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How Penetration Testing Ensures DORA Compliance

Written by Zoilijee Quero | Nov 12, 2025 5:49:36 PM

Complying with technology regulations is no longer just a legal obligation—it's a matter of trust and continuity. Financial institutions and ICT service providers must prove they can withstand cyberattacks and system failures without compromising their operations. In this landscape, the Digital Operational Resilience Act (DORA) marks a turning point by requiring concrete evidence of digital resilience.

At TecnetOne, we understand that embracing DORA isn't just about checking boxes—it's about genuinely strengthening operational security. That's why penetration testing (pentesting) has become essential: it helps identify vulnerabilities, validate controls, and ensure systems are truly prepared to face today's threats.

In this article, we’ll show you how pentesting can support your DORA compliance efforts, enhance your company’s resilience, and turn cybersecurity into a competitive advantage.

 

What is DORA and Why Does It Matter?

 

DORA is the first comprehensive regulation from the European Union that specifically addresses the digital operational resilience of the financial sector and its ICT providers. According to the European Insurance and Occupational Pensions Authority (EIOPA), DORA “ensures that banks, insurance companies, investment firms, and other actors in the financial ecosystem can withstand, respond to, and recover from ICT-related disruptions or attacks.”

One of DORA’s key pillars is advanced security testing—and this is where the true value of pentesting comes into play. These tests are designed to help regulated entities demonstrate, maintain, and strengthen their DORA compliance, ensuring that their systems not only meet regulatory standards but are also capable of withstanding real-world threats.

What Are the Main Obligations Imposed by DORA?

 

The Digital Operational Resilience Act (DORA) sets out a clear framework for financial institutions and ICT service providers to maintain security and stability in the face of technological incidents. In summary, it defines five key obligations that every regulated organization must meet:

 

  1. ICT Risk Management: Establish strong governance, clear policies, and effective controls to identify, assess, and mitigate technology-related risks.

  2. Incident Reporting: Detect, classify, and report major ICT incidents within the timeframes required by regulators.

  3. Digital Resilience Testing: Conduct regular assessments of information systems. All entities must carry out routine testing, while those considered “significant” are also required to perform threat-led penetration testing (TLPT) under supervision.

  4. Third-Party Risk Management: Monitor ICT service providers, especially those supporting critical functions.

  5. Information Sharing: Voluntarily share cyber threat intelligence with other entities to strengthen the security of the financial ecosystem.

 

These obligations apply to all types of financial and technological organizations within the European Union and form the foundation of DORA regulatory compliance.

 

Read more: DORA and NIS2: Differences and How to Comply with the New Regulations

 

Testing Mandates Under DORA: What You Need to Know

 

DORA goes far beyond basic audits or standard controls. According to Articles 24 to 27, regulated entities must test their digital infrastructure using realistic scenarios and a risk-based approach. Specifically, they are required to:

 

  1. Conduct regular digital resilience testing tailored to their risk level.

  2. Perform threat-led penetration testing (TLPT) on critical functions.

  3. Simulate real-world attacks in production or equivalent environments.

  4. Collaborate with competent authorities to define and validate the scope of these tests.

 

The goal is clear: to verify that both technical defenses and human responses can withstand complex, high-impact cyber threats.

 

Who Must Comply with DORA?

 

DORA has a broad scope and covers virtually the entire European financial ecosystem. Entities required to comply include:

 

  1. Banks and credit institutions

  2. Insurance and reinsurance companies

  3. Payment and electronic money institutions

  4. Investment firms

  5. Crypto-asset service providers (CASPs)

  6. ICT service providers: cloud, software, cybersecurity, and more

 

In other words, both financial institutions and the external providers that support them must demonstrate their resilience through formal testing—including penetration testing—and provide auditable evidence to the authorities.

DORA applies to all entities, regardless of size or complexity. However, those classified as “significant entities” are required to conduct TLPT every three years, in accordance with Article 26.

This risk-based approach ensures that requirements are proportionate to each organization’s criticality and technological exposure, guaranteeing that security is measured with the same rigor with which it is protected.

 

Read more: Why Pentesting Is Key in a Cybersecurity Strategy

 

How TecnetOne Supports DORA Compliance Through Offensive Security

 

At TecnetOne, we help financial and technology organizations meet the requirements of the DORA regulation through a practical approach: offensive security. We don’t just identify vulnerabilities—we test them in real-world scenarios, just as an attacker would, so you can demonstrate tangible and verifiable operational resilience.

 

Red Team: Simulations That Test Your Real Response

 

Our Red Team conducts simulated attacks targeting your organization’s most critical functions. The goal is to assess, under realistic conditions, three essential factors:

 

  1. The ability to detect and respond to complex threats

  2. The effectiveness of security controls under real stress

  3. The robustness of incident management and escalation processes

 

These simulations validate not only your technology, but also your teams' readiness in real-world risk scenarios.

 

Tailored Penetration Testing for Your Environment

 

Our penetration tests (pentesting) are customized to your infrastructure and regulatory priorities. We evaluate:

 

  1. Internal and external networks and infrastructure

  2. Applications, APIs, and cloud environments

  3. Access controls, identity, and privilege management

 

Each test is based on up-to-date threat intelligence and aligned with DORA’s focus on realistic testing in near-production environments. This ensures results are relevant, actionable, and compliant with Articles 24 to 27 of the regulation.

 

Getting Ready for DORA Compliance

 

At TecnetOne, we follow a structured process that guides you from preparation to final compliance validation:

 

  1. Readiness Assessment: We analyze current gaps against DORA testing mandates

  2. Critical Asset Definition: We identify which systems and functions need to be protected and tested

  3. Attack Scenario Design: We build realistic simulations based on threat paths and key business processes

  4. Test Execution: We perform Red Teaming, Pentesting, or optional Phishing simulations according to your needs

  5. Reporting and Guidance: We deliver clear, regulator-ready reports along with expert support for remediation

While phishing simulations aren’t mandatory under DORA, including them enhances TLPT maturity and staff readiness for real-world attacks.

 

If you're a financial institution aiming to align with DORA requirements, TecnetOne can help you achieve it with practical, effective solutions.

We are a cybersecurity firm specialized in penetration testing, threat-based assessments, Red Teaming, phishing simulations, and continuous monitoring. Our approach focuses on strengthening your operational resilience by helping you anticipate, detect, and respond to real cyber threats.

Unlike traditional pentesting services, TecnetOne goes beyond diagnosis:

 

  1. We exploit vulnerabilities to demonstrate their real-world impact and prioritize corrective actions

  2. We offer a collaborative remediation platform, enabling your team to track, manage, and resolve findings in real time

 

Our goal is to help you achieve DORA compliance in a tangible, auditable way—strengthening your organization’s security and ensuring your systems are ready to withstand the toughest threats.