The impact of the Digital Operational Resilience Act on financial market infrastructures in Europe

This paper provides a comprehensive overview of the approach taken by financial market infrastructures (FMIs) across Europe as they prepare for full implementation of the Digital Operational Resilience Act (DORA) in January 2025. With the final deadline so close, concerns are emerging that some FMIs and regulatory bodies will not be ready to meet all of DORA’s requirements in time. The purpose of this paper is to examine those concerns based on current operational resilience practices in European FMIs, and to clarify the challenges and opportunities presented by greater attention to managing third-party cyber risk. The paper also covers industry perspectives and stakeholder feedback, based on interviews with industry experts (both internal and external) in fields such as banking, financial regulation and cyber security.