Compliance CalendarEU

EU DORA deadlines and compliance calendar

Use this page to calendar DORA dates and recurring evidence work for financial entities: application, incident reporting, the register of information, annual reporting, TLPT, and critical ICT third-party oversight.

The dates below are based on DORA, delegated and implementing regulations, and ESA publications. They are not a substitute for the competent authority calendar that applies to a specific financial entity.

Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
Overview

DORA calendar work should separate fixed legal dates from event-triggered clocks. The fixed anchor is 17 January 2025, when Regulation (EU) 2022/2554 began to apply. After that, most useful calendar entries are recurring or trigger-based: classification and reporting of a , register-of-information updates and annual reporting, TLPT cycles for identified entities, and oversight milestones for critical ICT third-party providers.

Section 1

Fixed DORA dates to put on the compliance calendar

Start the calendar with the legal application date and the implementation instruments that change how teams report or maintain evidence. DORA was published in the Official Journal on 27 December 2022, entered into force on 16 January 2023, and applies from 17 January 2025.

For evidence planning, keep separate calendar rows for the 2024 register templates, the 2025 major incident reporting RTS and ITS, the 2025 TLPT criteria RTS, and the ESA publication of the first list of designated critical ICT third-party providers. These milestones do not replace entity-specific supervisory submissions, but they explain which template, clock, or oversight framework the entity should be using.

  • 27 December 2022: DORA was published in the Official Journal.
  • 16 January 2023: DORA entered into force.
  • 2 December 2024: Implementing Regulation (EU) 2024/2956 on register-of-information templates was published in the Official Journal.
  • 17 January 2025: DORA applies.
  • 20 February 2025: Delegated Regulation (EU) 2025/301 on major incident notification and report time limits, and Implementing Regulation (EU) 2025/302 on reporting forms, templates, and procedures, were published in the Official Journal.
  • 18 June 2025: Delegated Regulation (EU) 2025/1190 on TLPT identification criteria and process requirements was published in the Official Journal; it entered into force on 8 July 2025.
  • 18 November 2025: the ESAs published the first list of designated critical ICT third-party providers under DORA.
Section 2

Event-triggered major ICT incident reporting clocks

Do not calendar major incident reporting as a single annual date. Calendar it as a playbook clock that starts when an ICT-related incident is detected, assessed, and classified as major under the DORA incident-classification rules.

Delegated Regulation (EU) 2025/301 sets the time limits. The initial notification is due as early as possible, within four hours from classification as major, and no later than 24 hours from when the financial entity became aware of the incident. If the entity classifies the incident as major only after the first 24 hours, the initial notification is due within four hours from that later classification. The intermediate report is due within 72 hours from the initial notification. The final report is due no later than one month after the intermediate report, or after the latest updated intermediate report.

  • Calendar trigger: incident detected, awareness time recorded, classification assessment opened, and major-incident classification time recorded.
  • Recurring-incident review: assess at least monthly whether non-major incidents occurred at least twice within six months, share the same apparent root cause, and collectively meet the major-incident test. This aggregation rule does not apply to microenterprises or Article 16 entities.
  • Initial notification evidence: detection time, classification time, classification criteria, affected entity information, contact points, description, and available impact data.
  • Intermediate report evidence: updated incident status, impact, mitigation and recovery actions, and any change since the initial notification.
  • Final report evidence: resolution dates and times, root cause, costs and losses where applicable, resolution information, and recurring-incident information where applicable.
  • Dependency to track: Implementing Regulation (EU) 2025/302 supplies the reporting templates and allows combined submissions only where recovery or root-cause analysis is complete and the Delegated Regulation (EU) 2025/301 time limits are still met.
  • Delay handling: if a deadline cannot be met, notify the competent authority no later than the missed deadline and explain the delay.
  • Weekend and bank-holiday rule: a deadline that falls on a weekend or bank holiday in the reporting entity's Member State may move to noon on the next working day, but this extension does not apply to initial notifications or intermediate reports from credit institutions, central counterparties, trading-venue operators, or entities identified as essential or important under NIS2. A competent authority may also disapply it for other significant or systemic financial entities after notifying them.
Section 3

Register-of-information and third-party risk calendar

The register calendar has two layers: an always-current operational register and the reporting rhythm required by DORA. DORA requires financial entities to maintain and update, at entity level and at sub-consolidated and consolidated levels, a register of information for all contractual arrangements on the use of ICT services provided by ICT third-party service providers.

DORA also requires at least yearly reporting to competent authorities on new ICT service arrangements, provider categories, contractual arrangement types, and the ICT services and functions provided. The register should therefore be updated when a contract starts, changes, ends, a supporting function becomes critical or important, or a subcontracting chain changes, and reviewed before the annual reporting cycle.

