ComparisonDORA and PSD2 incidents

DORA vs PSD2 incident reporting

A cited-source comparison of DORA major ICT-related incident reporting and PSD2 major operational or security payment-related incident reporting.

Use it to separate which incident clock, report template, competent authority route, and evidence pack applies when a payment-service incident is also an ICT incident.

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

Since DORA became applicable on 17 January 2025, payment service providers within DORA report under DORA rather than the PSD2 Article 96 incident-reporting route. The same event may also be a major ICT-related incident, but the two classifications have separate definitions and should be recorded separately.

Side-by-side comparison

DORA major ICT-related incident reporting vs PSD2 payment-incident reporting

Use these rows to decide whether an incident belongs in the DORA incident-reporting chapter, a payment-incident analysis, or both evidence labels inside one coordinated incident file.

Review all sources
First framework
DORA major ICT-related incidents

DORA covers financial entities and requires major ICT-related incidents to be classified, reported to the relevant competent authority, and handled through DORA report stages and templates.

Second framework
PSD2 operational or security payment incidents

For DORA-scoped payment service providers, DORA states that PSD2 incident reporting ceases and that operational or security payment-related incidents are handled under the DORA reporting chapter.

Scope boundary

DORA major ICT-related incidents

Financial entities under DORA, including payment institutions, electronic money institutions, account information service providers, credit institutions, and other listed financial entities when an ICT-related incident affects their services, operations, clients, counterparts, data, or critical functions.

PSD2 operational or security payment incidents

Payment-service operational or security incidents for payment service providers. For payment service providers that are within DORA, PSD2 incident reporting gives way to DORA reporting for those incidents.

Operational implication

For a DORA-scoped payment service provider, classify the incident under DORA first and preserve a payment-related incident label where the facts show payment-service operational or security impact.

Covered actors

DORA major ICT-related incidents

DORA uses the financial-entity scope in Article 2 and Article 23. The Article 23 payment-incident extension matters only for credit institutions, payment institutions, account information service providers, and electronic money institutions that are inside DORA.

PSD2 operational or security payment incidents

DORA states that the PSD2 Article 96 reporting requirement ceases for payment service providers that fall within DORA. It does not establish a universal replacement rule for every entity or every national notification connected with payment services.

Operational implication

Confirm the entity's DORA status and the competent authority's current filing route. If DORA does not displace a requirement, check the applicable national PSD2 implementation and any separate sectoral notification duty rather than assuming a legacy form still applies unchanged.

Reporting clocks and classification

DORA major ICT-related incidents

DORA has specified clocks: initial report as early as possible, within four hours after major classification and no later than 24 hours after awareness; intermediate report within 72 hours after the initial notification; final report within one month after the intermediate report or latest updated intermediate report. If major classification occurs after the first 24 hours from awareness, the initial notification is due within four hours of that later classification.

PSD2 operational or security payment incidents

The former PSD2 route used its own major operational or security incident analysis under Article 96 and EBA guidance. For DORA-scoped payment service providers, the DORA classification RTS and reporting RTS now control the Union-level incident report.

Operational implication

Use the DORA clock for in-scope payment service providers. Keep the awareness time, major-classification time, submission times, threshold calculations, estimates based on comparable periods, and any delay explanation in the incident file.

Report templates and other notification duties

DORA major ICT-related incidents

DORA uses standard templates for initial, intermediate, and final reports, with data fields completed according to the reporting stage and submitted through the secure electronic channels made available by the competent authority.

PSD2 operational or security payment incidents

DORA removes PSD2 Article 96 reporting only for payment service providers within DORA. Other reporting duties, including national, prudential, data-protection, law-enforcement, or customer-communication duties, require their own legal analysis.

Operational implication

Build the regulator report around the DORA template when DORA applies, then record every additional notification separately with its own trigger, recipient, deadline, and submission evidence.

Evidence record

DORA major ICT-related incidents

Keep DORA classification evidence, incident logs, affected clients and transactions, downtime, Member State impact, data-loss assessment, critical-service impact, cost and loss estimates, business-continuity activation, report templates, and final root-cause and remediation evidence.

