For EU-regulated firms, managing technology risk is no longer just sound practice. Under DORA, NIS2 and ISO 27001, it is a legal or contractual obligation. Firms that treat it as an annual box-ticking exercise risk being caught out by regulators, according to compliance platform Copla.
According to Copla, technology risk management, often called IT risk management, is the process of identifying, assessing and controlling threats to a company’s systems, data and digital operations. It covers far more than cyberattacks.
Vendor failures, ageing infrastructure, misconfigured cloud settings, botched migrations and AI models that quietly drift all fall within scope. Cyber risk is a subset of technology risk, which is itself one strand of wider operational risk. Confusing these levels becomes costly when a register tries to score a supplier collapse using a method built only for cyber threats.
The process follows five steps. Firms inventory their assets, assess each risk for impact and likelihood, and treat it through mitigation, transfer, acceptance or avoidance. They then monitor continuously, and report and review so the register stays current. Sequencing matters as much as the steps themselves.
A real asset inventory should come first, followed by a business impact analysis, then the risk register, with controls sized last. Reverse that order and a firm may end up protecting whatever was easiest to define, rather than what it cannot afford to lose.
Each regime approaches the problem differently. DORA, Regulation (EU) 2022/2554, has applied across the EU since 17 January 2025. Articles 5 to 14 set out a detailed ICT risk framework, and major incidents trigger a four-hour reporting window. NIS2, Directive (EU) 2022/2555, applies similar logic to essential and important entities outside finance.
It requires an early warning within 24 hours, a fuller notification within 72 hours and a final report within a month, although details vary by national transposition. ISO 27001 is a certifiable standard whose clause 6.1 requires a documented risk assessment and treatment plan. Its 2022 Annex A contains 93 controls.
The overlap offers relief. Mapping a single programme across all three typically produces around 500 controls, of which only about 100 are unique. The remainder repeat the same requirements in different wording, so a well-built control can be reused three times rather than rebuilt for every audit.
Copla argues that programmes must also shift from point-in-time exercises to continuous operation. That means updating registers as vendors and systems change, re-scoring risks after material events, gathering evidence from routine work and assigning a named owner to the register itself. AI can speed up drafting and flag changes, but accountability remains with humans.
When assessing software, buyers should look for cross-framework control mapping, a living asset and vendor register, a business impact analysis linked to the risk register, validated evidence collection and access to compliance expertise.
Read the full Copla post here.
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