Operational Resilience testing

Operational resilience testing is a cornerstone of the Digital Operational Resilience Act (DORA), designed to ensure financial institutions and ICT service providers can withstand, respond to, and recover from disruptions. 

This requirement, outlined in Articles 12–14, focuses on rigorous testing to validate preparedness against operational risks.

Operational resilience testing is one of the five core requirements of DORA, alongside: 

• ICT Risk Management
• Incident Reporting
• Third-Party Risk Management
• Information Sharing

Together, these pillars form the foundation of DORA compliance. This guide provides an in-depth exploration of operational resilience testing, its practical implementation, and strategies for maintaining regulatory alignment.

📚 Related: The Digital Operational Resilience Act (DORA) - Regulation (EU) 2022/2554

What is Operational Resilience Testing?

Operational resilience testing involves evaluating an organization’s ability to continue delivering critical services during ICT disruptions, such as cyberattacks, system failures, or natural disasters. It goes beyond traditional disaster recovery testing by focusing on end-to-end service continuity, including people, processes, and technologies.

Under DORA, resilience testing ensures financial institutions can identify vulnerabilities, assess response mechanisms, and improve their preparedness against a wide range of operational risks. 

📚 Related: Official DORA Journal of the EU

DORA Compliance Requirements for Operational Resilience Testing

DORA mandates that operational resilience testing be comprehensive, regular, and reflective of real-world conditions. Key requirements include:

• Annual Testing: Organizations must test critical systems and processes at least once a year.
• Involvement of Third Parties: Tests should include critical third-party providers to validate end-to-end service resilience.
• Realistic Scenarios: Testing must simulate plausible risks and disruptions to evaluate readiness accurately.
• Continuous Improvement: Test findings must inform updates to resilience plans and ICT systems to address identified gaps.

📚 Related: DORA Maturity Assessment

Core Elements of Operational Resilience Testing under DORA

1. Scope Definition and Criticality Assessment (Article 12)

The first step in operational resilience testing is defining its scope, identifying critical systems, and assessing their importance to the organization’s overall operational stability.

Proper scope definition ensures that tests focus on the most critical areas, such as payment processing systems or customer data storage. By assessing the criticality of these components, organizations prioritize resources and create a clear testing framework that addresses the most significant risks.

Key Activities:

• Identifying Critical Systems: Enterprise architects use tools like SAP LeanIX to map dependencies across systems, processes, and third-party services. For example, mapping the dependencies of a payment processing platform can reveal potential vulnerabilities in supporting services.
• Engaging Stakeholders: Risk managers collaborate with IT teams, compliance officers, and business leaders to prioritize systems for testing based on their criticality and regulatory significance.
• Documenting Scope: Organizations prepare a detailed inventory of in-scope systems, including ICT infrastructure, workflows, and third-party dependencies.

The outcome is a detailed inventory of critical systems and dependencies, enabling targeted resilience strategies and compliance with DORA’s standards.

2. Testing Framework Selection (Article 13)

DORA encourages organizations to adopt structured testing frameworks that simulate real-world scenarios, such as Threat-Led Penetration Testing (TLPT) or resilience simulations based on frameworks like TIBER-EU.

Organizations must tailor testing frameworks to reflect their unique operational risks and regulatory requirements. For example, a financial institution heavily reliant on cloud services may include cloud service disruption scenarios in its tests.

By adopting a framework that aligns with their operational profile, organizations gain actionable insights into vulnerabilities and response capabilities.

Key Activities:

• Choosing the Right Framework: Organizations align their testing approach with their operational and regulatory needs. For instance, TLPT provides a realistic evaluation of defenses against targeted cyberattacks.
• Customizing Scenarios: Testing scenarios are tailored to reflect the organization’s specific risk landscape. For example, a simulated ransomware attack on customer data storage systems can validate backup and recovery mechanisms.
• Validating Testing Plans: Compliance teams review testing plans to ensure they align with DORA’s requirements and include all critical systems and processes.

The outcome is a customized testing strategy that ensures regulatory compliance and improved resilience.