PSD2 operational or security payment incidents

Where DORA does not displace a payment-services reporting duty, keep the entity-scope analysis, payment-service impact, applicable national PSD2 provision, current authority instructions, and submission evidence.

Operational implication

Use shared facts, but label each item. One incident file can support both views only if it shows the DORA classification basis and the payment-service impact separately.

Reporting recipients and national routes

DORA major ICT-related incidents

DORA reports go to the relevant competent authority. Where an entity is supervised by more than one national competent authority, Member States designate a single competent authority for Article 19 reporting. Significant credit institutions report to the national competent authority, which transmits the report to the ECB.

PSD2 operational or security payment incidents

Where DORA does not displace a payment-services reporting duty, the applicable national PSD2 implementation and competent-authority instructions determine the filing route and timing.

Operational implication

Do not send duplicate DORA reports merely because an entity has multiple authorisations. Confirm the relevant DORA competent authority and separately identify any surviving national or sectoral notifications.

Enforcement

DORA major ICT-related incidents

DORA gives competent authorities powers to supervise and sanction breaches of the DORA reporting regime for in-scope financial entities.

PSD2 operational or security payment incidents

PSD2 remains relevant outside the reporting requirement that DORA expressly displaces, and national law remains relevant to supervision and sanctions. The applicable authority and measure depend on the entity, breach, and Member State.

Operational implication

Tie each filing and control to its governing provision and competent authority. Do not infer that a DORA submission closes a different national or sectoral duty.

Overlap and reuse

DORA major ICT-related incidents

One incident can sit in both ICT and payment files, but DORA and PSD2 should not be treated as interchangeable. DORA Article 23 is a scope rule, not a blanket replacement for all payment incidents.

PSD2 operational or security payment incidents

For a payment service provider within DORA, use the DORA reporting chapter for . If DORA does not displace a requirement, verify the national PSD2 rule and current authority instructions.

Operational implication

Decide entity scope, classify the incident under each applicable DORA category, and list any additional notification duties. Shared facts can be reused, but each legal conclusion needs its own evidence.

Practical decision rule

DORA major ICT-related incidents

If the payment service provider is within DORA, classify the event as a payment-related incident and, separately, as an ICT-related incident. Report it when the applicable DORA major-incident test is met.

PSD2 operational or security payment incidents

If DORA does not displace the reporting duty, determine the applicable national PSD2 rule, competent-authority guidance, form, and clock. The EBA Guidelines on major incident reporting under PSD2 were repealed on 17 January 2025.

Operational implication

Record four answers: entity scope, payment-incident classification, ICT-incident classification, and every required notification route.

Practical decision rule

Practical triage rule for DORA and PSD2 incident reporting

  • Check whether the payment service provider falls within DORA and identify the relevant competent authority.
  • Classify the event separately as an operational or security payment-related incident and as an ICT-related incident; apply the relevant major-incident thresholds to each classification.
  • When DORA applies, use its report stages, time limits, template, and competent-authority submission route.
  • List any other national or sectoral notification duties and keep separate evidence for their triggers, recipients, clocks, and submissions.
Section 1

The main difference

PSD2 Article 96 was the EU-level payment-services incident-reporting route. DORA now brings major ICT-related incidents, voluntary significant cyber-threat notifications, and into its harmonised reporting chapter for the payment-sector entities listed in Article 23.

For a credit institution, payment institution, account information service provider, or electronic money institution within DORA, first decide whether the event is an operational or security payment-related incident and whether it is major under the DORA classification rules. Then assess separately whether it is also a major ICT-related incident. Do not assume that meeting one classification automatically meets the other.

  • DORA Article 17 requires an ICT-related incident management process that records incidents and significant cyber threats, assigns roles, escalates major incidents, and supports response and recovery.
  • DORA Article 18 sets classification criteria for ICT-related incidents, including affected clients or transactions, duration, geographical spread, data losses, criticality of affected services, and economic impact.
  • DORA Article 23 applies the reporting chapter to operational or security payment-related incidents concerning credit institutions, payment institutions, account information service providers, and electronic money institutions.
  • Delegated Regulation (EU) 2024/1772 requires affected critical services and either successful malicious unauthorised access not covered by Article 9(5)(a) that may result in data losses under Article 9(5)(b), or at least two other materiality thresholds. Other forms of data loss do not by themselves replace the two-threshold test.
Section 2

Reporting stages and clocks

DORA reporting is staged through an initial notification, an intermediate report, and a final report. Financial entities use the prescribed DORA template and the secure electronic channels made available by the competent authority.

