Introduction
The DORA Risk Ownership Model explains how accountability for Digital Operational Risk is assigned, defined & governed under the Digital Operational Resilience Act [DORA]. It clarifies who owns Risks related to Information & Communication Technology [ICT] Systems Services & Third Party Dependencies. The Model links Risk identification Assessment mitigation & reporting to named roles across the Organisation. By doing so the DORA Risk Ownership Model supports resilience transparency & Regulatory Compliance while reducing confusion during Incidents. It applies across Financial Entities & their critical Service Chains & it strengthens Governance by aligning Operational responsibility with decision making authority.
Understanding the DORA Framework & Risk Ownership
The Digital Operational Resilience Act [DORA] is a European Union Regulation designed to ensure that Financial Entities can withstand ICT related disruptions. At its core DORA emphasises responsibility rather than technology alone.
Risk Ownership under DORA means that every material Risk must have a clearly assigned owner. This owner is accountable for understanding the Risk acting on it & escalating issues when needed. Think of it like maintaining a building. Alarms & Sensors matter but without a named building manager issues remain unresolved.
The DORA Risk Ownership Model therefore turns abstract ICT Risks into managed Business Risks.
Core Principles of the DORA Risk Ownership Model
Clear Accountability
Each ICT Risk is assigned to a specific role rather than a Team or System. Accountability cannot be shared or vague. This principle ensures faster response during Incidents.
End to End Ownership
Ownership spans the full Risk lifecycle from identification to remediation. The owner cannot delegate accountability even if tasks are outsourced.
Alignment with Business Impact
Risks are owned by those closest to the Business impact rather than purely Technical Teams. This aligns Operational decisions with Customer & Financial outcomes.
Documented Governance
The DORA Risk Ownership Model requires formal documentation. Roles responsibilities & escalation paths must be written, approved & reviewed.
Roles & Responsibilities within Organisations
Management Body
Senior Management retains ultimate accountability. They approve the Framework & ensure that Risk Ownership is effective. They also review aggregated Risk Reports.
ICT Risk Owners
These Individuals manage specific ICT Risks. They assess controls, track Incidents & ensure Remediation. They act as the first line of defence.
Control & Assurance Functions
Risk Management Compliance & Internal Audit provide Oversight. They challenge the effectiveness of the DORA Risk Ownership Model without taking Ownership themselves.
Third Party Relationship Owners
DORA extends Risk Ownership to Outsourced Services. A named owner must oversee each critical provider relationship.
Practical Implementation across Business Functions
Implementing the DORA Risk Ownership Model requires mapping Risks to Services & then to people. Start by identifying critical Business Services. Next map supporting ICT Assets & Third Parties. Finally assign Ownership based on Authority & Expertise.
In practice this often means:
- Business Leaders own service disruption Risks
- Technology Leaders own platform stability Risks
- Procurement or Operations Leaders own Supplier Risks
This approach avoids the common mistake of assigning all Risks to ICT Teams.
An analogy helps here. Assigning every Risk to ICT is like asking an electrician to manage fire safety plumbing & security at once. Ownership must match influence.
Governance Oversight & Accountability
Governance ensures that Ownership works in reality. Regular reporting shows whether owners understand their Risks & Controls. Escalation thresholds must be clear so that issues reach Senior Management early.
The DORA Risk Ownership Model also supports Incident Response. When an event occurs there is no debate about who leads the response. This clarity reduces delay & confusion.
Challenges & Limitations
While effective the Model has limits. Assigning Ownership can reveal gaps in authority. Some roles may lack the power to enforce change. Cultural resistance is also common especially where accountability was previously informal.
Another challenge is maintaining accuracy. Organisational change can leave Ownership outdated. Regular review is essential to avoid nominal owners with no real connection to the Risk.
These challenges do not undermine the DORA Risk Ownership Model but they require active management.
Conclusion
The DORA Risk Ownership Model transforms Digital Operational Risk from a Technical concern into a governed Business responsibility. By assigning clear accountable owners it strengthens resilience, improves response & supports Regulatory Compliance under DORA.
Takeaways
- The DORA Risk Ownership Model assigns clear accountability for ICT Risks
- Ownership covers the full Risk lifecycle
- Business alignment is central to effective Ownership
- Governance & Documentation make Ownership enforceable
- Regular review keeps the Model effective
FAQ
What is the purpose of the DORA Risk Ownership Model?
The purpose is to ensure that every material ICT Risk has a named accountable owner who manages it consistently & transparently.
Who should be a Risk Owner under DORA?
Risk owners should be Individuals with sufficient authority knowledge & proximity to the Business impact of the Risk.
Does DORA allow shared Risk Ownership?
No DORA expects clear single point accountability even if tasks are delegated.
How does the DORA Risk Ownership Model apply to Third Parties?
Each critical Third Party Relationship must have a named internal owner responsible for oversight & escalation.
Is the DORA Risk Ownership Model only for ICT Teams?
No the Model spans Business Technology & Operational functions depending on the nature of the Risk.
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