DORA compliance for audit firms — methodology, gap analysis and a report the board can act on
Why DORA compliance has become a core engagement for audit firms
DORA (the Digital Operational Resilience Act, Regulation (EU) 2022/2554) has applied directly since 17 January 2025 and covers financial entities across the EU — including banks, insurers, investment firms and payment institutions.
For audit firms and advisory houses serving the financial sector, this means growing demand for DORA engagements: gap analyses, maturity assessments, support for internal audit, and documentation of compliance for the board and the competent authority. Firms that can deliver these engagements with a repeatable methodology are well positioned in the market.
The scope of a DORA engagement at the client
A full DORA review covers the regulation’s five pillars:
- ICT risk management — frameworks, roles, policies and controls,
- handling, classification and reporting of ICT-related incidents,
- digital operational resilience testing (including TLPT for selected entities),
- management of ICT third-party risk — contracts, criticality and the Register of Information,
- arrangements for sharing cyber threat information.
Methodology: from scoping to gap analysis
- clarify the client’s classification and proportionality (size, risk profile, critical functions),
- collect policies, procedures and evidence for each DORA area,
- perform a structured gap analysis against the requirements of the regulation,
- document each finding with a reference to evidence — traceability is half the value,
- prioritize deviations by risk and agree an action plan with the client.
The report to the board
The end product is a report the board can act on: an overall compliance picture, prioritized deviations, recommendations and references to evidence. Under DORA, the management body bears ultimate responsibility for ICT risk management — so the report must be readable by the board, not only by the IT department.
A reusable report structure across clients makes engagements profitable: the same methodology, the same evidence requirements, the same quality — client after client.
The role of the competent authority
The competent authority supervises DORA at national level — in Denmark, for example, this is Finanstilsynet. The supervisor oversees financial entities’ digital operational resilience, receives incident reports and collects the Register of Information, which is forwarded to the European Supervisory Authorities (the ESAs).
For audit firms, this means the client’s documentation must be able to withstand the supervisor’s scrutiny: a finding without evidence is worth little the day the authority asks.
Choosing a tool for DORA engagements — criteria for audit firms
When an audit firm selects a tool for DORA engagements, five questions should weigh most heavily:
- Repeatability — can the same methodology be reused across clients with consistent quality?
- Audit trail — does every finding carry sources, versions and approvals, so the report can be defended?
- Control over the client’s data — can the material stay in the client’s or the firm’s own infrastructure (on-premise), with no outbound traffic?
- Human in the loop — does a responsible person approve every finding and the final report?
- Maturity — has the tool been proven in real audits, not only in demos?
How Audnexa supports audit firms
Audnexa is an auditable workspace that supports DORA engagements from evidence collection to a review-ready report draft — with references to evidence and a full audit trail. In offline mode (Bank Mode), the client’s material stays in its own infrastructure, and a human approves every report.
The tool has matured through several years of real audit practice at Virtline (ISO/IEC 27001) and replaces neither an auditor’s opinion nor legal advice.
Frequently asked questions
What does DORA compliance mean for audit firms?
That the firm can run structured DORA engagements for financial clients: gap analysis of ICT risk management, incident handling, testing and third-party risk — documented with evidence and concluded with a report to the board.
Which clients are in scope for DORA?
Financial entities in the EU — including banks, insurers, investment firms, payment institutions and asset managers — and, indirectly, their critical ICT providers. DORA has applied since 17 January 2025.
Does a DORA gap analysis have to be approved by a human?
Yes. Good audit practice requires a responsible person to approve findings and the final report. Tools such as Audnexa produce drafts — approval always rests with the human.
Can the client’s data stay in its own infrastructure during a DORA engagement?
Yes. With an on-premise tool in offline mode (such as Audnexa’s Bank Mode), the audit material stays in the client’s infrastructure, with no outbound traffic by default.
What is the role of the competent authority in DORA?
The competent authority (in Denmark, Finanstilsynet) supervises compliance, receives incident reports and collects the Register of Information from financial entities, forwarding it to the ESAs.
Sources
This content is informational and does not constitute a legal opinion, an auditor’s opinion or a formal compliance decision.