter 31: Automation of Checklists, Logs and Calendars under DORA πŸ”’ Chapter 32: System Integration, Data Flows and CMDB Alignment πŸ”’ Chapter 33: Data Quality, Reconciliation and Consistency Checklists πŸ”’ Chapter 34: Training, Awareness and Competence Checklists πŸ”’ Chapter 35: Role Definition, Segregation of Duties and PRACI Enforcement Checklists πŸ”’ Chapter 36: Exception Management, Deviations and Risk Acceptance Checklists πŸ”’ Chapter 37: Supervisory Interaction, Inspections and Evidence Readiness Checklists πŸ”’ Chapter 38: Group-Level Governance, Cross-Border Operations and Consolidation Checklists πŸ”’ Chapter 39: Proportionality, Tailoring and DORA Maturity Models πŸ”’ Chapter 40: The DORA Operating Model - From Project to Permanent Capability πŸ”’ ANNEX B - ADVANCED MASTER CHECKLIST CATALOGUE πŸ”’ ANNEX C - WHY THESE CHECKLISTS MUST EXIST πŸ”’ ANNEX D - PRACI ROLE MATRICES, DECISION AUTHORITY πŸ”’ ANNEX E - END-TO-END RECOVERY SCENARIOS πŸ”’ ANNEX F - MANAGEMENT BODY LIABILITY, πŸ”’ ANNEX G - BOARD-LEVEL DECISION CHECKLISTS πŸ”’ ANNEX H - CIVIL, ADMINISTRATIVE AND CRIMINAL NEGLIGENCE πŸ”’ ANNEX I - MANAGEMENT BODY DECISION LOGS, πŸ”’ ANNEX J - LMS COURSE CATALOGUE πŸ”’ ANNEX K - AUTOMATION BLUEPRINTS πŸ”’ ANNEX L - SUPERVISORY INSPECTION QUESTION BANK πŸ”’ ANNEX M - 24-36 MONTH EU DORA IMPLEMENTATION πŸ”’ ANNEX N - MAPPING EU DORA TO GDPR, NIS πŸ”’ ANNEX O - OPERATIONAL CALENDAR OF DORA ACTIVITIES πŸ”’ ANNEX P - CONTROL PERFORMANCE πŸ”’ ANNEX Q - CORRECTIVE AND PREVENTIVE ACTION (CAPA) πŸ”’ ANNEX R - CHANGE MANAGEMENT πŸ”’ Closing Statement
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EU DORA Operational Excellence β€Ί PART I - DORA AS AN OPERATIONAL REGULATION
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Part 11 / 73

PART I - DORA AS AN OPERATIONAL REGULATION

This part establishes DORA not as a legal text to be interpreted in isolation, but as an operational regulation that reshapes how financial institutions are governed, managed, and run daily. It explains why DORA moves regulatory compliance away from static policies and periodic reporting toward continuous execution, evidence, and decision-making under uncertainty. The focus is on translating legal obligations into operational controls, roles, and routines that function during normal operations as well as during crises. This part clarifies the shift from system-centric thinking to service-centric resilience and highlights the central role of the management body in operational outcomes. It introduces the concepts of accountability, decision authority, and evidentiary discipline as regulatory requirements rather than best practices. Attention is given to the interaction between governance, technology, and human decision-making. The part also explains why traditional compliance approaches fail under DORA and how operational failures quickly become governance failures. It sets the foundation for understanding alerts, incidents, recovery, learning loops, and continuous improvement as inseparable elements of compliance. Finally, it positions DORA as a baseline expectation for resilience maturity rather than an end state, preparing the reader for the detailed operational frameworks that follow.

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