July 29, 2025 • Mary Marshall
DORA Compliance: How Financial Institutions Can Achieve Identity Resilience
Discover how Avatier’s comprehensive identity management solutions help financial institutions meet DORA compliance requirements.

When the EU dropped DORA last year it felt kind of like a tidal wave for banks. I remember my buddy Marco at FinBank saying, “We might need a whole new way to keep the passwords safe.” The law kicks in Jan 2025, so everyone’s scrambling.
What DORA really asks for
DORA basically says: “Show us you can keep the digital doors locked, even when the power’s out.” It covers every type of money‑place – banks, insurers, even the little payment apps that let you split pizza bills.
For the folks who handle who‑gets‑in‑what‑system, DORA drops a few must‑dos. A recent survey from EY (yeah, that big consulting firm) says only about one‑in‑four banks feel ready. That means most are probably pulling all‑nighters trying to patch things up.
The big identity rules
1. Access control that actually works
DORA wants the “least privilege” thing – only give people what they need, no extra fluff. It also says you must split duties: the person who can move money can’t also approve it.
- Review who can see the vault data every quarter.
- Keep logs that actually show who clicked what.
FinBank tried rolling out a spreadsheet to track this, but the sheet got huge and broke after a few weeks. The point? You need automation, not a manual list that melts under pressure.
2. Authentication that isn’t a nightmare
Multi‑factor is mandatory for any system that holds personal accounts. Think SMS codes, push notifications, maybe even a fingerprint.
Risk‑based login is also mentioned – if you’re logging in from a new city the system should ask for an extra step.
At EuroTrust they once let a guy use just a password to access the loan server (big oops). After that they switched to a hardware token that lights up when you press a button. It’s slower, but no one complained once they got used to it.
3. Governance that actually sees the picture
You can’t just set rules and walk away. DORA wants ongoing checks:
- Quarterly access recertification (the fancy way of saying “do we still need you?”).
- Spot weird combos – like a teller who can also change interest rates.
One bank used an old tool that flagged nothing because its rules were outdated. Updating the rule set fixed the blind spot in weeks before an audit.
4. Privileged accounts need extra love
People with admin rights are high‑value targets. DORA says you should give them rights just when they need them – “just‑in‑time” access – and record every click.
A small credit union tried giving its IT guy permanent admin rights on their core system. After a phishing email got through, the hacker walked straight to the database. That taught them to use time‑limited tokens instead.
Mixing identity with overall ICT risk
DORA isn’t just about passwords; it wants identity tied into the whole risk picture.
- Plug identity data into the broader risk dashboard so the CFO can see it.
- When you vet a third‑party vendor, check what identities they’ll get.
- Make sure identity services stay up during a blackout – think offline login cards or backup auth servers.
My own experience: I once helped set up a backup authentication server for a regional bank. We used a tiny Raspberry Pi that could run a local LDAP copy if the main data center went dark. It worked during a storm test and saved them from a whole day of downtime.
A tool that might help (but not perfect)
There are many products out there, Avatier being one of them. It claims to do lifecycle management, MFA integration, privileged access and more – all in one bundle.
The good bits: pre‑built templates that map to DORA’s checklist, containerised deployment that can spin up fast in another region if the first one crashes.
The not‑so‑good bits: the UI feels like it was built by engineers for engineers. Some smaller banks said their staff needed extra training just to click through the dashboards.
Other vendors like Okta or Ping also have heavy‑weight solutions, but they often need consultants for months – which could push you past the Jan 2025 deadline.
A realistic rollout plan (with hiccups)
Phase 1 – Know where you stand
- Walk through every identity process and match it against DORA clauses.
- Spot gaps – maybe you don’t have MFA on your loan approval app yet.
- Set simple KPIs: % of accounts with MFA, % of privileged sessions logged.
Phase 2 – Core pieces first
- Deploy an IAM core that can handle user provisioning (no more spreadsheets).
- Turn on MFA for everything that deals with money transfers.
- Start basic access reviews – ask managers “do we still need this?”
Phase 3 – Tighten the screws
- Add privileged access management with just‑in‑time tickets.
- Enable risk‑based authentication – if login is from a foreign IP ask for extra code.
- Hook identity logs into the enterprise SIEM for continuous monitoring.
Phase 4 – Test, tweak, repeat
- Run a tabletop drill where an admin account is compromised – see if your response workflow fires.
- Simulate a data‑center outage and check if backup auth works (the Raspberry Pi idea again).
- Document everything for the regulator – simple screenshots and short write‑ups are fine.
Looking beyond DORA
Regulations will keep changing. AI‑driven risk scoring may become mandatory soon – imagine a system that flags “this user’s pattern looks risky” before anything bad happens.
Zero‑trust is another buzzword that actually fits DORA: always verify identity, never assume trust based on network location.
And blockchain? Some fintech startups are testing self‑sovereign IDs on public ledgers. If that becomes mainstream, your IAM needs an API that can talk to those networks without breaking compliance.
In plain speak
DORA isn’t just a checklist you tick once and forget. It’s more like a habit you build into daily ops. If you lean on automated tools, keep the UX simple for your staff, and practice incident drills, you’ll be in good shape when Jan 2025 rolls around.
Sure, no tool is perfect – Avatier’s suite helps with many DORA parts but still needs training and fine‑tuning. The key is to start early, keep things human (people still press buttons), and never assume your security won’t be tested again.
So if you’re at FinBank or any other money firm, grab a coffee, map your identity flow, and start plugging those gaps now. The sooner you do it, the less likely you’ll be scrambling when regulators knock on your door – and maybe you’ll even sleep a bit better at night knowing your passwords aren’t an open invitation for hackers.









