DORA Artifact GuideICT third-party contracts

DORA Contract Remediation Workflow

Remediate ICT third-party contracts by tracing each service to supported functions, required contract clauses, subcontracting conditions, exit rights, and register-of-information fields.

Pair this workflow with legal, procurement, ICT risk, outsourcing, operational resilience, service-owner, and register owners before signing, renewing, materially changing, or remediating DORA-relevant ICT service contracts.

Author
Sorena AI
Published
May 9, 2026
Updated
Jul 24, 2026
Sections
5

Structured answer sets in this page tree.

Primary sources
4

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated Jul 24, 2026
Overview

DORA has applied since 17 January 2025. Contract remediation starts with the service and supported function, then moves to the contract. For each ICT third-party arrangement, the financial entity needs to determine whether the service supports a , whether subcontracting is permitted, which contract terms apply, whether access and audit rights can be exercised, how exit would work, and how the arrangement is recorded in the register of information.

Section 1

1. Build the remediation inventory

Start with the register of information and procurement inventory, not with a blank contract template. DORA requires financial entities to maintain and update a register of information for contractual arrangements on the use of ICT services provided by ICT third-party service providers.

Create one remediation row per contractual arrangement and link it to the financial entity using the service, the signer, the direct ICT third-party provider, the supported function, the ICT service type, start and end dates, and any termination status. This lets the team identify which contracts need the additional Article 30(3) terms and which need only the baseline Article 30(2) terms.

DORA and the cited technical standards are binding. The remediation row, clause matrix, owner model, and close-out package below are practical workflow controls; they do not replace the required written contract, legal-entity assessment, or competent-authority process.

  • Inventory fields: contractual arrangement reference number, financial entity using the ICT service, direct ICT third-party provider identifier, function identifier, ICT service type, start date, end or renewal date, termination reason if applicable, governing law country, service provision countries, data storage and processing countries, and reliance level.
  • Criticality fields: whether the ICT service supports a , whether the function would suffer no significant, low, material, or full reliance impact from disruption, and whether subcontractors effectively underpin the service.
  • Owner fields: legal or outsourcing owner for the contract, ICT risk owner for the service risk assessment, business owner for the supported function, procurement owner for supplier remediation, and register owner for data quality.
  • Evidence to attach: current signed contract, statement of work or order form, service description, supplier and subcontractor list, due-diligence file, service reports, audit or assurance reports, exit plan, and register extract before and after remediation.
Section 2

2. Classify critical or important function support

For each contract, decide whether the ICT service supports a before selecting remediation depth. DORA defines a critical or important function by the effect of disruption, defective performance, or failed performance on financial performance, service continuity, authorisation conditions, or other financial-services-law obligations.

Where a contract supports a , the remediation file should also cover concentration risk, subcontracting chains, audit and access rights, business continuity, exit strategy, and notification to the competent authority for planned arrangements or when a function becomes critical or important.

  • Record the function and service in plain language: for example, payment processing platform, trading venue connectivity, customer authentication, core banking hosting, policy administration, reporting platform, or backup and recovery service.
  • Map the service to business impact: continuity, availability, customer or market impact, regulatory authorisation impact, data sensitivity, recovery objectives, and dependency on other ICT services.
  • Flag support where a disruption would materially impair financial performance, soundness or continuity of services, authorisation compliance, or other obligations under financial services law.
  • Document planned material changes: DORA requires timely information to competent authorities about planned ICT service arrangements supporting critical or important functions and when a function has become critical or important.
Section 3

3. Remediate mandatory contract terms

Use a clause matrix that separates Article 30(2) terms for every ICT service contract from the additional Article 30(3) terms for services supporting critical or important functions. Applying the enhanced list to every contract can hide a more serious error: omitting a baseline term from an ordinary ICT service arrangement.

Every ICT service contract must be in one written, downloadable, durable, and accessible document and cover the service and functions, service and data locations, data availability and protection, data access, recovery and return, service levels, incident assistance, cooperation with authorities, termination rights and notice periods, and conditions for provider participation in security-awareness and resilience training.

