More than a year on from the Digital Operational Resilience Act (DORA) coming into force, compliance professionals in payments and financial services are no longer asking whether they need to comply — they are asking how to do it better.
According to Vixio, for many teams, the answer lies in purpose-built compliance software that can replace fragmented spreadsheets, disjointed workflows, and time-consuming manual research with a single, structured system.
Vixio recently discussed DORA compliance software and what firms and individuals need to look for.
DORA, formally known as Regulation EU 2022/2554, has applied to EU financial entities since 17 January 2025. Built around five pillars — ICT risk management, incident reporting, digital operational resilience testing, third-party risk management, and information sharing — it covers a broad range of institutions including banks, payment institutions, electronic money institutions, investment firms, and crypto asset service providers, along with their critical ICT third-party providers.
Moving from implementation to optimisation
With DORA’s implementation phase now behind it, regulators are focused on whether firms can demonstrate consistent, accurate compliance across all the jurisdictions in which they operate. Year one exposed just how demanding that standard is. When the European Supervisory Authorities (ESAs) conducted a dry-run exercise in 2024, only 6.5% of nearly 1,000 participating firms successfully passed all 116 data quality checks. Common failures ranged from incorrect file formats and blank mandatory fields to mismanaged unique identifiers and incomplete subcontractor chain detail.
With the second annual Register of Information deadline falling in Q1 2026, national competent authorities (NCAs) have signalled they expect materially better submissions this time around. The margin for error is narrowing, and the enforcement stakes are rising accordingly.
Why manual processes are struggling
Without dedicated compliance software, DORA obligations typically land across spreadsheets, email threads, and informal coordination between compliance and IT. This approach creates compounding problems as regulatory scrutiny intensifies.
Jurisdictional complexity alone is a significant operational burden. Each NCA sets its own submission window before forwarding data to the ESAs by the end of March, and those timelines shift from year to year. In 2026, the Netherlands required submission by 20 March, Malta’s window ran from 1 January to 21 March, Luxembourg’s deadline was 1 March, Ireland’s window ran from 2 to 31 March, and Germany’s ran from 9 to 30 March. File format requirements diverge too — Germany currently accepts XBRL or Excel, while Ireland accepts XBRL only. Submitting in the wrong format can constitute a compliance failure, potentially accompanied by financial penalties.
Beyond deadlines and formats, staying current with the secondary technical standards that underpin DORA is a resource-intensive task in its own right. The ESAs have published more than 12 batches of regulatory technical standards, implementing technical standards, guidelines, and Q&As alongside the core regulation. These secondary standards carry most of the practical compliance obligations, including how ICT-related incidents must be classified, how the Register of Information should be structured, what subcontracting chains must be documented, and how requirements vary by entity type and size. Teams that track only the core regulation are at risk of missing most of the detail that will determine whether their submissions hold up under scrutiny.
The compliance-to-IT handoff creates a further layer of complexity. DORA is unusual in that it spans two distinct organisational functions: compliance defines what is required, and IT must implement it. When that handoff happens across email threads and messaging platforms, accountability gaps emerge. Key messages are missed, updates become buried, and when a regulator requests evidence of how a risk was identified and mitigated, piecing together a coherent audit trail from disjointed records is both time-consuming and unreliable.
Staying current with DORA developments also demands significant research time. Monitoring NCA websites, ESA publications, legislative databases, and enforcement updates across multiple jurisdictions is a growing burden that scales with every new market a firm enters. Some teams have turned to general-purpose AI tools to accelerate this research, but the reliability risks are hard to ignore — training data may not include recently published deadlines, and there is no audit trail explaining how a conclusion was reached.
What good DORA compliance software should deliver
Effective compliance software shifts teams from information gathering to decision-making. At a minimum, it should consolidate monitoring across all relevant NCAs, ESAs, and legislative bodies into a single view, create a structured and auditable workflow for handing off obligations from compliance to IT, maintain a documented record of every review, decision, and action taken, and cover the broader EU regulatory environment so that DORA, PSD3, MiCA, NIS2, and other frameworks are managed in one place rather than across separate tools.
How Vixio approaches DORA compliance
Vixio is a regulatory intelligence platform built for compliance teams in payments, banking, and FinTech. It combines AI-powered monitoring with in-house regulatory analysts who review and contextualise every development before it reaches the platform, reducing the risk of unverified summaries or missed nuance.
Every DORA development — whether a new RTS batch, an NCA guidance update, an enforcement action, or an ESA clarification — is identified as soon as it is published, reviewed by analysts, and classified into one of three tiers: actionable, meaning it requires a defined response; indicative, meaning it signals a potential change worth monitoring; or informative, providing context without creating an immediate task. Every update links back to the primary source document, allowing teams to validate conclusions and cite sources in internal reporting.
Vixio’s Workspace feature addresses the compliance-to-IT handoff directly. When a DORA development requires action, teams can create a task from within the regulatory update itself, assign it to the appropriate person with full context attached, and track progress through to completion. Every decision and action is captured in a built-in audit trail, replacing the email and messaging threads that currently serve as the default record for most firms.
Critically, Vixio covers DORA alongside the broader EU regulatory calendar — including PSD3, AMLA, MiCA, NIS2, FIDA, and the AI Act — on a single platform with consistent analyst-reviewed intelligence and unified workflows. For compliance teams managing multiple regulations across multiple jurisdictions, this removes the need to build separate monitoring processes for each new framework or reconcile outputs from different systems. The platform is browser-based and requires no IT implementation, meaning teams can get started without an internal project or procurement delay.
Read the full Vixio post here.
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