Skip to content

Testing and third-party risk

DORA places strong emphasis on resilience testing and third-party risk control. Modulos covers these duties across OFF-16 governance and MFF-16 execution.

Testing requirements

RequirementTopicRegulation reference
ORF-318Resilience testing and TLPT governanceArt. 24, 25, 26, 26(11), 27
MRF-287AI system resilience testing programme executionArt. 24, 25
MRF-288AI system TLPT participation and tester-assurance executionArt. 26, 26(11), 27

ICT third-party risk requirements

RequirementTopicRegulation reference
ORF-319ICT third-party risk and contractual governanceArt. 28(1)-(10), 29, 30(1)-(5)
MRF-289AI system ICT third-party due diligence and concentration-risk executionArt. 28(4), 28(5), 29, 30(5)
MRF-290AI system ICT third-party contractual safeguards and exit executionArt. 28(6)-(8), 30(1)-(5)
MRF-291AI system ICT third-party register evidence workflowArt. 28(3), 28(9)

Operational evidence baseline

  • annual and scenario-based testing plan with outcomes
  • TLPT scope decisions, tester assurance, and remediation records
  • third-party due diligence and concentration-risk analyses
  • contract baseline checks and exit/transition test evidence
  • register data completeness and submission readiness evidence

Critical ICT third-party oversight framework (Art. 31-44)

DORA Articles 31 to 44 establish an EU-level oversight framework for critical ICT third-party service providers. Most direct obligations in this section apply to oversight authorities and designated critical providers, not to every financial entity as standalone requirement objects.

In Modulos, customer-facing execution is covered through ORF-319 and MRF-289 to MRF-291:

  • maintain complete, defensible ICT third-party registers and reporting readiness
  • evidence due diligence, concentration-risk assessment, and contract baseline compliance
  • retain traceable records that support competent-authority and lead-overseer information requests

Disclaimer

This page is for general informational purposes and does not constitute legal advice.