The Digital Operational Resilience Act (DORA) is a game-changer for the financial sector in Europe, and its implications for cloud security are significant.Â
As of 17th January 2025, financial entities and their critical ICT providers, including cloud providers, need to comply with DORA’s stringent requirements.Â
But there are complexities when it comes to cloud security – especially in a regulated environment.Â
We’ve helped countless organisations migrate to and optimise their cloud environments. Based on our experience, here are ten essential steps to ensure your cloud environment is DORA-ready.
- Understand DORA’s reach:
First things first: determine if DORA applies to you. While primarily targeting financial entities, DORA’s scope extends to critical ICT third-party providers, a category that often include cloud service providers. Start by familiarising yourself with Articles 31, 32 and 33, focusing on ICT third-party risk, to understand your obligations.
- Assess your cloud landscape:
Take stock of your cloud estate. Create a detailed inventory of all cloud services (including SaaS, PaaS, IaaS), applications, and data used by your organisation. Classify your data based on sensitivity and criticality. While a time-intensive task, identifying which cloud services are essential to your operations will be crucial to your organisation’s resilience. In this process, make sure you track the elements that, if disrupted, would cause the biggest impact. This is your foundation for a DORA-compliant cloud strategy.
- Conduct a cloud-specific risk assessment:
DORA demands a robust risk assessment process, and your cloud environment needs special attention. Identify potential threats and vulnerabilities specific to your cloud usage, considering the shared responsibility model with your providers. Analyse the potential impact of cloud service outages or data breaches on your operations and customers. This assessment should inform all subsequent security measures.
- Implement robust security controls:
This is where you fortify your defences. Implement strong Identity and Access Management (IAM) with Multi-Factor Authentication (MFA) wherever possible, enforcing the principle of least privilege. Encrypt sensitive data both in transit and at rest within the cloud. Deploy robust network security controls, including firewalls and intrusion detection/prevention systems, and ensure secure configuration of your Virtual Private Clouds (VPCs). Data Loss Prevention (DLP) and Security Information and Event Management (SIEM) tools are also essential for monitoring and responding to threats.
- Strengthen your cloud governance:
Develop clear cloud security policies aligned with DORA and industry best practices. Implement robust configuration management to ensure secure deployment and maintenance of cloud resources. Establish processes for generating compliance reports to demonstrate your adherence to DORA’s requirements. Don’t forget to conduct regular security audits and vulnerability assessments tailored to your cloud environment, as these are crucial for identifying and addressing weaknesses.
- Master third-party risk (especially your cloud providers):
DORA places significant emphasis on managing third-party risk. Thoroughly vet your cloud providers, examining their security posture, certifications (like ISO 27001 and SOC 2), and their own DORA compliance. Your contracts must be watertight, addressing security, data ownership, audit rights, incident response procedures, and clear exit strategies. Don’t just focus on new providers though – you need to look at your whole supply chain and assess your current providers too.
- Develop and rigorously test incident response plans:
Hope for the best, but plan for the worst. Create incident response plans that specifically address cloud-related incidents like data breaches or service outages. Establish clear communication channels and escalation procedures, both internally and with your cloud providers. Regularly test these plans through tabletop exercises and simulations – practice makes perfect after all.
- Foster a culture of cloud security awareness:
Security isn’t just an IT issue; it’s everyone’s responsibility. Provide regular training to all employees on cloud security best practices and DORA compliance requirements. Promote a culture where security is a primary consideration in all cloud-related activities.
- Leverage cloud-native security tools:
Make the most of the security tools offered by your cloud providers and the wider market. Cloud Security Posture Management (CSPM) tools can automate security assessments and identify misconfigurations. Cloud Access Security Brokers (CASBs) provide visibility and control over cloud application usage. Cloud Workload Protection Platforms (CWPPs) protect your cloud workloads from threats. These tools can significantly enhance your security posture.
- Stay ahead of the curve and continually review:
DORA compliance isn’t a one-and-done project. Continuously monitor for regulatory updates and emerging threats. Regularly review your cloud security measures, adapt to new technologies, and seek opportunities for improvement. This will ensure that you don’t become complacent and that your security approach evolves in line with the changing digital and regulatory landscape.
DORA presents a significant but manageable challenge for organisations with workloads in the cloud. By taking these steps, you can build a secure, resilient, and DORA-compliant cloud environment.Â
But you aren’t alone in this. We’re committed to helping our clients navigate this new landscape. Our expertise in cloud migration, security, and compliance can help you achieve your DORA objectives and unlock the full potential of the cloud.
Get in touch here: https://cirrushq.com/contact/Â
