DORA · ICT risk and evidence

DORA audit in Estonia: scope, evidence and report

DORA does not require one certificate. A practical audit shows whether ICT risk management, the register of information, contracts, incidents and resilience testing actually work — and which evidence is missing.

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By , Tehisabiline OÜ · Last materially updated

Short answer

DORA requires financial entities to manage ICT risk, handle incidents, test resilience and oversee third parties. An audit is not a certification: it is an independent or internal review of evidence and operation. A good audit answers whether the control works when nobody is watching.

Audit scope

  • Governance: roles, approvals, risk appetite and board oversight.
  • ICT risk: assets, dependencies, risk register, controls and metrics.
  • Register: providers, contracts, critical functions and exit plans.
  • Incidents: detection, notification, handling and lessons learned.
  • Resilience: backup, restore tests, crisis exercise and TLPT need.
  • Third parties: due diligence, contract clauses, subcontractors and oversight.

Evidence to request

DORA audit evidence
AreaEvidence
ICT riskRisk register, treatment plan, board decisions
RegisterContracts, provider list, critical-function mapping
IncidentsIncident log, notification history, tabletop record
ResilienceRestore test result, RTO/RPO, crisis plan test
Third partiesDue diligence, contract clauses, subcontractor list, exit plan

A document without an owner, date and evidence link is weak evidence. Prefer a small number of verified artifacts over a large document dump.

Register, audit and TLPT

The register of information is one DORA evidence artifact describing ICT providers and contractual arrangements. TLPT is a threat-led resilience test for designated entities. A general DORA audit reviews the wider governance, risk, incident and evidence picture. They complement but do not replace each other.

How the audit runs

  1. Scope: entities, systems, processes and critical functions.
  2. Document review: policies, register, contracts and prior tests.
  3. Controls: sample-based evidence and operating checks.
  4. Interviews: owners, support, management and third parties.
  5. Report: findings, impact, fixes and retest.

Common gaps

  • The register exists but does not match contracts and actual services.
  • The incident process is written, but notification history is missing.
  • Backups are tested, but restore results are not recorded.
  • Every service is marked non-critical.
  • Subcontractors are absent from the register.
  • Board decisions and risk appetite are not traceable.

Frequently asked questions

Does DORA require one mandatory audit?

DORA does not prescribe one mandatory certificate or audit format. A financial entity must be able to evidence ICT risk management, incident handling, resilience testing, third-party oversight and governance.

What does a DORA audit cover?

Typically the ICT risk register, register of information, contracts, incident process, backup and restore testing, resilience testing plan, governance and evidence traceability.

Is the register of information a DORA audit?

No. The register is one evidence artifact showing ICT providers and contractual arrangements. An audit reviews the wider governance, risk and evidence picture.

Does a DORA audit replace TLPT?

No. TLPT is a specific threat-led resilience test for designated entities. A general DORA audit can support preparation but does not replace it.

Sources

Can your DORA evidence survive review?

Send the register, contract count and last test. We will show where the evidence gap is.

Request a DORA audit