DORA in the Supply Chain: What IT Service Providers Now Have to Deliver to Their Clients

The problem isn't yours – but it becomes yours

The Digital Operational Resilience Act (DORA) formally targets financial institutions. Since its application date in January 2025, banks, insurers, and payment providers have had to systematically manage, document, and monitor their IT third parties.The catch: your clients can't meet these obligations on their own. They need input to do it – from you. And this is exactly where it's decided whether you stay a frictionless partner or become a risk entry in their outsourcing register.

What your clients will specifically demand from you

DORA shifts part of the burden of proof onto the supply chain.

In practice, that means:

Mandatory contractual terms. Article 30 of DORA prescribes required clauses – covering service descriptions, data processing locations, access, inspection and audit rights, as well as termination and exit provisions. Contracts missing these terms have to be renegotiated by your client. Every renegotiation costs them time and you trust.

Details for the information register. Your clients must report their IT third-party providers to the supervisory authority in a structured format. For that, they need precise information from you: legal entity, locations, supported functions, subcontractors. Providers who deliver this data cleanly and repeatably make themselves indispensable.

Transparency over subcontractors. If you pass on critical services, it has to be traceable. Your clients need to understand the chain all the way to the end – and be informed of changes in good time.Cooperation on audits and incidents. Inspection and access rights can't just sit in the contract; they have to be lived. In the event of serious ICT incidents, clients expect fast, reliable input for their own reporting obligations.

From cost factor to selection criterion

For many providers, this feels like an added burden. The shift in perspective is worth it: going forward, your clients will preferentially award regulated contracts to providers who deliver these records without months of back-and-forth. DORA-readiness becomes a differentiator – not just an obligation.A provider who can demonstrate that contracts, register details, and incident processes are in order cuts the client's vendor assessment from weeks to days. That's no longer a compliance topic. It's a sales advantage.What you should do nowReview your standard contracts against the mandatory terms in Article 30. Keep your register-relevant master data current and ready to retrieve. And create a single place where your clients can find these records themselves – instead of requesting them from you one by one.

Because the real question your clients are asking isn't: "Are you DORA-compliant?" It's: "Are you making my DORA life easier?"