For compliance professionals working in payments and financial services, DORA is no longer a looming deadline — it is a live regulatory obligation with real enforcement consequences. The question is no longer whether your firm is prepared for implementation.
According to Vixio, the question is whether you can demonstrate ongoing, accurate compliance across every jurisdiction you operate in, and whether your current tools are up to the task.
Vixio recently discussed DORA compliance software and what firms and individuals need to look for.
The Digital Operational Resilience Act (Regulation EU 2022/2554) has applied to EU financial entities since 17 January 2025. It establishes a unified framework for managing ICT risk across the financial sector, built around five pillars: ICT risk management, incident reporting, digital operational resilience testing, third-party risk management, and information sharing. It applies to a wide range of entities, including banks, payment institutions, e-money institutions, investment firms, and crypto asset service providers, as well as their critical ICT third-party service providers.
From implementation to optimisation
With the implementation period now over, regulators have shifted their focus to whether firms can prove they are complying consistently and accurately. Year one reporting exposed just how difficult full compliance is in practice. When the European Supervisory Authorities (ESAs) ran a 2024 dry-run exercise, only 6.5% of nearly 1,000 participating firms successfully passed all 116 data quality checks. Common failures included submitting files in the wrong format, leaving mandatory fields blank, mismanaging unique identifiers, and omitting subcontractor chain detail.
With the second annual Register of Information deadline having fallen in Q1 2026, national competent authorities have signalled they expect materially better submissions this time around. The margin for error is shrinking, and compliance teams are under mounting pressure not only to prove current compliance but to stay ahead of future changes.
Why manual processes fall short
Without dedicated compliance software, DORA management typically falls to spreadsheets, email threads, and informal coordination between compliance and IT. While this may appear workable on the surface, it creates significant operational risks.
Managing DORA across multiple EU jurisdictions is particularly challenging. Each National Competent Authority (NCA) sets its own collection timeline before forwarding submissions to the ESAs by the end of March, and those windows can shift from year to year. In 2026, the Netherlands required submission by 20 March, Malta’s window ran from 1 January to 21 March, Luxembourg required submission by 1 March, Ireland’s window ran from 2 to 31 March, and Germany’s from 9 to 30 March. File format requirements also diverge — Germany accepts XBRL or Excel, while Ireland accepts XBRL only. Submitting in the wrong format can constitute a compliance failure and carry potential fines.
Beyond jurisdictional complexity, tracking the 12-plus batches of regulatory technical standards (RTS), implementing technical standards (ITS), guidelines, and Q&As published by the ESAs is resource-intensive. The EBA’s Q&As alone have clarified dozens of highly specific points — including that certain fields assumed to be optional are in fact mandatory, and that non-branch financial entities must report “Not Applicable” rather than leaving fields blank. These details do not appear in the core regulation but will determine whether a submission passes validation.
There is also the persistent challenge of the compliance-to-IT handoff. DORA uniquely spans two distinct functions within the same organisation. Compliance teams define what is required, while IT must implement it. When that handoff happens over email, Slack, or in meetings, the process becomes prone to human error and leaves no structured audit trail — a serious problem when regulators ask for documented evidence of how an ICT risk was identified, assessed, and mitigated.
The challenge is compounded by the broader EU regulatory landscape. DORA sits alongside PSD3, MiCA, AMLA, NIS2, FIDA, and the AI Act, each bringing its own secondary standards, deadlines, and monitoring requirements. Manual processes simply do not scale at the rate the regulatory calendar now demands.
What good DORA compliance software should do
Regulatory change management software can address these challenges by consolidating intelligence, structuring workflows, and maintaining audit-ready records. At a minimum, effective DORA compliance software should bring automated horizon scanning across all relevant NCAs, ESAs, and legislative bodies into a single view; create a structured handoff between compliance and IT with tasks assigned directly from regulatory updates; maintain a documented audit trail of every review, decision, and action; and cover the full EU regulatory environment so that DORA is not managed in isolation from other obligations.
Why compliance teams use Vixio
Vixio is a specialist regulatory intelligence platform built for compliance teams in payments, banking, and FinTech. It combines AI-powered monitoring with in-house regulatory analysts who review, interpret, and contextualise every development before it reaches the platform.
Every DORA development — whether a new RTS batch, an NCA submission guidance update, an enforcement action, or a Q&A clarification — is identified as soon as it is published and reviewed by Vixio’s analysts before being surfaced to users. This eliminates the risk of unverified summaries or hallucinated outputs, and every update is linked back to the primary source document. Updates are classified into three tiers: actionable, indicative, and informative, so teams can prioritise immediately without wading through noise.
Vixio Workspace addresses the compliance-to-IT handoff directly. When a DORA development requires action, teams can create a task directly from the regulatory update, assign it to the relevant person across compliance, IT, or legal, and track progress through to completion in a single central system. The built-in audit trail documents every review, decision, and action, replacing the email threads and Slack messages that currently serve as the default record.
Critically, Vixio is not limited to DORA. PSD3, MiCA, AMLA, NIS2, FIDA, and the AI Act are all covered on the same platform, with the same analyst-reviewed intelligence, three-tier classification, and workflow tooling. As the EU regulatory calendar expands, so does Vixio’s coverage — all through a browser-based platform that requires no IT implementation.
Read the full Vixio post here.
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