How Financial Institutions Can Meet DORA Compliance with Crypto-Agility – Source: securityboulevard.com

Today’s financial systems are highly digital and deeply interconnected. That’s great until something breaks. Whether it’s ransomware paralyzing critical services or cryptographic vulnerabilities quietly eroding trust, disruptions are no longer rare—they’re systemic.

The Modern Heist Bank Report 2025 shows just how serious it’s become: 64% of surveyed financial institutions reported cyber incidents in the past 12 months. Regulators aren’t standing by waiting for institutions to catch up. They’re demanding proof that firms have the countermeasures to withstand and recover fast from operational shocks. 

That’s what the EU’s Digital Operational Resilience Act (DORA) sets out to enforce.

What Is DORA?

The Digital Operational Resilience Act (DORA) is a European Union regulation designed to strengthen the digital operational resilience of financial institutions. The goal is to ensure they prepare for, respond to, and recover from ICT (Information and Communications Technology) risks—from cyberattacks to system outages and industry disruptions. 

Effective across the EU since January 17, 2025, DORA applies to a wide range of financial entities, including banks, insurance companies, investment firms, payment service providers, crypto‑asset (currency) service providers, and even ICT third‑party suppliers that support them. 

Why Focus on ICT Resilience ?

Modern financial operations run on ICT systems for everything from data processing and API integrations to cloud infrastructure and network security. But when these systems are mismanaged or targeted, they become serious points of failure. A single breach or outage can leak sensitive data, disrupt services, and destabilize the broader financial system. To prevent this, DORA enforces a comprehensive resilience framework to manage, mitigate, and report ICT-related incidents. 

It focuses on five key areas:

1. ICT Risk Management: Implement structured policies, ongoing risk assessments, and governance mechanisms to proactively manage ICT risks.
2. Incident Reporting: Establish clear protocols for detecting, classifying, and reporting ICT-related incidents that could impact operational continuity or customer trust.
3. Third-Party Risk Management: Conduct due diligence, establish contractual safeguards, define clear exit strategies, and continuously monitor critical third-party ICT service providers.
4. Resilience Testing: Conduct regular risk-based penetration tests, such as Threat-Led Penetration Testing (TLPT), on critical ICT systems to simulate real-world attack scenarios and identify vulnerabilities. Implement incident response plans to mitigate attacks quickly.
5. Information Sharing: Share information and threat intelligence with other EU financial institutions to drive awareness and improve collective resilience.

Together, these five pillars form the backbone of DORA’s resilience strategy, ensuring resilience against cyber threats and operational disruptions.

Cryptography Requirements Under DORA

As financial institutions go increasingly digital, cryptography has become more than a security best practice. It is crucial to ensuring the confidentiality, integrity, and availability of sensitive data. Recognizing this, DORA—along with its supporting Regulatory Technical Standards (RTS) under Delegated Regulation (EU) 2024/1774—lays out clear expectations for how financial institutions should govern cryptographic controls.

Encryption and Cryptographic Controls (RTS Article 6)

Under DORA, financial institutions must develop, document, and implement a formal encryption policy covering all data and communications as part of their ICT risk management framework. Key requirements include:

• Encrypting data at rest and in transit—as well as in use where feasible. If encrypting in use isn’t technically possible, organizations must process such data in isolated, protected environments.
• Encrypting all internal network traffic and external communications 
• Defining clear criteria for choosing cryptographic algorithms and key lengths based on industry standards, risk analysis, and data classification
• Updating or replacing cryptographic methods as threats evolve; When updates aren’t immediately possible, compensating controls must be documented and justified.

Cryptographic Key Management (RTS Article 7)

DORA expects financial institutions to maintain a documented key management policy that covers the entire lifecycle of cryptographic keys to prevent key exposure and misuse. Core expectations include:

• Secure key handling across every stage—generation, storage, backup, transmission, rotation, and revocation
• Strict access control and usage policies throughout the key lifecycle to prevent unauthorized access, theft, loss, or tampering
• Clear procedures for key replacement following suspected compromise or damage
• A comprehensive register of all digital certificates used in critical systems—along with processes to ensure timely renewals.
• Protecting keys during their active use, often through encryption or isolation in secure hardware such as hardware security modules (HSMs)
• Proper disposal of retired keys, including securely deleting keys and associated metadata to prevent recovery or misuse

Secure Authentication and Access Controls (Article 9)

Access to cryptographic assets must be carefully managed. Article 9 reinforces the need for strong identity verification and strict privilege controls. This includes:

• Least-privilege access policies that restrict both physical and logical access to only those who need it, with documented and continuously monitored access rights
• Strong authentication mechanisms to protect cryptographic keys from unauthorized use

Why Crypto-Agility Matters for DORA?

