---
title: "DORA TLPT selection: who can be required to test?"
canonical_url: "https://www.sorena.io/artifacts/eu/digital-operational-resilience-act/faq/tlpt-selection"
source_url: "https://www.sorena.io/artifacts/eu/digital-operational-resilience-act/faq/tlpt-selection"
author: "Sorena AI"
description: "FAQ on DORA threat-led penetration testing selection: who identifies financial entities, what criteria are used, what the TLPT authority validates, and what evidence to keep."
published_at: "2026-05-09"
updated_at: "2026-05-09"
keywords:
  - "DORA TLPT selection"
  - "EU DORA threat-led penetration testing"
  - "TLPT authority"
  - "competent authority"
  - "TIBER-EU"
  - "EU DORA"
  - "DORA"
  - "TLPT"
  - "threat-led penetration testing"
  - "ICT risk management"
---
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# DORA TLPT selection: who can be required to test?

FAQ on DORA threat-led penetration testing selection: who identifies financial entities, what criteria are used, what the TLPT authority validates, and what evidence to keep.

*FAQ* *EU DORA*

## DORA TLPT Selection

DORA TLPT selection is not a voluntary self-label. Competent authorities or TLPT authorities identify which financial entities must perform threat-led penetration testing.

Use this FAQ to understand the selection criteria, authority involvement, readiness timeline, provider checks, scope evidence, remediation records, and attestation artifacts.

Under DORA, advanced testing by means of threat-led penetration testing (TLPT) applies to financial entities that are identified by the relevant authority. The practical question is therefore not whether every DORA entity must run TLPT, but whether the authority assessment, entity type, ICT risk profile, systemic importance, group/shared-system facts, and critical or important functions make TLPT required. Timings in this page are source-linked; verify current legal source language before implementation decisions.

## Who decides whether a financial entity must perform DORA TLPT?

The authority decision is central. DORA says financial entities identified under Article 26 must carry out TLPT at least every 3 years, and competent authorities identify those entities using impact, financial-stability, ICT-risk, maturity, and technology-feature criteria.

Commission Delegated Regulation (EU) 2025/1190 refines that selection process. It uses the term TLPT authority for the public authority, delegated national financial-sector authority, or competent authority responsible for TLPT-related tasks. That TLPT authority assesses whether a financial entity is required to perform TLPT, participates in every phase of the test, and validates key documents and decisions.

- Do not treat TLPT selection as a generic company-size threshold; the official criteria are financial-sector and ICT-risk specific.
- Track the authority that made or communicated the TLPT selection decision, especially where the TLPT authority and the competent authority are different.
- If the entity is part of a group that shares ICT systems or uses the same ICT intra-group service provider, capture whether authorities considered individual, joint, or pooled testing.
- If an entity believes TLPT is not justified despite meeting a listed category or quantitative criterion, record the authority assessment rather than relying on an internal exemption.

Sources for this answer:

- [Regulation (EU) 2022/2554 (DORA), Article 26](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32022R2554&ref=sorena.io) - Supports the Article 26 rule that identified financial entities perform TLPT at least every 3 years and that competent authorities identify entities using impact, financial-stability, ICT-risk, maturity, and technology criteria.
- [Commission Delegated Regulation (EU) 2025/1190 on DORA TLPT](https://eur-lex.europa.eu/eli/reg_del/2025/1190/oj/eng?ref=sorena.io) - Supports the TLPT authority role and the detailed criteria for identifying financial entities required to perform TLPT.

## Which financial entities may be identified for DORA TLPT?

Delegated Regulation 2025/1190 starts from the financial entity's impact, systemic character, and ICT risk profile. It points the TLPT authority to impact-related factors such as size, cross-border services, interconnectedness, criticality, substitutability, business-model complexity, and whether the entity belongs to a systemic group sharing ICT systems.

It also points to ICT-risk factors such as the entity's threat landscape, dependence of critical or important functions on ICT, ICT architecture complexity, use of ICT third-party or intra-group providers, supervisory review outcomes, business-continuity maturity, response-and-recovery maturity, and real-time monitoring, detection, analysis, and response capability.

