Establish Governance and Accountability

Appoint Leaders: Designate a Chief Information Security Officer (CISO) or equivalent to oversee DORA and NIS2 compliance.
Form Committees: Create cross-functional teams (e.g., IT, legal, compliance, and operations) to coordinate implementation.
Board-Level Oversight: Ensure board members understand their roles in overseeing digital resilience and cybersecurity.

Conduct a Gap Analysis

Assess Current State: Compare existing policies, procedures, and technologies against DORA and NIS2 requirements.
Identify Gaps: Highlight areas of non-compliance, such as incident reporting processes, third-party risk management, or cybersecurity capabilities.

Develop a Compliance Roadmap

Set Priorities: Focus first on high-risk areas, such as ICT incident reporting or critical system resilience.
Allocate Resources: Dedicate adequate personnel, budget, and technology to implement necessary changes.
Timeline: Establish clear milestones to track progress.

Strengthen ICT and Cyber Risk Management

Risk Assessment: Regularly evaluate ICT risks and vulnerabilities in systems, processes, and third-party providers.
Policies and Frameworks: Implement robust policies aligned with DORA and NIS2, including:|
Cybersecurity controls
Business continuity planning
Incident response procedures
Testing and Validation: Regularly test controls and systems for resilience, including penetration testing and scenario-based exercises.

Enhance Incident Detection and Reporting

Incident Monitoring: Deploy advanced monitoring tools to detect potential incidents in real time.
Reporting Framework: Create a standardized template and process for reporting ICT-related incidents within the required timeframes.
Training: Train staff on incident identification, escalation, and reporting protocols.

Manage Third-Party Risks

Vendor Assessments: Evaluate the ICT security and resilience of third-party providers, especially critical service providers.
Contracts and SLAs: Include clauses that require compliance with DORA and NIS2, including incident reporting and resilience standards.
Monitoring: Continuously monitor third-party risks and conduct periodic audits.

Implement/Leverage Technology

Automation: Use tools for continuous monitoring, compliance tracking, and reporting.
Encryption and Data Protection: Ensure data security through encryption, access controls, and data loss prevention measures.
Redundancy and Recovery: Invest in backup systems and disaster recovery solutions to ensure business continuity.

Build a Cybersecurity Culture

Employee Training: Conduct regular training programs to educate staff on their role in maintaining digital resilience.
Simulations and Drills: Organize cyberattack simulations to prepare employees for real-world scenarios.
Awareness Campaigns: Promote a culture where cybersecurity is a shared responsibility.

Foster Collaboration

Internal Collaboration: Align IT, risk, legal, and compliance teams for unified implementation efforts.
External Collaboration: Participate in industry forums, information-sharing initiatives, and public-private partnerships.

Monitor, Review, and Improve

Continuous Monitoring: Implement systems to monitor compliance and system performance in real-time.
Regular Audits: Conduct internal and external audits to verify compliance and identify areas for improvement.
Feedback Loop: Use lessons learned from incidents, audits, and exercises to refine policies and practices.

Engage with Regulators

Proactive Communication: Engage with regulatory bodies to ensure your implementation aligns with their expectations.
Stay Updated: Monitor changes in DORA and NIS2 requirements to keep your implementation current.