Digital Operational Resilience Act (DORA) Audit Methodology
Release: Version 2.0
Document
| Field | Description |
|---|---|
| Name | Digital Operational Resilience Act (DORA) Audit Methodology |
| Creators | Hacken OU |
| Subject | DORA; digital operational resilience; compliance assessment; ICT risk management; Web3 regulation; crypto compliance; |
| Description | A 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. |
| Author | Dmytro Yasmanovych | Compliance Services Lead, Hacken OU |
| Date | Oct 15th, 2025 |
| Rights | Hacken 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:
- ICT Risk Management
- Incident Detection & Reporting
- Digital Operational Resilience Testing
- Third-Party Risk Management
- 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
| Stage | Deliverable |
|---|---|
| Scoping & Readiness | Readiness Memo |
| Gap Assessment | DORA Gap Assessment Report |
| Remediation | Remediation Roadmap |
| Follow-Up | Follow-Up Report |
| Final Report | Final Compliance Report |
| Optional Add-ons | TLPT, 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.