DORA · Art. 28–44 · Third-Party ICT Risk

Third-party ICT risk management for DORA-regulated financial institutions

Banks, insurers, and investment firms subject to DORA must document every ICT third-party relationship, assess concentration risk, and hold structured evidence for ECB, BaFin, FINMA, and ACPR supervisors. Supplier Shield gives you the register, the assessments, and the supervisory evidence, built around Articles 28–44.

17
mandatory contractual provisions per Art. 30 ICT contract
Jan 2025
DORA enforcement live across the EU
1% turnover
maximum DORA fine for repeat infringements

Trusted by global organisations

UNICCGaviThe Global FundGold StandardRépublique et canton de GenèveAbilene Advisors

§ The challenge

Where financial institutions fall short

DORA enforcement is live. Supervisors are already requesting ICT third-party registers. Most financial entities are not ready.

No complete ICT vendor register

DORA Article 28 requires a documented inventory of all ICT third-party providers, including sub-contractors and fourth parties. Most teams rely on spreadsheets with no version control, missing entries, and no criticality scoring.

Concentration risk is invisible

DORA mandates identification of single-provider dependencies across critical functions. Without structured data, risk committees cannot see geographic or provider concentration, which is exactly what EBA and ESMA supervisors will ask for.

Contractual provisions are incomplete

Article 30 requires exit strategies, audit rights, SLA definitions, and sub-contracting transparency in every critical ICT contract. Most legal teams have no systematic way to verify these provisions exist and are current.

§ How we help

How Supplier Shield addresses DORA Art. 28–44

Structured workflows covering every ICT third-party requirement, from initial vendor registration through to annual supervisory reporting.

ICT vendor register (Art. 28)

Build and maintain the authoritative ICT third-party inventory required by DORA.

Import your supplier list, auto-tier by criticality (critical, important, standard), document sub-contracting chains, and attach contractual evidence. The register is always export-ready for supervisory submission.

Concentration risk analysis (Art. 29)

Identify systemic dependencies on single providers, geographic regions, or service lines.

Run concentration risk reports aligned to EBA and ESMA guidance. Flag providers that support multiple critical functions, exactly the data your risk committee and supervisors will request.

Contractual gap analysis (Art. 30)

Scan ICT contracts for mandatory DORA provisions before audits surface the gaps.

Structured checklists verify exit strategies, audit rights, SLA clauses, and sub-contracting disclosure per contract. Findings feed directly into a remediation queue with owner assignments and deadlines.

§ Why us

Why financial compliance teams choose Supplier Shield

25+ years · 500+ audits

Built by practitioners who've been in the room

Our team has delivered 500+ audits and advised entities regulated by ECB, BaFin, FINMA, and ACPR. We built Supplier Shield to solve the DORA compliance gaps we encounter in real client engagements, not gaps described in a requirements document.

No custom development · no infrastructure

Structured ICT third-party programme without a 6-month implementation

No custom development, no infrastructure project, no professional services engagement. Import your vendor list, configure DORA criticality tiers, and run your first full assessment cycle. Most teams close their first supervisory gap within a quarter.

Published pricing · no per-user fees

Transparent pricing, no RFP cycle to get a number

Unlike enterprise GRC suites that require an RFP just to get a quote, Acuna GRC platform tiers are published on the pricing page. Supplier Shield TPRM is an add-on module priced on top of the platform. Annual fee by vendor count. No per-user fees, no negotiation required.

§ Regulatory obligations

DORA third-party obligations: what supervisors check

These are the specific DORA articles that supervisors, internal auditors, and Big 4 reviewers will test against. Supplier Shield maps your vendor program to each one.

Art. 28
ICT third-party risk policy

Document the policy, roles, and register for all ICT third-party relationships. Must include criticality tiers and sub-contracting chains.

Art. 30
Key contractual provisions

All critical ICT contracts must include: access and audit rights, service level definitions, exit strategies, sub-contracting transparency, and data location clauses.