- Entity categories expressly addressed include credit institutions, payment institutions, electronic money institutions, central securities depositories, central counterparties, trading venues, and insurance or reinsurance undertakings.
- The RTS also allows TLPT authorities to assess other types of financial entities where qualitative factors make TLPT appropriate.
- Meeting an entity-category or quantitative criterion is not the end of the analysis: the TLPT authority can assess whether impact, financial-stability concerns, or ICT risk profile justify TLPT.
- Microenterprises and entities under the simplified ICT risk management framework should not be treated as TLPT candidates unless a grounded authority position says otherwise.

Sources for this answer:

- [Commission Delegated Regulation (EU) 2025/1190 on DORA TLPT](https://eur-lex.europa.eu/eli/reg_del/2025/1190/oj/eng?ref=sorena.io) - Supports the impact, systemic-character, ICT-risk, entity-category, group/shared-system, and qualitative assessment criteria used for TLPT identification.
- [Regulation (EU) 2022/2554 (DORA), Recital 43 and Article 26](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32022R2554&ref=sorena.io) - Supports that only identified financial entities perform advanced TLPT and that microenterprises and simplified-framework entities are not the target of TLPT selection.

## What happens after a financial entity is selected for TLPT?

Selection triggers a supervised testing process, not an immediate red-team exercise. After notification from the TLPT authority, the financial entity must initiate TLPT and submit initiation information within 3 months. That information includes a project charter, control team lead contact details, intended use of internal or external testers, communication channels, and a code name.

The financial entity must then submit a scope specification document within 6 months of the authority notification. The management body approves the scope specification document, and the TLPT authority approves it if it is complete and supports an appropriate and effective TLPT.

- Appoint a control team lead responsible for day-to-day TLPT management and control-team decisions.
- Keep knowledge of planned or ongoing TLPT limited to the control team, management body, testers, threat intelligence provider, and TLPT authority on a need-to-know basis.
- Scope critical or important functions by considering their criticality, day-to-day importance, exchangeability, interconnectedness, geographic location, sector dependence, and available threat intelligence.
- Do not begin the testing phase until provider procurement or assignment is complete, the TLPT risk assessment has been consulted on with test managers, and authority validation points have been handled.

Sources for this answer:

- [Commission Delegated Regulation (EU) 2025/1190 on DORA TLPT](https://eur-lex.europa.eu/eli/reg_del/2025/1190/oj/eng?ref=sorena.io) - Supports the post-selection preparation sequence, including 3-month initiation information, 6-month scope submission, control-team setup, risk assessment, provider evidence, and TLPT authority approval.
- [Regulation (EU) 2022/2554 (DORA), Article 26](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32022R2554&ref=sorena.io) - Supports the requirement that TLPT covers several or all critical or important functions and is performed on live production systems supporting those functions.

## How should scope, providers, and authority validation be documented?

The scope record should explain why each critical or important function and supporting ICT system is included or excluded. Annex II to Delegated Regulation 2025/1190 requires the scope specification to list all critical or important functions identified by the financial entity and, for included functions, the relevant ICT systems, outsourcing status, ICT third-party provider, jurisdictions, and preliminary flags.

Provider selection also needs evidence. The control team must assess testers and threat intelligence providers against DORA Article 27 and the RTS requirements before contracting, provide evidence to test managers, and not proceed where the TLPT authority concludes that the selected providers or testers do not comply with the applicable requirements.

- Keep the function inventory, inclusion and exclusion rationale, supporting ICT systems, outsourced-system facts, provider names, jurisdictions, and preliminary flags.
- Keep provider CVs, appropriate certifications, professional indemnity insurance evidence, references, conflict checks, separation of threat-intelligence and tester staff where relevant, and restoration-procedure commitments.
- If internal testers are proposed, keep the authority approval, conflict-of-interest analysis, resource evidence, and proof that the threat intelligence provider is external.
- If pooled or joint TLPT is considered, keep the authority feasibility assessment, designated financial entity, lead TLPT authority, participating entities, shared ICT provider facts, and each entity's own risk assessment.

Sources for this answer:

- [Commission Delegated Regulation (EU) 2025/1190 on DORA TLPT](https://eur-lex.europa.eu/eli/reg_del/2025/1190/oj/eng?ref=sorena.io) - Supports scope specification content, provider-selection evidence, internal-tester conditions, pooled and joint TLPT coordination, and TLPT authority validation.
- [Regulation (EU) 2022/2554 (DORA), Articles 26 and 27](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32022R2554&ref=sorena.io) - Supports the tester requirements, internal-tester approval conditions, pooled testing rule, ICT third-party participation, and full responsibility of the financial entity.

