The Digital Operational Resilience Act (DORA) is one of the most consequential pieces of EU regulation for the financial sector in recent years. Its scope is broad, covering not just banks, insurers, and traditional institutions, but also fintechs, payment firms, and crypto asset service providers. For fintech companies, which often operate with lean teams, agile product cycles, and a heavy reliance on cloud or third-party providers, DORA represents both a compliance challenge and an opportunity to strengthen their foundations.
According to Nojus Bendoraitis, a regulatory compliance strategist with over a decade of experience guiding fintechs through EU legislation, the act should not be seen as “yet another box-ticking exercise.” Instead, it is a framework for resilience that, when implemented effectively, can enhance investor confidence, foster stronger customer trust, and enable sustainable growth. Bendoraitis explains that fintechs are uniquely positioned to embed DORA requirements more seamlessly than many legacy players because they tend to have less technical debt and more flexible operating models. The key, however, is to start early and approach compliance with both structure and creativity.
Understanding Why DORA Matters for Fintechs
Unlike larger financial institutions, fintechs often operate in niche markets, offering digital-only products or serving as service providers to larger entities. This makes them highly dependent on technology, cloud infrastructure, and vendor ecosystems. DORA directly addresses these dependencies. It requires firms to demonstrate their ability to manage ICT risks, classify and report incidents, test their resilience, and control third-party exposures.
For fintechs, the reputational stakes are high. A single major service outage or data breach can erode customer trust and quickly escalate into a regulatory issue. DORA creates a harmonized standard across the EU, which means fintechs that prepare well can turn compliance into a competitive differentiator, showing potential partners and investors that their operational maturity is on par with—or even ahead of—traditional players.
Step One: Building Governance and Awareness Early
One of the first challenges fintechs face is organizational. Many small or mid-sized firms underestimate the extent to which board-level accountability is embedded in DORA. Management bodies are not just expected to sign off on policies; they are required to actively oversee ICT risk management and resilience strategies.
Bendoraitis points out that fintech boards often consist of founders, investors, or technologists who may not have deep compliance backgrounds. Educating these stakeholders early and assigning clear ownership for DORA-related responsibilities is critical. Some fintechs have begun establishing dedicated “resilience committees” or appointing operational resilience officers to ensure that board-level accountability is effectively translated into daily practice.
The tone at the top matters. When leaders treat DORA as integral to business strategy, it becomes easier to embed resilience across product design, customer service, and supplier management.
Step Two: Mapping Services and Dependencies
DORA requires firms to identify their important business services, assess the ICT assets that support them, and understand interdependencies. For fintechs, this can be complex, as many rely heavily on cloud-native services, APIs, and external vendors.
The practical step is to create a dynamic service map, showing not only what applications and infrastructure are in place, but also how they link to customer-facing outcomes. For example, a payment start-up should be able to show how transaction processing depends on a specific cloud provider, an anti-fraud tool, and a customer authentication service.
As Bendoraitis notes, “Service mapping is not simply an IT inventory exercise—it is about demonstrating to regulators and stakeholders that you understand how disruptions cascade across your ecosystem and that you can prioritize recovery where it matters most.”
For fintechs that aspire to scale across multiple EU markets, building this discipline early will pay dividends when entering new jurisdictions or attracting institutional clients who demand robust due diligence.
Step Three: Incident Readiness and Reporting
Perhaps the most operationally challenging element of DORA for fintechs is incident reporting. The regulation sets strict requirements for classifying ICT incidents and notifying regulators within specific timelines.
Fintechs often pride themselves on rapid response and informal communication, but DORA requires structured processes. That means having predefined severity levels, escalation paths, and reporting templates. In practice, a cyberattack that disrupts services or compromises customer data must be logged, classified, and escalated not just internally but also to supervisory authorities in a matter of hours.
Bendoraitis highlights that many fintechs underestimate the amount of documentation and evidence that regulators will expect. “It’s not enough to fix the issue quickly—you need to prove how it was identified, who made the decisions, and how information was shared across teams,” he explains. For resource-constrained fintechs, automating parts of this workflow—through incident management tools, integrated dashboards, and templated reports—can significantly ease the burden.
Step Four: Managing Third-Party Risks
DORA shines a spotlight on ICT third-party providers, including cloud platforms, software vendors, and outsourced service partners. For fintechs, which often rely on such providers for critical functions, this is a central compliance challenge.
The regulation requires maintaining a detailed register of third-party arrangements, assessing the criticality of providers, and ensuring that contracts include specific clauses regarding resilience, audit rights, and cooperation during incidents. For many fintechs, renegotiating existing contracts or pushing global cloud giants for compliance-friendly terms may feel daunting.
Bendoraitis suggests a pragmatic approach: start with criticality triage. Identify which vendors are truly essential to customer-facing services and prioritize compliance efforts there. In parallel, fintechs should develop exit strategies and contingency plans—whether that means implementing multi-cloud resilience or establishing backup providers for specific functions. Demonstrating that these plans exist, even if they are not yet fully implemented, signals to regulators that the firm takes DORA obligations seriously.
Step Five: Testing and Continuous Improvement
Resilience is not proven on paper. DORA emphasizes testing, from scenario-based exercises to full-scale threat-led penetration testing for larger entities. For fintechs, the temptation may be to do the minimum required; however, Bendoraitis argues that testing should be viewed as a strategic asset.
“Every exercise is a chance to identify weaknesses before they hurt you in the real world,” he notes. Whether it is a simulated cyberattack, a failover test of cloud infrastructure, or a board-level crisis table-top, each test produces valuable insights. The key is to document results, track remediation actions, and ensure a seamless closure.
Over time, fintechs that treat testing as part of their innovation cycle—iterating not just products but also resilience capabilities—will be stronger and more trustworthy in the market.
Turning Compliance into Advantage
For fintechs across the EU, preparing for DORA may feel like a burden, but the reality is that compliance can become a competitive edge. Investors are more likely to back firms with mature risk management. Institutional partners will prefer fintechs that can demonstrate operational resilience. And customers, increasingly aware of cybersecurity threats, will gravitate toward firms that can prove they are reliable and secure.
Bendoraitis concludes that fintechs should view DORA as “a framework to professionalize operations, win trust, and accelerate growth.” By embedding governance, mapping dependencies, preparing for incidents, managing vendors, and embracing testing, fintechs can position themselves not only to comply but to thrive in the new regulatory environment.
In the end, DORA is not about slowing innovation—it is about ensuring innovation can withstand shocks, scale sustainably, and contribute to a resilient European financial system. Fintechs that grasp this early, guided by specialists like Copla and experts such as Nojus Bendoraitis, will be the ones setting the pace.
