Chapter 1: The Compliance Wake-Up Call
Generale Bank, a mid-sized European financial institution, prided itself on its cutting-edge digital services. However, the rapid evolution of cybersecurity threats and stringent regulatory changes were proving to be a challenge. The European Union’s Digital Operational Resilience Act (DORA) and the Network and Information Security Directive 2 (NIS2) were on the horizon, both aimed at enhancing cybersecurity and operational resilience, but with different focuses and requirements.
One morning, the bank’s Compliance Officer, Karin Printemps, received an urgent memo from the board: “We need to comply with both DORA and NIS2 by the deadline. Map out the requirements and gaps immediately.”
With regulatory scrutiny increasing, Karin knew the bank’s future depended on how efficiently they tackled these regulations.
Chapter 2: Understanding the Regulatory Landscape
Karin gathered her team of cybersecurity and compliance experts. The first order of business was understanding where DORA and NIS2 overlapped and where they diverged.
- DORA: Specifically targeted financial entities, including banks, insurers, and investment firms. Its core focus was on ensuring the resilience of ICT services, mandating comprehensive risk management, third-party oversight, incident reporting, and resilience testing.
- NIS2: Applied more broadly to essential and important entities, including banking but also covering energy, healthcare, digital infrastructure, and public administration. It emphasized network security, governance obligations, and cross-border collaboration on cyber threats.
The challenge? DORA was highly prescriptive, requiring detailed ICT risk assessments and testing procedures, while NIS2 focused on overall cybersecurity governance and cooperation.
Chapter 3: A Crisis Exposes Gaps
A week into their compliance strategy, Generale Bank suffered a DDoS attack that disrupted its online banking services for several hours. The incident response team reacted swiftly, mitigating the impact, but the attack exposed several compliance gaps:
- DORA’s stricter requirements on resilience testing and incident response meant Generale Bank’s existing tabletop exercises were insufficient.
- NIS2’s mandates for broader incident disclosure forced them to report to the national cybersecurity agency within 24 hours, something they were not fully prepared for.
- Supply chain security was a weak point, as DORA imposed rigorous third-party risk assessments that the bank hadn’t fully implemented yet.
Karin realized that while both regulations aimed for cyber resilience, their scope and reporting obligations differed, making a unified compliance strategy challenging.
Chapter 4: Finding the Balance
The team devised a dual compliance strategy:
Aligning Cyber Resilience Testing with DORA
- Implemented advanced penetration testing and scenario-based stress tests to meet DORA’s ICT risk management requirements.
- Conducted resilience assessments on all third-party ICT service providers.
- Enhancing Governance and Information Sharing under NIS2
- Developed a structured incident reporting framework to comply with NIS2’s mandatory breach notification timelines.
- Increased coordination with the national cybersecurity authority and financial regulators, ensuring compliance with cross-sector requirements.
Unified Incident Response Approach
- Established a joint Security Operations Center (SOC) that merged DORA’s operational resilience focus with NIS2’s broader cybersecurity mandates.
- Created a real-time threat intelligence sharing program across both financial and non-financial sectors, enhancing defense capabilities.
Chapter 5: The Compliance Milestone
Months of intense preparation paid off. When an EU regulator conducted an audit, Generale Bank demonstrated its full compliance with DORA and NIS2, highlighting its:
- Integrated cyber resilience framework
- Cross-sector cybersecurity collaboration
- Proactive supply chain risk management
Despite their differences, DORA and NIS2 had been harmonized into a single operational strategy that strengthened ArdentBank’s resilience.
As Karin looked at the final compliance report, he knew the real success wasn’t just ticking regulatory boxes—it was ensuring that Generale Bank was truly prepared for the evolving threat landscape of the financial sector.
Thanks to Karin the storm had been weathered, but vigilance was the new norm.