The initial notification is due as early as possible, within four hours after classification as major and no later than 24 hours after awareness of the incident. The intermediate report is due within 72 hours after the initial notification, even if the incident has not recovered. The final report is due no later than one month after the intermediate report or, when an updated intermediate report was submitted, no later than one month after the latest update. If classification as major occurs after the first 24 hours from awareness, the initial notification is due within four hours of that later classification. Article 5 of Regulation (EU) 2025/301 separately qualifies weekend and bank-holiday deadlines.

  • Initial notification: incident reference, detection and classification information, description, classification criteria, impacted Member States, discovery route, origin where available, business-continuity activation, and reclassification information where applicable.
  • Intermediate report: occurrence and recovery timing, classification detail, incident type, threat techniques where applicable, affected business processes and infrastructure, client financial impact, other-authority reporting, temporary recovery measures, and indicators of compromise where applicable.
  • Final report: root causes, resolution timing, permanent resolution, resolution-authority information where applicable, direct and indirect costs and losses, recoveries, and recurring-incident information where applicable.
Section 3

Evidence to keep separate

A payment incident can share facts with an ICT incident, but the evidence labels should stay separate. ICT classification evidence must show how DORA Article 18 and Delegated Regulation (EU) 2024/1772 were applied. Payment-incident evidence must show why the event affected the availability, authenticity, integrity, or confidentiality of payment-related data, systems, or services, and how the payment-specific major-incident test was applied.

Keep enough evidence to explain both the incident decision and the report content: logs, service downtime records, transaction impact, affected clients or financial counterparts, Member State impact, data-loss analysis, business-continuity activation, customer communications, other-authority reporting, root-cause analysis, remediation, and cost or loss estimates.

  • Label whether the incident was classified as a major ICT-related incident, a major operational or security payment-related incident, both, or neither.
  • Record the awareness time, classification time, report submission times, any delay explanation sent to the competent authority, and any reclassification from major to non-major.
  • Keep the template fields and source citations with the incident file so later reviewers can see why each reported field was required.
Incident reporting support

Turn this comparison into a report-ready incident workflow

Sorena can help structure DORA incident classification, payment-incident triage, report-stage evidence, and source citations for teams preparing regulator-facing incident records.