## What evidence closes a DORA TLPT selection and testing cycle?

A selected entity should preserve both selection evidence and testing evidence. Selection evidence explains why the entity was identified, who the authority contact was, what scope was approved, and whether the test was individual, joint, or pooled. Testing evidence shows that the authority-supervised process was completed and that remediation is owned.

The active red team testing phase must last at least 12 weeks. After testing, the RTS requires red team and blue team reports, replay and purple teaming activities, a test summary report, remediation plans, and an attestation. The attestation is for mutual recognition and does not remove the financial entity's responsibility for the test impact or remediation.

- Keep the selected-entity rationale, authority notification, authority validations, and any decision on individual, pooled, or joint TLPT.
- Keep the targeted threat intelligence report, selected scenarios, red team test plan, weekly progress records, deviations, leg-ups, suspensions, and risk-management decisions.
- Keep the red team report, blue team report, replay and purple-teaming outputs, test summary report, and remediation plan with root causes, priorities, owners, expected completion, and risks of non-implementation.
- Keep the attestation showing dates, functions in scope, participating entities and providers, internal-tester use where relevant, active red team duration, involved TLPT authorities, and documents examined by the TLPT authority.

Sources for this answer:

- [Commission Delegated Regulation (EU) 2025/1190 on DORA TLPT](https://eur-lex.europa.eu/eli/reg_del/2025/1190/oj/eng?ref=sorena.io) - Supports the 12-week minimum active red-team phase, closure reports, test summary report, remediation-plan content, and attestation details.
- [Regulation (EU) 2022/2554 (DORA), Article 26](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32022R2554&ref=sorena.io) - Supports the Article 26 attestation, mutual-recognition purpose, remediation-plan submission, and continuing responsibility of the financial entity.

## Primary sources

- [Regulation (EU) 2022/2554 (DORA), Articles 26 and 27](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32022R2554&ref=sorena.io) - Primary DORA source for the TLPT obligation, 3-year cycle for identified financial entities, competent-authority identification, scope, pooled testing, tester requirements, remediation submission, and attestation.
  - Quote: "Advanced testing of ICT tools, systems and processes based on TLPT"
- [Commission Delegated Regulation (EU) 2025/1190 on DORA TLPT](https://eur-lex.europa.eu/eli/reg_del/2025/1190/oj/eng?ref=sorena.io) - Regulatory technical standards source for TLPT selection criteria, TLPT authority tasks, preparation, scope, provider due diligence, testing methodology, closure, remediation, and attestation details.
  - Quote: "criteria used for identifying financial entities required to perform threat-led penetration testing"

