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ITAM and DORA
Bridging the Gap: How ITAM & DORA Should be Working Together
DORA is not a cybersecurity regulation wearing a suit. It is an asset governance regulation wearing a cybersecurity regulation wearing a suit — and if your organisation is scrambling to build a DORA compliance programme from scratch, there is a good chance you are duplicating work your ITAM function has already done.
The Digital Operational Resilience Act became fully applicable across the EU financial sector on 17 January 2025. Its five structural pillars — ICT risk management, incident classification and reporting, digital operational resilience testing, ICT third-party risk management, and information sharing — carry supervisory teeth: fines, corrective powers, and the possibility of forced contract termination for non-compliant entities. The pressure is real. The deadlines are not negotiable.
What is missing from most DORA compliance conversations is the recognition that the operational substance the regulation demands — structured asset inventories, single-accountable ownership of ICT processes, documented vendor due diligence, exit-strategy testing, continuous audit trails — is exactly what mature ITAM governance already produces. Not approximately. Not directionally. Process by process, article by article.
ITAM & DORA: The Mix
This whitepaper does the mapping work so you don't have to. Seventy HAM, SAM Foundation, SAM Advanced and Cloud processes are mapped against DORA's specific Articles, producing a clear picture of where your existing ITAM governance already satisfies regulatory requirements, where small extensions close the remaining gap, and where DORA genuinely goes beyond what any ITAM process kit can address — statutory reporting timelines, supervisory designation of critical third parties, and threat-led penetration testing among them.
The conclusion is a practical one. Financial entities under DORA's scope do not need to build a parallel compliance programme. They need to point to existing, RACIU-owned processes at five new evidentiary questions. Then they should extend a handful of them where the regulation asks for something the kits don't yet capture.
If your organisation operates in the EU financial sector — or advises, audits, or supplies technology to those who do — this paper gives you the map, the gap analysis, and the five-step operating model to close the distance between where your ITAM programme is today and where DORA requires it to be.
Download it. Share it with your compliance team. And if the mapping surfaces gaps your current programme hasn't addressed, you know where to find us.
