Your ICT Vendors Are a Regulatory Time Bomb
DORA requires full visibility into your ICT supply chain — not just direct vendors, but their sub-contractors too. You need a platform that maps, monitors, and reports on the entire chain. In real time.
Regulatory Penalties
Up to 1% of average daily worldwide turnover for each day of non-compliance. Regulators can impose periodic penalty payments.
Personal Liability
Board members and senior management are directly responsible under Article 28(2). Individual accountability cannot be delegated.
ESA Reporting Deadline
Your Register of Information must be available to competent authorities on demand. Incomplete or inaccurate registers trigger immediate scrutiny.
Concentration Risk
Over-reliance on a single ICT provider is a systemic risk. Regulators can force you to diversify or limit new contracts with critical providers.
The Supply Chain Visibility Gap
Most financial institutions have hundreds of ICT providers — but almost no visibility beyond their direct vendors. DORA requires transparency over the entire chain, including sub-outsourcing arrangements. Spreadsheets and ad-hoc reviews can't map what you can't see. You need a tool that gives you real-time visibility into every layer of your ICT supply chain.
What Regulators Will Check
DORA Third-Party Requirements: Article by Article
ICT Third-Party Register
Maintain a complete, accurate register of all ICT third-party service arrangements at entity, sub-consolidated, and consolidated levels.
Pre-Contractual Due Diligence
Conduct thorough risk assessment before entering ICT service arrangements, including ability to comply with DORA requirements.
Contractual Requirements
All ICT contracts must include specific clauses on security, audit rights, data location, incident notification, and exit provisions.
Concentration Risk
Assess and mitigate risks from over-reliance on single ICT providers. Consider substitutability and systemic impact.
Exit Strategy Planning
Develop and maintain exit strategies for all critical ICT providers, ensuring business continuity during transition.
Ongoing Monitoring
Implement continuous monitoring of ICT third-party performance, security, and compliance throughout the contract lifecycle.
Incident Management
Coordinate incident response with ICT third-party providers. Ensure timely notification and joint resolution processes.
Register of Information
Prepare and maintain Register of Information (ROI) for submission to ESAs, covering all ICT third-party arrangements.
Sub-Outsourcing Transparency
Ensure visibility into the full chain of ICT sub-outsourcing arrangements. Financial entities must identify and monitor sub-contractors of their direct providers.
The Auditbahn DORA Supply Chain Platform
Supply Chain Mapping
- Visualize the full ICT provider chain including sub-outsourcing layers
- Auto-discover and map vendor-to-sub-contractor relationships
- ICT provider tiering and criticality classification
- Interactive dependency graph with drill-down capability
- Import from existing registers, contracts, and vendor databases
Compliance Dashboard
- Track DORA Article 28-30 compliance status per provider
- Concentration risk scoring with automated alerts
- Contract clause compliance monitoring (Art. 30)
- Exit strategy readiness tracking for critical providers
- Board-level compliance overview and risk heatmaps
Reporting & Alerts
- ESA-ready Register of Information generation
- Automated alerts for risk threshold breaches
- Regulatory submission-ready export formats
- Periodic risk reassessment scheduling and tracking
- Audit trail for all compliance activities
Who Needs DORA Supply Chain Compliance?
Banks & Credit Institutions
Commercial banks, savings banks, and cooperative banks with complex ICT vendor ecosystems.
Insurance & Reinsurance
Insurers and reinsurers managing third-party claims systems, underwriting platforms, and data providers.
Investment Firms & Asset Managers
Fund managers, trading venues, and investment firms dependent on market data and trading infrastructure.
Payment Service Providers
Payment processors, e-money institutions, and account information service providers with critical ICT dependencies.
Central Securities Depositories
CSDs and clearing houses managing settlement infrastructure and post-trade processing systems.
Crypto-Asset Service Providers
Exchanges, custody providers, and crypto platforms authorized under MiCA with ICT third-party exposure.
How It Works
Connect & Import
Import your existing ICT provider data from registers, contracts, and internal systems. No manual data entry required.
Map & Visualize
Auto-map the full supply chain including sub-outsourcing relationships. See your ICT dependencies in an interactive graph.
Assess & Monitor
Continuous concentration risk scoring, compliance gap tracking, and automated alerts when risk thresholds change.
Report & Export
Generate ESA-ready Register of Information, board dashboards, and regulatory submissions with one click.
Why the Auditbahn Platform
Built for DORA
Purpose-built for Articles 28-30. Every feature maps directly to a regulatory requirement — no generic GRC overhead.
Full Chain Visibility
Map sub-outsourcing relationships automatically. See beyond your direct vendors to the providers behind them.
Always Current
Real-time ESA-ready reporting, not one-off documents. Your Register of Information is always current and export-ready.
Financial Sector Focus
Designed specifically for EU financial institutions. Pre-configured for banking, insurance, and investment firm requirements.
DORA Enforcement Is Not Coming. It Is Here.
Every day without full visibility into your ICT supply chain increases your regulatory exposure. See how the Auditbahn platform maps your entire vendor ecosystem — including the sub-contractors you don't know about yet.
Hand Off Compliance. Keep Building.
Your compliance system is ready. Hand off vendor management, questionnaire responses, and regulatory compliance — and get back to building the product your customers are paying for.