DORA Compliance for Crypto: What Firms Need to Know
Plus: The Digital Operational Resilience Act is now in force across the EU. Here's a practical guide for crypto service providers.
The Digital Operational Resilience Act (DORA) went live in January 2025, and crypto firms operating in the EU must now comply with its comprehensive ICT risk management requirements.
What DORA Requires
DORA establishes uniform requirements for:
- ICT Risk Management: Comprehensive frameworks for identifying, protecting against, and recovering from ICT-related incidents
- Incident Reporting: Mandatory reporting of significant cyber incidents to regulators within strict timelines
- Third-Party Risk: Enhanced oversight of critical ICT third-party service providers, including cloud and infrastructure providers
- Resilience Testing: Regular threat-led penetration testing and vulnerability assessments
Impact on Crypto Firms
For crypto exchanges, custodians, and other service providers, DORA adds a significant compliance layer on top of MiCA:
- Enhanced cybersecurity investments
- Formalized incident response procedures
- Contractual requirements with technology vendors
- Regular resilience testing programs
Compliance Timeline
While DORA is already in effect, regulators have indicated a pragmatic approach to enforcement during the first year.
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