AmCham EU publishes position on Digital Operational Resilience Act (DORA)

The use of technology in financial services is not new. In fact, the financial services industry has always been at the forefront of testing and adopting new technologies to transform the financial services industry, increase competition and efficiency, as well as offering new solutions to its customers. What is new is the speed of innovation we are seeing in recent years covering all aspects of the financial services sector and leading to the development of new business models, services and products.

Amongst these new developments is the use of information and communications technology (ICT), which finds itself at continuously greater use in the sphere of finance, requiring greater security resilience for firms. The Digital Operational Resilience Act (DORA) represents thus a crucial step towards a harmonized EU framework for digital resilience in financial operations. Due to the unique factors coming together in the financial services sector, given its fast evolution, increased diversification and international nature, additional care needs to be taken into consideration in the adoption of the new proposed regulation. Read our position here.

News
7 Mar 2021
Digital, Financial services
AmCham EU publishes position on Digital Operational Resilience Act (DORA)

The use of technology in financial services is not new. In fact, the financial services industry has always been at the forefront of testing and adopting new technologies to transform the financial services industry, increase competition and efficiency, as well as offering new solutions to its customers. What is new is the speed of innovation we are seeing in recent years covering all aspects of the financial services sector and leading to the development of new business models, services and products.

Amongst these new developments is the use of information and communications technology (ICT), which finds itself at continuously greater use in the sphere of finance, requiring greater security resilience for firms. The Digital Operational Resilience Act (DORA) represents thus a crucial step towards a harmonized EU framework for digital resilience in financial operations. Due to the unique factors coming together in the financial services sector, given its fast evolution, increased diversification and international nature, additional care needs to be taken into consideration in the adoption of the new proposed regulation. Read our position here.

As the voice of American businesses invested in Europe, AmCham EU emphasises the transatlantic dimension and the need for a coordinated international approach to ICT risk management in this paper. The recommendations contained within this paper therefore focus on building on existing international practices and call for openness to incorporating international best practices into the implementation of the EU’s digital operational resilience.

The issues addressed in this paper include general principles; cloud computing; third-country provisions; intragroup delegation; ICT risk management; legislative consistency; the designation critical third-party providers; testing; incident reporting; EU oversight of critical third-party providers; contractual arrangements; outsourcing and sub-outsourcing; cyber threat information sharing; sanctions and penalties; oversight fees; and the implementation period.

Related items

News
27 Nov 2025

Highlighting our financial services priorities in Frankfurt and Strasbourg

On Monday, 25 and Wednesday, 27 November 2025, AmCham EU travelled to Frankfurt, Germany and Strasbourg, France to support an ambitious Savings and Investment Union (SIU) that will allow the EU to gain momentum towards more integrated Single Market. In Frankfurt, members met with senior officials from the European Central Bank, Deutsche Bundesbank, as well as the International Financial Reporting Standards (IFRS) and the International Sustainability Standards Board (ISSB). Conversations focused on strengthening Europe’s place in the global financial markets and opportunities to streamline regulatory complexities. 

The delegation then continued to the European Parliament in Strasbourg, where discussions with MEPs centred on securitsiation, the upcoming market integration package, next steps for the sustainable finance framework, the role of innovative technologies and the future of the digital euro. Throughout the visit, members emphasised the need to deepen Europe's capital markets, prevent further fragmentation, support innovation-driven regulation and foster a globally attractive investment environment that strengthens Europe’s financial resilience. 

Financial services
Read more
Read more about Highlighting our financial services priorities in Frankfurt and Strasbourg
News
26 Nov 2025

Brainy in Brittany

Along with beautiful scenery and delicious cuisine, Brittany is a hub for cutting-edge innovation, thanks to strategic investments in research and technology. InterDigital established its largest research centre in Rennes in 2019, employing local engineers to develop next-generation video, wireless and artificial intelligence technologies. The company partners with the French Research Institute for Computer Science and Automation and the University of Rennes 1, fostering collaboration with researchers and students. In 2025, InterDigital was awarded ‘Produit en Bretagne’ accreditation, recognising its regional impact. Learn how InterDigital is investing in European innovation and talent through its state-of-the-art Rennes facility on Invested in Europe.

Social impact, inclusion and skills
Digital
Read more
Read more about Brainy in Brittany
News
20 Nov 2025

Digital Economy Conference 2025: in review

AmCham EU’s 2025 Digital Economy Conference took place on Thursday, 20 November with the theme ‘A transatlantic agenda for growth, innovation and simplification’. The event brought together policymakers, regulators and industry leaders to explore how Europe and the US can align efforts to promote responsible innovation, resilient infrastructure and forward-looking regulation in a rapidly evolving digital landscape. 

Malte Lohan, CEO, AmCham EU, opened the conference with remarks highlighting the importance of strong transatlantic partnership to shape digital policy in an increasingly complex global environment. 

Digital
Read more
Read more about Digital Economy Conference 2025: in review