Art. 29 / Annex III
Concentration risk monitoring

Identify dependencies on single providers. Financial entities must report concentration risk data annually to their competent authority (ECB, BaFin, FINMA, ACPR, etc.).

Art. 32
Exit strategies

For each critical ICT provider, document a tested exit strategy covering service substitution, transition timeline, and data portability. Must be reviewed annually.

§ Acuna GRC

Part of Acuna GRC: one operating system for financial compliance

Supplier Shield is the TPRM module inside Acuna GRC. Your ICT vendor register connects directly to your broader risk register, data protection framework, and internal audit workflows, all Swiss-hosted, all on one platform.

§ Platform capabilities

What Acuna GRC + Supplier Shield does for financial institutions

Supplier Shield is the TPRM module inside Acuna GRC. Here is what that means in practice for a DORA-regulated entity, beyond questionnaires.

OSINT automated risk scoring
A–F grades · zero manual research

Every ICT vendor in your register is continuously scanned for DNS hygiene, TLS configuration, web security headers, breach exposure, and threat intelligence feeds. Composite A–F grades update automatically. Your risk committee sees live posture, not a snapshot from the last assessment cycle.

Multi-framework control mapping
DORA + GDPR + ISO 27001 in one control

DORA Art. 30 contractual provisions, GDPR Art. 28 DPAs, and ISO 27001 A.15 supplier controls are the same underlying obligation. In Acuna, one control maps to all three frameworks simultaneously. No duplicated assessments, no conflicting evidence, no inconsistent scoring between your ICT and data protection registers.

Aiko: AI inside your GRC data
Natural language · instant answers

Ask Aiko: "Which ICT vendors are missing exit strategy documentation?" or "Show me concentration risk by provider for our trading systems." Answers come from your live vendor register, structured and ready to pull into a risk committee briefing without manual data extraction.

Annual compliance calendar
Scheduled reviews · DORA cadence

DORA requires annual review of your ICT third-party register, concentration risk assessments, and exit strategy tests. The Acuna compliance calendar schedules these automatically, assigns owners, and tracks completion, ensuring supervisory deadlines do not catch your team by surprise.

ERM and TPRM together
Optional module · Enterprise Risk

For financial entities with a broader enterprise risk program, the Enterprise Risk Management module connects ICT third-party risk findings directly to your operational risk register. A vendor concentration finding surfaces in your ORSA. No manual bridge between TPRM and ERM.

Full platform overview: Acuna GRC cloud platform

§ FAQ

Common questions from financial institutions

Does DORA apply to our organisation?

DORA applies to all EU-regulated financial entities: credit institutions, investment firms, insurance and reinsurance undertakings, payment institutions, electronic money institutions, AIFMs, UCITS management companies, and more. Swiss-headquartered firms with EU branches or subsidiaries are also in scope.

What is the difference between the DORA hub and this page?

The DORA hub explains the full regulation, all five pillars. This page focuses specifically on how financial institutions use Supplier Shield to meet the ICT third-party risk requirements in Articles 28–44. It is the operational application, not the regulatory overview.

How long does it take to build a DORA-compliant ICT vendor register?

Most teams complete their initial register within two to four weeks using Supplier Shield. The platform imports your existing supplier list, applies automated criticality scoring, and surfaces the highest-priority gaps immediately.

Can Supplier Shield produce the Annex III supervisory report?

Yes. The platform generates a structured export aligned to the EBA/ESMA register template (Annex III) for the annual supervisory submission. No manual data extraction required.

Is hosting in Switzerland compliant with DORA data residency requirements?

Acuna GRC is hosted in Switzerland, which satisfies data residency requirements for Swiss FINMA-regulated entities. For EU supervisors, we provide documented data processing agreements and can discuss jurisdiction-specific requirements.

Your DORA third-party register, ready in weeks.

Book a focused session with our team. We will map your current ICT third-party posture to Articles 28–44 and show you exactly where Supplier Shield closes the gaps.