## Topic Guides

- [DORA Critical or Important Functions: mapping ICT dependencies and evidence](/artifacts/eu/digital-operational-resilience-act/critical-and-important-functions.md): How DORA critical or important functions affect ICT service mapping, third-party contracts, register-of-information records, incidents, testing, and evidence.
- [DORA deadlines and compliance calendar for financial entities](/artifacts/eu/digital-operational-resilience-act/deadlines-and-compliance-calendar.md): Calendar the grounded DORA dates and recurring evidence: 17 January 2025 application, incident reporting clocks, register updates, annual reporting, TLPT cadence, and CTPP oversight milestones.
- [DORA ICT Third-Party Contract Remediation Workflow](/artifacts/eu/digital-operational-resilience-act/contract-remediation-workflow.md): A DORA workflow for remediating ICT third-party contracts covering critical or important functions, subcontracting, audit rights, exits, register updates, and evidence.
- [DORA ICT Third-Party Contracts FAQ](/artifacts/eu/digital-operational-resilience-act/faq/ict-third-party-contracts.md): What DORA requires in ICT third-party contracts, including critical or important functions, audit and access rights, termination, exit, subcontracting, register updates, and evidence.
- [DORA ICT third-party risk and contract clauses guide](/artifacts/eu/digital-operational-resilience-act/third-party-risk-and-contract-clauses.md): Source-grounded DORA guide for financial entities in scope, ICT third-party risk, contract clauses, subcontracting controls, register evidence, audit rights, exit planning, and oversight.
- [DORA incident classification forms: criteria, fields, and reporting clocks](/artifacts/eu/digital-operational-resilience-act/incident-classification-forms.md): Grounded guide to DORA ICT incident classification forms: major-incident criteria, significant cyber-threat notifications, report fields, time limits, evidence, and reclassification records.
- [DORA incident clock workflow: classification, reports, deadlines, and evidence](/artifacts/eu/digital-operational-resilience-act/incident-clock-workflow.md): Grounded DORA workflow for starting the major-incident reporting clock, classifying ICT incidents, submitting initial, intermediate, and final reports, and preserving authority evidence.
- [DORA major ICT incident reporting: classification, reports, and timing](/artifacts/eu/digital-operational-resilience-act/major-incident-reporting.md): Source-grounded DORA guide to major ICT-related incident classification, initial notifications, intermediate and final reports, competent authority routing, and significant cyber threat notifications.
- [DORA major ICT incident thresholds: what triggers reporting?](/artifacts/eu/digital-operational-resilience-act/faq/major-incident-thresholds.md): FAQ on DORA major ICT-related incident classification thresholds, recurring incidents, reporting triggers, and evidence inputs grounded in EU DORA RTS and ITS texts.
- [DORA Register of Information FAQ: ICT Third-Party Arrangements](/artifacts/eu/digital-operational-resilience-act/faq/register-of-information.md): FAQ on the DORA register of information: who maintains it, which ICT third-party arrangements it covers, template fields, critical functions, reporting, data quality, and evidence.
- [DORA Register of Information Import and Build Workflow](/artifacts/eu/digital-operational-resilience-act/roi-import-and-build-workflow.md): Build a DORA register of information from procurement, vendor, contract, service, function, and subcontractor data using the official register templates and validation checks.
- [DORA Register of Information Template: ICT Provider Fields and Evidence](/artifacts/eu/digital-operational-resilience-act/dora-register-of-information-template.md): A grounded DORA register of information template for ICT third-party contracts, provider hierarchy, critical functions, dates, statuses, reporting, and evidence.
- [DORA vs EBA outsourcing guidelines: ICT third-party risk comparison](/artifacts/eu/digital-operational-resilience-act/dora-vs-eba-outsourcing-guidelines.md): Compare binding DORA ICT third-party risk duties with the EBA/ESA outsourcing baseline for registers, critical functions, contracts, subcontracting, exit, incident reporting, and evidence.
- [DORA vs ISO 22301: ICT resilience and business continuity compared](/artifacts/eu/digital-operational-resilience-act/dora-vs-iso-22301.md): Compare DORA's binding ICT operational resilience duties for financial entities with ISO 22301's business continuity management system requirements.
- [DORA vs ISO/IEC 27001: legal ICT resilience obligations and ISMS controls](/artifacts/eu/digital-operational-resilience-act/dora-vs-iso-27001.md): Compare EU DORA and ISO/IEC 27001 across scope, governance, incident reporting, testing, ICT third-party risk, certification, evidence, overlap, and gaps.
- [DORA vs NIS2: financial-sector obligations, overlap, and evidence](/artifacts/eu/digital-operational-resilience-act/dora-vs-nis2.md): Compare DORA and NIS2 for financial entities, ICT providers, incident reporting, management accountability, third-party risk, supervisory routes, and reusable evidence.
- [DORA vs PSD2 incident reporting: major ICT and payment incidents](/artifacts/eu/digital-operational-resilience-act/dora-vs-psd2-incident-reporting.md): Compare DORA major ICT-related incident reporting with PSD2 major operational or security payment incident reporting, including scope, triggers, report stages, recipients, and evidence.