  • Standing owner: ICT third-party risk or outsourcing owner maintains the register, with legal, procurement, technology, and business-service inputs.
  • Calendar triggers: new ICT service contract, contract amendment, exit or termination, supplier change, intra-group ICT service change, subcontractor change, or a function becoming critical or important.
  • Annual reporting evidence: count of new arrangements, ICT third-party service provider categories, contractual arrangement types, ICT services, and supported functions.
  • Template evidence: contractual arrangement reference number, financial entity LEI and country, date of last update, date of integration, start date of contractual arrangement, ICT service type, and critical-or-important function indicators where required by the template.
  • Authority-request evidence: the full register, specified sections of the register, and supporting information needed for effective supervision.
  • Template maintenance: track the 19 September 2025 corrigendum to Implementing Regulation (EU) 2024/2956 when validating register template fields.
Section 4

TLPT and resilience testing cadence

DORA creates both general resilience-testing cadence and advanced TLPT cadence. Financial entities other than microenterprises must ensure, at least yearly, appropriate tests on all ICT systems and applications supporting critical or important functions. Article 16 entities and microenterprises are outside the TLPT duty. Other financial entities identified by the competent or designated TLPT authority must carry out advanced testing by means of TLPT at least every three years, unless the competent authority changes the frequency based on risk profile and operational circumstances.

For TLPT, the compliance calendar should start when the TLPT authority notifies the financial entity that a TLPT is to be carried out. Delegated Regulation (EU) 2025/1190 then creates planning and closure dependencies: initiation information within three months of that notification, scope specification within six months, active red team testing lasting at least 12 weeks, a red team report within four weeks after active testing ends, and the blue team report, replay, and purple teaming no later than 10 weeks after active testing ends. After the TLPT authority confirms that the red and blue team reports contain the required information, the financial entity has eight weeks to submit both the summary report and the remediation plan and supporting documentation.

  • Annual testing row: test ICT systems and applications supporting critical or important functions, log findings, remediation ownership, validation evidence, and management review.
  • Three-year TLPT row for identified entities: maintain the next TLPT due date, competent-authority frequency changes, and whether the prior test used internal or external testers.
  • Authority notification trigger: open TLPT initiation tasks, project charter, control team, tester and threat-intelligence provider procurement, communication channels, and code name.
  • Scope dependency: include several or all critical or important functions and live production systems supporting those functions; competent authorities validate the TLPT scope.
  • Closure evidence: red team report, blue team report, replay and purple teaming outcomes, summary findings report, remediation plan, and TLPT attestation records.
  • Tester dependency: DORA requires external testers at least every three tests when the entity uses internal testers.
Section 5

Critical-provider oversight dates are separate from financial-entity filing dates

The ESA designation of a critical ICT third-party service provider does not create a new general filing deadline for every customer financial entity. It starts an EU oversight relationship between the designated provider and its Lead Overseer. Financial entities should still track the designation because supervisory recommendations to a provider can affect service risk, remediation, and, as a last resort, continued use of the service.

A designated provider has 60 calendar days after receiving a Lead Overseer recommendation to state that it intends to follow the recommendation or give a reasoned explanation for not doing so. Separately, if the provider does not comply with a Lead Overseer information request, investigation, or inspection measure, a periodic penalty-payment decision can follow only after at least 30 calendar days from notification of that measure. Both clocks apply to provider oversight; the major-incident reporting clocks apply to financial entities.

  • Financial-entity calendar trigger: notice that a relied-on provider has been designated critical, a competent authority communicates an unaddressed risk, or a recommendation affects a contracted service.
  • Provider response clock: 60 calendar days from receipt of a Lead Overseer recommendation to state an intention to follow it or provide a reasoned explanation.
  • Penalty-payment precondition: at least 30 calendar days must pass after the critical provider receives notice of a required information, investigation, or inspection measure with which it wholly or partly fails to comply.
  • Customer action: reassess the affected service, concentration and exit risks, contractual rights, continuity measures, and register data; follow any competent-authority direction that applies to the financial entity.
  • Last-resort outcome: a competent authority may require temporary suspension or termination of the service arrangement when the Article 42 conditions are met; the ESA designation alone does not require termination.
Section 6

Practical evidence calendar fields

Each DORA calendar row should show the date or trigger, legal source, responsible owner, required evidence, and any authority or template dependency.

Use separate row types for fixed milestones, event-triggered clocks, recurring reviews, authority-request items, and template-maintenance changes. That separation prevents teams from treating incident reports, register updates, and TLPT cycles as the same kind of deadline.

