A practical way to decide whether DORA applies - and what layer applies.
Designed to output a scope memo you can defend in audits and supervisory discussions.
Structured answer sets in this page tree.
Cited legal and guidance references.
DORA applicability is a structured decision: you classify each legal entity, map it to Article 2 scope, decide proportionality/simplification, and identify which obligations attach (controls, reporting, testing, third-party governance). This applicability test is written for implementation teams so the output is actionable, not just legal interpretation.
At the end of this test you should have a scope memo per regulated entity and a group summary. This memo becomes the backbone for your requirements matrix, roadmap, and evidence pack.
Most teams fail by skipping this artifact and immediately building controls without tier clarity.
Start with legal facts: what regulated category are you, and what license/authorization do you hold?
DORA scope is defined by the covered financial entity list in Article 2.
DORA requires applying the proportionality principle: controls and testing intensity can scale with size, complexity, and risk profile.
Document your proportionality decision as a management body artifact and review it periodically.
Once you're in scope, DORA becomes an implementation program across four main workstreams plus governance and cooperation.
Use this as your workstream inventory and owner assignment checklist.
Some obligations, especially around ICT third-party risk, operate at entity level and also at sub-consolidated and consolidated levels.
If you have centralized vendor management, ensure entity-level supervisory requests can still be answered quickly.
Even if you're not a covered financial entity, you may be impacted as an ICT third-party provider supporting critical or important functions for in-scope entities.
Financial entities will demand contract clauses aligned to DORA RTS; critical designation adds oversight exposure.
Assessment Autopilot can take EU DORA Applicability Test from deciding whether these obligations apply in practice to a reusable workflow inside Sorena. Teams working on EU DORA can keep owners, evidence, and next steps aligned without copying this guide into separate documents.
Start from EU DORA Applicability Test and turn the guidance into owned tasks, evidence requests, and review checkpoints.
Review your current process, evidence gaps, and next steps for EU DORA Applicability Test.