- [EU DORA Applicability Test for Financial Entities and ICT Providers](/artifacts/eu/digital-operational-resilience-act/applicability-test.md): A source-grounded DORA applicability test for financial-entity scope, ICT third-party services, critical or important functions, exclusions, proportionality, and evidence.
- [EU DORA Compliance Checklist for Financial Entities](/artifacts/eu/digital-operational-resilience-act/checklist.md): A source-grounded DORA checklist covering ICT risk governance, major incident reporting, resilience testing, TLPT, ICT third-party contracts, register-of-information records, and audit evidence.
- [EU DORA Compliance Obligations and Evidence Guide](/artifacts/eu/digital-operational-resilience-act/compliance.md): A source-grounded DORA compliance guide covering ICT risk management, incident reporting, resilience testing, TLPT, ICT third-party risk, registers, governance, oversight, and evidence.
- [EU DORA FAQ: scope, incidents, ICT contracts, testing, and evidence](/artifacts/eu/digital-operational-resilience-act/faq.md): Concise DORA FAQ covering who is in scope, proportionality, ICT third-party contracts, register-of-information records, major ICT incident thresholds and reporting, TLPT, testing, enforcement, and evidence.
- [EU DORA ICT risk management control baseline](/artifacts/eu/digital-operational-resilience-act/ict-risk-management-control-baseline.md): A source-grounded DORA control baseline for ICT risk governance, asset and dependency mapping, protection, detection, response, recovery, testing, third-party risk, and evidence.
- [EU DORA ICT subcontracting chain controls for critical functions](/artifacts/eu/digital-operational-resilience-act/subcontracting-chain-controls.md): DORA guide to ICT subcontracting chains for critical or important functions: prior assessment, contract conditions, register fields, monitoring, exit rights, and evidence.
- [EU DORA penalties and fines: enforcement powers and limits](/artifacts/eu/digital-operational-resilience-act/penalties-and-fines.md): Grounded guide to DORA enforcement: competent-authority powers, administrative penalties, remedial measures, publication rules, and Lead Overseer penalty payments for critical ICT third-party providers.
- [EU DORA Register of Information Data Model: templates, fields, and evidence](/artifacts/eu/digital-operational-resilience-act/register-of-information-data-model.md): Field-level guide to the EU DORA register of information data model: templates B_01 to B_07, provider identifiers, contract links, subcontracting chains, critical-function assessments, dates, and export evidence.
- [EU DORA Requirements Overview: ICT risk, incidents, testing, and third-party risk](/artifacts/eu/digital-operational-resilience-act/requirements.md): A grounded overview of the main EU DORA requirements for financial entities: governance, ICT risk management, incident reporting, resilience testing, TLPT, ICT third-party risk, register of information, oversight, proportionality, and evidence.
- [EU DORA Scope and Covered Entities: financial entities and ICT providers](/artifacts/eu/digital-operational-resilience-act/scope-and-covered-entities.md): Classify whether DORA applies to a financial entity, ICT third-party provider, group arrangement, branch, or critical ICT service dependency.
- [EU DORA Scope and Proportionality Workflow](/artifacts/eu/digital-operational-resilience-act/scope-and-proportionality-workflow.md): Classify DORA covered entities, simplified-framework status, critical or important functions, ICT dependencies, evidence records, and governance approvals.
- [EU DORA testing and TLPT readiness guide](/artifacts/eu/digital-operational-resilience-act/testing-and-tlpt-readiness.md): A grounded DORA guide for resilience testing, TLPT eligibility, authority interaction, test evidence, remediation plans, and avoiding unsupported testing cadence.
- [EU DORA TLPT eligibility workflow for financial entities](/artifacts/eu/digital-operational-resilience-act/tlpt-eligibility-workflow.md): Check how DORA TLPT authorities identify financial entities for threat-led penetration testing and what evidence supports scope, readiness, providers, and governance.
- [EU DORA TLPT Runbook: scope, providers, reports, and remediation](/artifacts/eu/digital-operational-resilience-act/tlpt-runbook.md): Build a DORA threat-led penetration testing runbook around authority coordination, scope validation, provider controls, active testing, closure reports, remediation, and attestation.
- [How does proportionality work under EU DORA?](/artifacts/eu/digital-operational-resilience-act/faq/proportionality.md): A grounded FAQ on DORA proportionality: what can be scaled, who may use the simplified ICT risk framework, what evidence supports the decision, and which duties cannot be waived.
- [How to build a DORA register of information](/artifacts/eu/digital-operational-resilience-act/register-of-information-how-to-build.md): Build a DORA register of information from contracts, ICT services, providers, functions, subcontractors, risk assessments, audit evidence, exit plans, and export checks.

*Recommended next step*

*Placement: before sources*

## Prepare the authority-facing TLPT selection record

Use the cited sources listed here to verify obligations and the supporting evidence requirements.

- [Open Research Copilot for EU DORA](/solutions/research-copilot.md): Verify the following areas from the cited sources:  TLPT selection, authority validation, provider checks, scope evidence, and remediation records using the cited sources on this page.
- [Talk through TLPT readiness](/contact.md): Review your DORA TLPT selection facts, authority evidence, and testing-cycle records with Sorena.


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