3. Execution of Resilience Tests (Article 13)

Conducting operational resilience tests involves executing predefined scenarios to evaluate an organization’s response and recovery capabilities.

During execution, organizations monitor system performance, employee responses, and third-party actions in real time. For instance, a simulated ransomware attack may test the effectiveness of backup systems and incident response protocols.

Key Activities:

• Simulating Disruptions: IT teams simulate disruptions like DDoS attacks or hardware failures to evaluate system resilience.
• Testing Third-Party Dependencies: Including critical third-party providers in tests ensures their resilience aligns with organizational needs. For example, testing a cloud provider’s failover capabilities can reveal gaps in service agreements.
• Monitoring and Documenting Outcomes: Real-time monitoring tools capture system behavior during tests, providing data for analysis.

The outcome is a comprehensive understanding of the organization’s current resilience levels, highlighting gaps that need to be addressed to strengthen defenses.

4. Analyzing Test Results and Addressing Gaps (Article 14)

After tests are completed, organizations analyze results to identify weaknesses and refine their resilience strategies.

Organizations use these insights to implement improvements, such as updating recovery protocols, enhancing training programs, or upgrading ICT infrastructure.

For example, if a resilience test reveals that a vendor's recovery capabilities are insufficient, organizations may renegotiate service-level agreements (SLAs) or seek alternative providers.

Key Activities:

• Root Cause Analysis: IT and risk management teams investigate any failures during tests to identify underlying causes. For instance, a failed backup recovery test might reveal issues with data replication settings.
• Implementing Improvements: Findings from tests are used to update processes, technologies, and policies to enhance resilience.
• Reporting Outcomes: Compliance officers prepare reports summarizing test results, key findings, and remedial actions for internal stakeholders and regulators.

The outcome is a refined resilience strategy that addresses identified gaps, ensuring continuous improvement and alignment with DORA requirements. 

Operational Resilience Testing Tools and Technologies

• Enterprise Architecture Platforms (e.g., SAP LeanIX): Map dependencies and simulate the impact of disruptions across ICT environments.
• Threat Simulation Tools (e.g., TIBER-EU): Provide structured frameworks for conducting threat-led penetration testing.
• Disaster Recovery Platforms: Automate failover and recovery processes, validating RTOs and RPOs.
• Monitoring Tools (e.g., SIEM): Enable real-time tracking of system performance during resilience tests.
• Governance Dashboards: Track testing outcomes and ensure compliance with DORA’s standards. 

📚 Related: The Role of Enterprise Architecture in DORA Compliance

Most Common Challenges

1. Defining Test Scenarios: Organizations often struggle to develop realistic scenarios that reflect their unique risk profiles. 
   Solution: Use industry frameworks like TIBER-EU to standardize scenario development while customizing them to your environment.
   
   
2. Involving Third Parties: Ensuring third-party participation in resilience tests can be challenging due to contractual limitations or resource constraints. 
   Solution: Include resilience testing clauses in contracts with third-party providers and collaborate early in the testing process.
   
   
3. Resource Allocation: Resilience testing can require significant time and resources, which may be difficult for smaller organizations. 
   Solution: Focus on critical systems and use automated tools to streamline testing processes.
   
   
4. Interpreting Results: Understanding the implications of test outcomes can be complex, especially for non-technical stakeholders. 
   Solution: Use governance dashboards to present results in an accessible, actionable format. 

Best Practices

• Adopt a Risk-Based Approach: Prioritize testing for systems and processes that pose the highest risk to operational stability.
• Integrate Testing into Business Operations: Align testing schedules with operational priorities to minimize disruptions while maximizing relevance.
• Collaborate Across Teams: Involve IT, compliance, risk management, and business units to ensure comprehensive testing and follow-through.
• Leverage Advanced Tools: Use platforms like SAP LeanIX and TIBER-EU to enhance testing precision and streamline workflows.
• Document and Share Findings: Maintain detailed records of test outcomes and use them to inform decision-making and regulatory reporting. 

Operational resilience testing empowers financial institutions to maintain continuity during disruptions. Structured frameworks, advanced tools, and collaboration keep organizations prepared, compliant, and resilient against evolving risks.