DORA — DIGITAL OPERATIONAL RESILIENCE ACT

Where we fit in DORA

IdentityStream is built for ICT risk management, identity and access governance, ICT-incident reporting and ICT third-party risk — including the Register of Information. We are not a resilience-testing tool and not a threat-intelligence sharing platform — this page shows exactly what we cover, what we don't, and the evidence you get out.

DORA has applied since 17 January 2025. Supervisory focus is now on documentation, evidence and the Register of Information.

Where IdentityStream delivers value for DORA

Four areas where our modules give you concrete artefacts, workflow and audit trail — mapped to the DORA articles your auditor will actually ask about.

ICT risk management & access governance

DORA Art. 5–14 · IAM / IGA

Move from spreadsheets and ad-hoc approvals to a controlled lifecycle for every identity — employees, contractors and machine accounts — with documented ownership, least privilege and periodic review.

  • Automated Joiner / Mover / Leaver across HR, AD / Entra ID and business systems, with role models combining RBAC, ABAC, PBAC and DAC and role mining via IdentityMap.
  • A new risk register that links every risk directly to processes, systems, suppliers, contracts, incidents and follow-up actions — a living risk picture, not a once-a-year spreadsheet.
  • Function and process register with Business Impact Analysis (BIA), criticality, RTO and RPO per process, and DORA-licensed activity mapping.
  • Periodic access reviews, exception reports (intended vs actual access) and four-eyes approvals with full audit trail.
  • PoPS — a structured decision process for risk-assessing changes to products, organisation, processes and systems before they go live.

ICT-related incident handling & reporting

DORA Art. 17 & 19 · IdS RegTech

A structured workflow from first signal to final report — with the DORA classification criteria built in, so you can tell quickly whether an incident is reportable to Finanstilsynet.

  • Structured ICT-incident register with severity, root cause, owner and full timeline — also handles fraud, AML alerts and customer complaints in the same workflow.
  • Built-in DORA classification (clients affected, downtime, data losses, geographical spread, criticality, reputational and economic impact) with automatic alert when reporting thresholds are crossed.
  • Guided reporting flow: 4-hour initial notification → 72-hour status report → final report within one month, with reminders and management escalation.
  • Direct submission to Finanstilsynet via Altinn integration, so the same case both runs the response and produces the regulatory report.
  • Every incident links to corrective actions in the Measures Database and to the systems, suppliers and processes affected — no separate Excel for follow-up.

ICT third-party risk & Register of Information

DORA Art. 28–30 · ICT Service Agreements & ContractManager

A live register of your ICT third-party arrangements — not a once-a-year spreadsheet. Built to produce the Register of Information (RoI) in the format Finanstilsynet expects.

  • Live Register of Information with business functions, ICT services, providers, subcontractors and data flows — full traceability from data element to responsible function.
  • Full, partial and annual RoI reports generated in xBRL-CSV — packaged as a ZIP file ready for Finanstilsynet, with direct submission of new ICT agreements via the KRT-1121 form in Altinn.
  • AI-assisted, continuous supplier monitoring of public sources — Brønnøysund announcements, eInnsyn orders, news and Transparency Act information — that reopens vendor assessments when the risk picture changes.
  • Contract register with renewal reminders, exit plans, SLA / KPI follow-up and reports on suppliers without contract, audit or up-to-date assessment.
  • Concentration-risk visualisation across subcontractors so you can see — not just describe — your critical dependencies.

Internal control, governance & audit-ready evidence

Cross-cutting · IdS Risk POPS + Measures Database

Daily operational work — approvals, reviews, incidents, supplier follow-up — generates the trail an auditor or Finanstilsynet supervisor will ask for. No separate evidence project.

  • Control database where controls are linked to risks, incidents and regulatory requirements — execution and results documented, with dashboards and alerts to management.
  • Measures Database that ties findings from audits, ICT incidents and supervisory letters to a named owner, deadline and status — with pattern analysis to spot recurring problem areas.
  • Annual ICT risk report for the board, consolidated automatically from risk assessments, incidents, actions, suppliers and controls — one source of truth, not a manual exercise.
  • Local and global dashboards across services and tenants, with data available via API and export to Power BI for the analytics platform you already use.
  • Full audit trail with attachments and history on every change, plus export to PDF, PNG and PowerPoint for board reporting and supervisory dialogue.

Concrete capabilities you can demo

Production-grade features already running at Norwegian financial institutions — and the next wave we're rolling out right now.

Joiner / Mover / Leaver

End-to-end lifecycle from HR event to access change, with timely revocation when people leave.

Periodic access reviews

Campaigns with reviewers, reminders, sign-off and exportable evidence.

Exception & deviation reports

Intended access vs actual access — find the gaps before the auditor does.

External user governance

Contractors and third-party staff with sponsors, expiry dates and re-attestation.

Four-eyes & SoD controls

Dual approval and segregation-of-duties checks on sensitive role assignments.

Incident classification (DORA)

Built-in criteria, automatic alert and reporting flow to Finanstilsynet.

Register of Information

RoI with subcontractors, business functions and xBRL-CSV export for KRT-1121.

Supplier & contract follow-up

Renewals, exit plans, SLA / KPI, periodic audits and findings tracked per supplier.