For contracts supporting critical or important functions, add full service levels with quantitative and qualitative targets, notice and reporting duties for developments that may materially affect delivery, tested business-contingency and ICT security commitments, participation and cooperation in TLPT where relevant, ongoing monitoring, access, inspection, and audit rights, and an exit transition period that lets the financial entity move to another provider or in-house delivery without disrupting the service.

  • Service description: complete description of functions and ICT services, including whether subcontracting of the ICT service or material parts is permitted and under what conditions.
  • Location and data: regions or countries of service provision, data processing and storage, and advance notice before location changes.
  • Performance and monitoring: service levels, performance targets, key performance indicators, key control indicators, reports on activities, incidents, ICT security, business continuity measures, and testing.
  • Audit and access: contract rights to information, inspections, audits, ICT testing, copies of relevant documentation where critical to operations, and cooperation during authority or appointed-third-party audits.
  • Exit and termination: termination rights, minimum notice periods, data return and recovery, portability or transition support, and an exit plan that is realistic, feasible, periodically reviewed, and tested.
Section 4

4. Fix subcontracting controls

Subcontracting review should be separate from general supplier due diligence. If an ICT third-party provider may subcontract ICT services supporting critical or important functions or material parts, the contract should say exactly which services may be subcontracted, the conditions for doing so, the provider's monitoring and reporting duties, and the financial entity's rights when subcontracting changes.

The financial entity should be able to identify subcontractors that effectively underpin the ICT service, assess the chain length and complexity, understand where subcontractors and data are located, consider concentration and transferability risks, and preserve equivalent access, inspection, and audit rights through the subcontracting chain. Reliance on the provider's subcontractor assessment does not remove the financial entity's responsibility for its own DORA obligations.

  • Before approval: assess whether the provider can select, assess, identify, notify, and inform the financial entity about subcontractors supporting critical or important functions.
  • Contract conditions: require the provider to remain responsible for subcontracted services, monitor subcontractors, report on them, assess location risks, ensure continuity through the chain, and impose business contingency and ICT security requirements downstream.
  • Change control: require advance notice of intended material subcontracting changes, time to assess risk, and approval or non-objection before implementation.
  • Risk-tolerance branch: if a notified material subcontracting change exceeds the financial entity's risk tolerance, object and request modifications before the notice period ends.
  • Termination branch: preserve the contractual right to terminate if the provider implements an objected-to material change despite the requested modifications, implements a material change before the notice period ends without approval, or subcontracts a service that the contract did not expressly permit it to subcontract.
Section 5

5. Close remediation with register updates and evidence

Do not close a remediation row when the contract is signed but the register and operating evidence still disagree. The close-out package should show the remediated clause set, the risk assessment result, the due-diligence and assurance basis, the subcontracting position, the exit plan, and the updated register fields. A residual-risk approval can record an unresolved issue, but it does not replace a contract term that DORA requires.

The evidence file should also show how the contract will be monitored after remediation. Delegated Regulation 2024/1773 expects documented monitoring of performance, reports, incident information, service delivery, ICT security, business continuity measures, testing, shortcomings, and updates to the risk assessment.

Close with one recorded outcome: execute the compliant amendment and update the register; keep the item open with a named owner and deadline while a non-mandatory residual risk is decided; or invoke the documented objection, termination, and exit branch when the provider will not accept a required term or an unacceptable subcontracting change. Reopen the row at renewal, material service or location change, function-criticality change, significant incident, adverse audit finding, or exit-plan failure.

  • Contract evidence: executed amendment or restated agreement, clause matrix showing Article 30 coverage, written material-change approvals, and renewal or change-control record.
  • Risk evidence: classification, due-diligence result, concentration-risk review, subcontractor assessment, location-risk review, assurance reports, and residual-risk approval where gaps remain.
  • Operational evidence: service reports, incident reports, ICT security reports, business continuity and testing evidence, audit plan or pooled-audit arrangement, and corrective-action tracking for supplier shortcomings.
  • Register evidence: updated contractual reference, provider identifiers, function identifiers, ICT service type, start and end or renewal dates, termination reason when relevant, notice periods, data and service locations, reliance level, and subcontractor chain records.
Primary sources

References and citations

eur-lex.europa.eu
Referenced sections
  • Article 30 lists the contractual elements for ICT services and the additional clauses for critical or important functions.
"full service level descriptions"
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