Why Third-Party Assurance Is the Single Biggest DORA Risk
If you run cloud infrastructure, core banking software, payment processing, market data, or managed cybersecurity for European banks and insurers, one line in DORA should keep you awake at night:
Financial entities shall manage ICT third-party risk as an integral part of ICT risk management.
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If you run cloud infrastructure, core banking software, payment processing, market data, or managed cybersecurity for European banks and insurers, one line in DORA should keep you awake at night:
“Financial entities shall manage ICT third-party risk as an integral part of ICT risk management.” - Article 28(2) DORA
Translation: Every single one of your EU financial customers now has a legal obligation to prove they have you under control.
If they can’t, they get fined. If you don’t help them, they walk and take their peers with them.
This is no longer a “nice-to-have” SOC 2 report once a year.
Starting 2025–2026, regulators and procurement teams are demanding continuous, auditable, granular evidence that you meet all five DORA pillars, directly from you, not from your customer.
What the ESAs and Lead Overseers Will Actually Look For
When the EBA, ESMA, or EIOPA (or your customer’s internal audit team) shows up, they won’t ask “Do you have ISO 27001?”
They will open the exact same spreadsheet and ask:
Your customers must hand this over on demand. Most of them have no capability to create it themselves.
That puts the accountability and the relationship risk squarely on you.
The Two Types of ICT Providers in 2026
- The ones still emailing PDFs twice a year → losing RFPs and getting dragged into quarterly audit calls.
- The ones delivering continuous, machine-readable assurance through a proper third-party assurance platform → winning multi-year strategic deals and becoming preferred partners.
We already see the split in real time:
- Two of the top three hyperscalers quietly moved from annual attestations to weekly automated evidence feeds for their Tier-1 banking clients in 2025.
- Multiple core banking vendors have been dropped from shortlists in the last 90 days because they couldn’t produce an up-to-date register of information in under 48 hours.
Third-Party Assurance = Competitive Moat
The providers who build (or buy) automated, always-on assurance capability are turning a regulatory burden into a massive commercial advantage:
- Close deals 60–75% faster (procurement signs off in days, not months)
- Expand existing accounts (one large European universal bank just consolidated three vendors into one that could prove DORA readiness instantly)
- Charge resilience premiums (some vendors are already adding 8–12% “DORA-ready” uplift on new contracts)
The Clock Is Ticking
- The first wave of CTPP designations lands in early 2026.
- The first major oversight examinations begin mid-2026.
Your largest customers are already running “DORA readiness” vendor reviews in Q4 2025.
If you wait until you’re officially designated critical, you will be reacting from a position of weakness.
Bottom Line
Bottom Line
Third-party assurance under DORA is no longer a compliance checkbox.
It is now the primary decision criterion for every EU financial entity choosing (and keeping) strategic ICT partners.
The question every Head of Financial Services, Chief Regulatory Officer, and EMEA CRO is asking right now is simple:
Can this vendor prove, continuously and instantly, that they are DORA-safe?
Make sure the answer is an unqualified “yes” — or someone else will.
Ready to turn third-party assurance from a cost center into your biggest growth driver in 2026?
Download our free 2026 DORA Checklist (no email required) or book 15 minutes with our team.