DORA’s technical standards—especially Article 6—send a strong message: cryptographic systems must evolve with the ever-changing threat landscape. In practice, this means building crypto-agility into your infrastructure. Financial institutions are expected to monitor cryptographic developments, assess emerging risks, and update algorithms or protocols—quickly, smoothly, and without disruption.

Why is this important? Because cryptographic standards don’t last forever. They age, weaken, and get replaced. Crypto-agility gives you the ability to:

• Replace outdated algorithms and vulnerable keys without operational delays
• Adapt to new regulatory mandates, such as DORA, with minimal friction
• Stay ahead of new threats, such as the potential vulnerability of current encryption methods like RSA or ECC to quantum resilient algorithms, by transitioning to NIST-approved post-quantum cryptography (PQC) algorithms before these methods are compromised.

Whether you are preparing for PQC, adapting to 47-day TLS certificate lifespans, or responding to Certificate Authority distrust incidents, crypto-agility ensures your cryptographic infrastructure remains resilient, secure, and compliant throughout.

How AppViewX Enables Crypto-Agility and Supports DORA Compliance 

Crypto-agility isn’t a checkbox—it’s a continuous capability. AppViewX AVX ONE CLM, our certificate lifecycle management solution, helps you build and maintain it through powerful visibility, automation, and policy control—fully aligned with DORA’s technical requirements.

Complete Crypto Visibility

Under DORA Article 7, a complete, up-to-date certificate registry is non-negotiable. AVX ONE CLM delivers it by: 

• Automatically discovering certificates across your infrastructure—from any public or private CA, across all endpoints and cloud services—consolidating them into a centralized inventory
• Mapping certificates to their location, owner, issuing CA, expiry date, and crypto standards for a single-pane-of-glass view
• Providing dynamic visual dashboards to understand risks, manage renewals, prevent outages and vulnerabilities, and ensure compliance

End-to-End CLM Automation

DORA demands secure, consistent handling of digital certificates across their lifecycle—and AVX ONE CLM delivers precisely that.

• Full lifecycle automation, including issuance, renewal, provisioning, revocation, and last-mile binding to endpoints
• A low-code workflow builder and a rich library of automation templates to tailor automation to your environment
• CA-agnostic operations—manage all public and private certificates from one place and implement cryptographic changes quickly, without disruption

Built-In Policy Control and Governance:

Strong cryptographic governance is central to DORA compliance. AVX ONE CLM enables:

• Automatic enforcement of defined policies for approved CAs, algorithms, validity periods, upgrades, and more. 
• Role-based access controls (RBAC) to ensure secure and authorized certificate issuance
• Detailed audit logs, automated policy checks, and periodic reports to simplify audits, ensure compliance, and strengthen overall crypto hygiene

DORA Compliance Starts with Crypto-Agility

DORA marks a major step forward in strengthening the financial sector’s defense against growing digital threats. With its strong focus on operational resilience and crypto-agility, DORA pushes financial institutions to move beyond static defenses to dynamic systems that can adapt, recover, and stay secure as risks evolve. 

Crypto-agility is central to making that shift.

With AppViewX AVX ONE CLM, crypto-agility isn’t an afterthought—it’s built in. From complete certificate visibility and lifecycle automation to centralized policy control and reporting, AppViewX helps your organization meet DORA requirements with confidence.

Explore our Crypto-Agility Solution Brief to understand how AppViewX makes it possible.

Or better yet—schedule a quick call with our team and see how easily your organization can hit DORA benchmarks.

*** This is a Security Bloggers Network syndicated blog from Blogs Archive – AppViewX authored by Krupa Patil. Read the original post at: https://www.appviewx.com/blogs/how-financial-institutions-can-meet-dora-compliance-with-crypto-agility/