  • Date or trigger: fixed calendar date, annual review month, authority notification, incident awareness time, major classification time, contract start or change, or template corrigendum.
  • DORA area: ICT risk management, incident reporting, register of information, ICT third-party risk, TLPT, or CTPP oversight.
  • Affected cohort: all in-scope financial entities, entities other than microenterprises, identified TLPT entities, entities with ICT third-party arrangements, or designated CTPPs.
  • Clock rule: fixed date, at least yearly, at least every three years, within four hours, no later than 24 hours, within 72 hours, one month, three months, six months, 12-week minimum, four weeks, 10 weeks, eight weeks, 30 calendar days, or 60 calendar days.
  • Evidence required: source citation, owner, approval record, template version, submission copy, authority correspondence, register extract, test report, remediation plan, or attestation.
  • Reopen trigger: incident reclassification, missed reporting deadline, competent-authority request, contract change, function-criticality change, template corrigendum, TLPT authority notification, or CTPP designation update.
Recommended next step

Build a DORA calendar that tracks clocks, templates, owners, and proof

Sorena can help convert DORA incident, register, TLPT, and third-party-risk milestones into cited calendar rows with owners, evidence fields, and review triggers.

Primary sources

References and citations

eur-lex.europa.eu6 citations
Referenced sections
  • Primary DORA source for the application date, ICT resilience testing cadence, TLPT cadence, register maintenance and yearly reporting, and ICT third-party risk calendar triggers.
  • Supports the DORA publication, entry-into-force, and 17 January 2025 application anchors.
  • Supports the obligation to maintain and update the register and report at least yearly to competent authorities.
Show 3 more
  • Supports the yearly testing requirement for critical or important functions and the at-least-every-three-years TLPT cadence.
  • Articles 35 and 42 support the 30-day periodic-penalty precondition, the 60-day recommendation response, financial-entity notification of identified risks, and the last-resort suspension or termination process.
  • Supports the calendar categories covering ICT risk management, testing, incident reporting, and ICT third-party risk obligations.
"It shall apply from 17 January 2025."
More quoted passages
"maintain and update at entity level"
"at least every 3 years advanced testing"
"Within 60 calendar days of the receipt of the recommendations"
"digital operational resilience for the financial sector"
eur-lex.europa.eu3 citations
Referenced sections
  • Source for TLPT identification criteria, initiation, scope, testing, closure, remediation, and authority-validation milestones.
  • Supports the 18 June 2025 Official Journal publication and entry into force on the twentieth day after publication.
  • Supports TLPT identification criteria, notification-triggered initiation, scope, testing phase, closure, remediation, and authority-validation milestones.
"initiate a TLPT following a notification"
More quoted passages
"This Regulation shall enter into force on the twentieth day following that of its publication"
eur-lex.europa.eu3 citations
Referenced sections
  • Source for major ICT incident initial notification, intermediate report, final report, delay, and weekend or bank-holiday timing rules.
  • Supports the 20 February 2025 incident-reporting RTS milestone and the reporting clocks used later on this page.
  • Supports the four-hour, 24-hour, 72-hour, and one-month reporting clocks for major ICT-related incidents.
"within four hours from the classification"
More quoted passages
"content and time limits for the initial notification"
esma.europa.eu3 citations
Referenced sections
  • Source for the 18 November 2025 first ESA publication of designated critical ICT third-party providers under DORA.
  • Supports the 18 November 2025 publication of the first list of designated critical ICT third-party providers and the start of the provider oversight framework.
  • Supports the 18 November 2025 milestone for the first published list of designated critical ICT third-party providers.
"publish today the list of designated critical ICT third-party providers"
eur-lex.europa.eu3 citations
Referenced sections
  • Source for DORA register-of-information templates and fields used to calendar register updates and annual reporting evidence.
  • Supports the 2 December 2024 register-of-information template milestone and the standard template basis for register evidence.
  • Supports the standard register template fields and relational structure used for DORA register evidence.
"standard templates for the register of information"
More quoted passages
"contractual arrangement reference number"
eur-lex.europa.eu3 citations
Referenced sections
  • Source for standard forms, templates, secure electronic channels, outsourcing notice, reclassification notice, and aggregated reporting procedures for major ICT incidents.
  • Supports the 20 February 2025 publication date for the standard forms, templates, and procedures used to report major ICT-related incidents.
  • Supports the use of standard forms, templates, secure electronic channels, outsourcing notices, reclassification notices, and combined submissions for DORA incident reporting.
"standard forms, templates, and procedures"
eur-lex.europa.eu2 citations
Referenced sections
  • Source for the 19 September 2025 register-template corrigendum milestone.
  • Supports the September 2025 register-template corrigendum milestone for template maintenance checks.
"Corrigendum to Commission Implementing Regulation (EU) 2024/2956"
eur-lex.europa.eu2 citations
Referenced sections
  • Source for the classification dependency that determines when a DORA ICT-related incident becomes a major ICT-related incident.
  • Supports the incident-classification dependency before the major-incident reporting clocks can be applied.
"criteria for the classification of ICT-related incidents"

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