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AI and DORA: Enhancing Digital Resilience in Financial Services

FTI Consulting Experts Discuss How the Challenges Surrounding Dora Compliance Can Also Become Opportunities.

Europe’s financial sector woke up to a new regulatory reality with the enactment of the Digital Operational Resilience Act (“DORA”).¹ In effect as of January 2025, the law placed banks, insurers and their critical technology vendors under increased scrutiny. FTI Consulting experts have seen first-hand how the challenges surrounding DORA compliance can also become opportunities. One key example is the use of artificial intelligence to pave a smoother, smarter journey for DORA compliance and ICT risk management.

New Requirements and The Rise of AI

DORA compliance isn’t a box-ticking exercise. It’s a comprehensive push for operational resilience, covering everything from ICT risk management to incident reporting and third-party oversight. Complying means reviewing countless vendor contracts, mapping where regulations impact operations and shoring up cybersecurity defences. Traditionally, such tasks required scores of analysts poring over documents and systems. It was a slow, error-prone process. Conversely, today, AI can be leveraged as a powerful ally.

Examples Include:

AI-Driven Contract Review: Expert-led modern AI tools powered by large language models can scan thousands of contracts to help pinpoint DORA-relevant clauses and gaps. Instead of manually hunting for provisions on incident reporting or data security, compliance teams can rapidly uncover highlights of what’s missing or non-compliant within their contracts. This saves time and supports quality control so that nothing slips through the cracks. In the past, ensuring every ICT vendor agreement met DORA’s standards would be daunting, but generative AI may help to shoulder the load, flagging risks and suggesting fixes.

Identifying Regulatory Scope: AI is also helping map the regulatory scope within complex operations. By analysing internal data and processes for subtle patterns, AI can reveal potential risk areas that might otherwise go unnoticed. Whether it’s identifying a critical business function reliant on a third-party service or spotting inconsistencies in how different departments manage ICT risks, AI offers a smart approach to digital risk management. The result is a clear view of where DORA’s requirements apply across the enterprise and confidence that no important obligations are overlooked.

Cybersecurity Resilience
At its core, DORA is designed to improve resilience against ICT disruptions. Here, intelligent analytics can improve the speed and precision of anomaly detection by up to 30%, helping organizations spot cyber threats early and respond faster.² AI can also trigger automated incident response protocols, supporting breach containment and timely reporting to regulators. This helps financial entities meet DORA’s strict incident reporting requirements while minimizing damage from attacks.

Crucially, technology alone isn’t a silver bullet. Effective resilience comes from blending AI tools with seasoned expertise. Evolving regulations like DORA demand an integrated approach, bridging compliance and cybersecurity. FTI Consulting’s experience with these financial regulations and cyber defence strategies has enabled clients to better prepare for and respond to incidents in this complex, constantly changing environment. In practice, that means viewing DORA not just as an IT checklist, but as a board-level priority for building a robust cyber risk culture.

Conclusion

For financial services firms and their ICT partners, the message is clear: AI and expert guidance together can turn DORA from a headache into a strategic advantage. FTI Consulting continues to help clients navigate DORA’s complexity with solutions that make compliance more efficient and operations more resilient. The road to compliance doesn’t need to be daunting. With the right tools and insights, it can be a catalyst for strengthening a business. Legal and compliance teams can now consider whether their organizations are ready to not only comply with DORA, but thrive under it.

Footnotes:

1: “Digital Operational Resilience Act (DORA)”, European Insurance and Occupational Pensions Authority (17 January 2025).

2: Haosen Xu, Kaiyi Niu, Tianyi Lu, Siyang Li, “Leveraging artificial intelligence for enhanced risk management in financial services: Current applications and future prospects,” Engineering Science & Technology Journal (August 2024), .