The Digital Operational Resilience Act (DORA) introduces a licensing framework that obliges banks, insurers and fintechs to prove they can withstand ICT disruptions. The “license puzzle” refers to the collection of separate requirements—risk assessments, third‑party oversight, incident reporting, and governance documentation—that must fit together before regulators grant a compliance licence. Each piece is evaluated by national supervisors and the European Banking Authority, creating a coordinated oversight environment across the EU.
The puzzle’s main components break down into four categories: (1) ICT risk management, where firms map critical systems; (2) Third‑party provider oversight, demanding contracts and monitoring plans; (3) Incident classification and disclosure, setting thresholds for reporting breaches; and (4) Governance and testing, which includes regular resilience drills and board‑level accountability. Understanding how these sections interlock is essential before you start assembling paperwork.