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Digital Operational Resilience Act (DORA) Audit Methodology

Release: Version 2.0


Document​

FieldDescription
NameDigital Operational Resilience Act (DORA) Audit Methodology
CreatorsHacken OU
SubjectDORA; digital operational resilience; compliance assessment; ICT risk management; Web3 regulation; crypto compliance;
DescriptionA structured methodology for evaluating organizational readiness and compliance with the Digital Operational Resilience Act (DORA), focusing on interviews, documentation reviews, and risk-based assessments. Designed to identify gaps, define actionable remediation, and support organizations in meeting DORA’s requirements across ICT risk, incident reporting, continuity, and third-party management.
AuthorDmytro Yasmanovych | Compliance Services Lead, Hacken OU
DateOct 15th, 2025
RightsHacken OU

Intro​

Purpose of the document​

This document defines Hacken’s methodology for assessing and supporting DORA compliance readiness. It is intended for financial entities and crypto-asset service providers (CASPs) operating within the scope of EU Regulation (EU) 2022/2554 — Digital Operational Resilience Act (DORA).

Why Hacken​

Hacken’s compliance services team consists of professionals with deep expertise in cybersecurity, crypto custody systems, and financial-sector regulations. Our methodology ensures clients receive not only an evaluation of current gaps but a clearly guided path toward resilient, audit-ready ICT practices — across both traditional and Web3 environments.


DORA in Brief​

What is DORA?​

The Digital Operational Resilience Act (DORA) is a European regulation mandating that financial entities, including crypto-asset service providers, ensure operational continuity and cyber resilience in the face of ICT-related threats.

DORA applies to a wide spectrum of entities — from credit institutions and payment providers to blockchain platforms and DeFi applications — requiring them to demonstrate maturity in five key areas:

  1. ICT Risk Management
  2. Incident Detection & Reporting
  3. Digital Operational Resilience Testing
  4. Third-Party Risk Management
  5. Threat Intelligence and Information Sharing

Hacken’s DORA Audit Methodology​

Hacken applies a five-phase compliance methodology, designed for regulatory alignment, technical accuracy, and long-term resilience.

1. Scoping & Readiness Assessment​

Before any formal evaluation, Hacken conducts a structured Readiness Assessment to determine:

  • The entity's operational and regulatory exposure to DORA.
  • Existing ICT risk governance and available documentation.
  • In-scope systems, subsidiaries, and third-party service relationships.

Deliverable:
📄 Readiness Memo outlining DORA applicability, certification goals, and key risk areas that require immediate focus.


2. DORA Gap Assessment​

Hacken performs a detailed gap assessment through:

  • Interviews with operational, risk, and IT/security stakeholders.
  • Evidence requests across all five DORA domains (ICT risk, incident response, testing, third-party risk, and information sharing).
  • Documentation analysis, including policies, diagrams, contracts, and audit logs.

Our review is based on EU Regulation (EU) 2022/2554, related EBA/ESMA/EIOPA guidance, and mapped to Web3-specific risks when applicable.

Deliverable:
📄 DORA Gap Assessment Report with clause-by-clause findings, risk levels, and clear explanations of compliance issues in plain language.


3. Remediation Plan​

Based on the findings, Hacken provides a Remediation Roadmap prioritizing the most critical gaps and suggesting:

  • Missing or incomplete policies (e.g., ICT Continuity, Critical Third-Party Monitoring, DLT Security).
  • Technical controls that require implementation or tuning.
  • Operational maturity improvements (e.g., simulation exercises, backup recovery testing).
  • Vendor contract clauses to align with DORA outsourcing requirements.

Deliverable:
📄 Remediation Roadmap — structured by priority, impact, and feasibility.


4. Follow-Up Check​

After the entity implements the recommended improvements, Hacken conducts a Follow-Up Check to verify:

  • Whether non-conformities were fully addressed.
  • Updated evidence reflects real-world implementation (not only policy rewrites).
  • ICT governance structure now supports DORA-aligned operations.

Deliverable:
📄 Follow-Up Report indicating resolved, partially resolved, and outstanding issues, with final guidance on residual risk posture.


5. Final Compliance Report​

If remediation is successful, Hacken prepares a final compliance statement detailing:

  • The entity’s current alignment with DORA.
  • Progress made since initial assessment.
  • Clear areas where the entity demonstrates industry-leading practices or acceptable compliance maturity.

Deliverable:
📄 Final DORA Compliance Report — suitable for internal use, regulatory disclosure, or partner validation.


Optional Technical Services​

To support full-spectrum digital resilience, Hacken may offer additional services via separate technical teams, fully independent from the compliance audit team, ensuring no conflict of interest:

  • Threat-Led Penetration Testing (TLPT)
  • Web2/Web3 Penetration Testing
  • Smart Contract Security Audits
  • Static Code Analysis (SCA)
  • On-chain Monitoring (via Hacken Extractor)
  • Layer 1 / Layer 2 Protocol Reviews

These services are available upon client request and may complement the compliance engagement but are managed as standalone technical scopes.


Deliverables Summary​

StageDeliverable
Scoping & ReadinessReadiness Memo
Gap AssessmentDORA Gap Assessment Report
RemediationRemediation Roadmap
Follow-UpFollow-Up Report
Final ReportFinal Compliance Report
Optional Add-onsTLPT, Pentest, SCA, Smart Contract Audits (Separate Team)

Conclusion​

Hacken’s DORA Audit Methodology is built to help financial entities and crypto-native service providers navigate DORA obligations efficiently. Our phased process blends regulatory clarity, practical recommendations, and technical rigor — preparing you not just for compliance, but for long-term operational resilience.

For onboarding, please fill our Hacken Compliance Services Form.