Primary sources

References and citations

eur-lex.europa.eu14 citations
Referenced sections
  • Primary DORA source for incident management, Article 18 classification criteria, Article 19 reporting to competent authorities, Article 20 templates, Article 21 centralisation study, Article 22 feedback, Article 23 payment-related incident coverage, and the PSD2 reporting transition for in-scope payment service providers.
  • Supports this page's analysis of DORA rule that PSD2 incident reporting ceases for in-scope payment service providers and that operational or security payment-related incidents are handled under the DORA incident-reporting chapter.
  • DORA Article 2 lists covered financial entities.
Show 11 more
  • Supports the transition from PSD2 incident reporting to DORA reporting for in-scope payment service providers.
  • Supports applying the DORA reporting chapter to operational or security payment-related incidents concerning the listed payment-sector entities.
  • Sets the DORA scope for payment-sector entities and the Article 23 carve-in for payment-related incidents.
  • Supports the rule that PSD2 incident reporting ceases only for payment service providers that fall within DORA.
  • Supports the decision rule for choosing between DORA and PSD2 based on DORA scope.
  • Supports DORA Article 19 reporting to the relevant competent authority and onward transmission to ECB or other authorities where applicable.
  • Supports checking national additional submission rules to competent authorities or CSIRTs under DORA Article 19.
  • DORA Article 50 gives competent authorities the powers necessary to supervise, investigate, and sanction breaches.
  • DORA Article 23 applies the reporting chapter to both operational or security payment-related incidents and major operational or security payment-related incidents concerning the listed payment-sector entities.
  • DORA Articles 3 and 23 distinguish payment-related incidents from ICT-related incidents and apply the reporting chapter to the listed payment-sector entities.
  • Supports the DORA scope, Article 19 reporting route, and Article 23 payment-related incident coverage used in the triage rule.
"major operational or security payment-related incidents"
More quoted passages
"the requirement for the incident reporting pursuant to Directive (EU) 2015/2366"
"shall collectively be referred to as ‘financial entities’"
"report pursuant to this Regulation"
"operational or security payment-related incidents"
"credit institutions, payment institutions, account information service providers, and electronic money institutions"
"shall also apply"
"relevant competent authority"
"Member States may additionally determine"
"all supervisory, investigatory and sanctioning powers necessary"
"operational or security payment-related incidents and to major operational or security payment-related incidents"
"whether ICT-related or not"
"Reporting of major ICT-related incidents"
eur-lex.europa.eu7 citations
Referenced sections
  • Specifies the content and time limits for initial notifications, intermediate reports, final reports, and voluntary significant cyber-threat notifications.
  • Supports the DORA initial, intermediate, and final report content requirements and the four-hour, 24-hour, 72-hour, and one-month reporting limits.
  • Supports the report-content evidence fields for initial, intermediate, and final DORA incident submissions.
Show 4 more
  • Supports the four-hour, 24-hour, 72-hour, and one-month DORA reporting deadlines.
  • Supports recording delay explanations when the financial entity cannot submit within the specified limits.
  • Supports the required information categories for DORA initial, intermediate, and final reports.
  • Supports the DORA reporting stages and time limits used in the triage rule.
"Time limits for the initial notification"
More quoted passages
"initial notification, the intermediate report, and the final report"
"Specific information to be provided"
"within four hours"
"explain the reasons for the delay"
"Final reports"
"Time limits"
eba.europa.eu5 citations
Referenced sections
  • Official EBA notice confirming that the PSD2 major-incident-reporting Guidelines were repealed on 17 January 2025 because of DORA.
  • Official EBA notice explaining that PSD2 incident reporting can remain for PSP types outside DORA and may be retained through national law or supervisory measures.
  • Official EBA notice explaining that PSPs still subject to PSD2 incident reporting can be subject to national incident-reporting requirements.
Show 1 more
  • Official EBA notice confirming the repeal date and explaining the national-law position for PSPs still subject to PSD2 incident reporting.
"repealed its Guidelines on major incidents reporting under the Payment Services Directive (PSD2)"
More quoted passages
"incident reporting requirements under PSD2 still apply for other types of PSPs"
"can be subject to national incident reporting requirements"
"continue to do so under their national legal framework or supervisory measures"
eur-lex.europa.eu4 citations
Referenced sections
  • Specifies DORA classification criteria and materiality thresholds for major ICT-related incidents and major operational or security payment-related incidents.
  • Supports the classification evidence categories for clients, transactions, duration, geographical spread, data losses, critical services, and economic impact.
  • Supports using classification evidence instead of a generic incident label.
"materiality thresholds"
More quoted passages
"classification criteria"
"clients, financial counterparts and transactions"
"affected transactions"
eur-lex.europa.eu4 citations
Referenced sections
  • Establishes the DORA standard forms, templates, data glossary, and reporting procedures for major ICT-related incidents and significant cyber-threat notifications.
  • Supports the requirement to use the DORA reporting template, competent-authority secure electronic channels, and the data glossary and instructions.
  • Supports use of the DORA template, secure electronic channels, data glossary, and update procedure.
Show 1 more
  • Supports completing stage-specific fields and updating prior information in later reports.
"single reporting template"
More quoted passages
"standard forms, templates, and procedures"
"secure electronic channels"
"update any information"
eur-lex.europa.eu
Referenced sections
  • PSD2 requires Member States to designate competent authorities and set penalties for infringements of national transposing law.
"Member States shall lay down rules on penalties applicable to infringements of the national law transposing this Directive"
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