Management dashboards

Status across access, incidents, suppliers and findings — local and alliance-wide, with API and Power BI export.

Function & process register with BIA

Functions, processes, RTO / RPO, criticality and DORA-licensed activities in one navigable register.

Control database

Define, plan, document and follow up controls linked to risks, incidents and regulatory requirements.

Policy & routine register

Searchable register of policies and routines with process diagrams, periodic review and AI-assisted lookup.

AI-FIRST GRC

DORA evidence at your fingertips — inside Microsoft Teams

We don't build yet another isolated AI. We make your GRC data available to the tools your bank already uses — Microsoft Copilot, Teams and Power BI — grounded in Norwegian financial regulation.

Copilot & Teams integration

A dedicated Graph Connector exposes IdentityStream data to Microsoft 365. Ask 'show me open DORA incidents' or 'latest risk assessment for the mortgage process' in Teams and get an interactive Adaptive Card back — for advisors, compliance, IT security and the executive team.

AI wizard for complex GRC forms

Step-by-step guidance through PoPS, DPIA, vendor assessments and other long forms. Suggestions are sourced from attachments, related cases and the GRC taxonomy — each with a confidence score and citation. Caseworkers accept, edit or reject; the AI never overrides.

AI-driven supplier monitoring

Continuous scanning of Brønnøysund announcements, eInnsyn supervisory orders and news for signals that affect a supplier's solidity or reputation. When something changes, the system proposes that the vendor assessment or contract be reopened.

AI suggestions for risks, controls and actions

When a new case is registered, the AI proposes links to existing risks, controls, actions and similar past cases — or proposes creating new ones if gaps are detected. Builds a more consistent and complete GRC dataset over time.

Automatic identification of review domains

The AI suggests which expert roles should be involved in each case — information security, privacy, legal, operational risk, IT architecture, third-party risk — so the right people are pulled in from the start.

AI fields in the 0-code form builder

Add AI fields to your own forms — auto-summary, suggested values, severity or risk-level scoring — without writing a single line of code. Your bank's bespoke compliance workflows get the same intelligence as our standard modules.

All AI suggestions are decision support, not auto-decisions. Every change keeps a full audit trail.

FOR ALLIANCES & GROUPS

GRC Standardbank — one framework, many institutions

For savings-bank alliances and groups: a centrally maintained GRC framework — system catalogue, supplier register, RoI, GDPR processing protocol, incident database, measures database and PoPS — distributed to each member bank, with full freedom to add local elements. Economies of scale on regulation, without losing local ownership.

  • Common structure, categories and minimum data — so management can compare across the group.
  • Centrally maintained PoPS decisions, distributed to each bank — change risk handled once, applied everywhere.
  • Local freedom: every institution adds its own systems, suppliers, processes and incidents in the same model.
  • Start independently, join a Standardbank later — the data model and modules are the same either way.

Delivered through our partners

Two DORA areas we cover through skilled, specialised partners — not in-house. You get one programme, with IdentityStream as the system of record and our partners doing what they do best.

Digital operational resilience testing

DORA Art. 24–27 — via partners

Threat-led penetration testing (TLPT), red-team exercises, vulnerability scanning, scenario tests and recovery drills are delivered by our specialist security and testing partners.

How IdentityStream ties it together: Plan and document the testing programme, register scope and findings from our partners, and track remediation in the Measures Database so findings don't get lost.

Information sharing & threat intelligence

DORA Art. 45 — via partners

Cyber threat intelligence sharing, ISAC participation and feed integrations are delivered by our partners on specialist platforms and sector communities.

How IdentityStream ties it together: Document your participation in sharing arrangements, register relevant intel as ICT risk input, and link it to incidents and supplier risk in IdentityStream.

Why Norwegian financial institutions choose IdentityStream for DORA

Built with Norwegian savings banks for Norwegian regulatory reality — and honest about what we are.

  • Around 80% of Norwegian savings banks already run on IdentityStream — built directly on DORA, GDPR and Finanstilsynet's expectations, not translated from US/EU generics.
  • Customer-driven innovation: modules are built together with Norwegian banks, so functionality maps to actual supervisory dialogue — not a global roadmap from a foreign HQ.
  • Audit-ready evidence is a by-product of daily work, not a separate project — RoI ready for Finanstilsynet in the expected format.
  • One platform for IAM, third-party risk, contracts, incidents, controls and findings — fewer integrations, lower total cost.
  • 0-code form builder lets your team add new compliance workflows, with AI fields, without involving developers.
  • Honest scope and deployment flexibility: SaaS in Azure or on-prem, and we're upfront about what we don't do so you can pick the right partners for testing and threat-intel.

Want to see how IdentityStream supports your DORA work?

Send us a note and we'll walk you through which parts of DORA our solutions cover — and we'll be upfront about the areas you'll need other tools for.

Address

IdentityStream AS

Laberget 22

4020 Stavanger

Phone number
(+47) 98 23 24 55
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Also subject to NIS2 / Digitalsikkerhetsloven?

Most of the DORA work — ICT risk, incident reporting, supplier register, controls, audit trail — carries straight over. We've mapped how IdentityStream supports the Norwegian Digital Security Act on a dedicated page.

See our NIS2 page