Dora

DORA / PSD2 / MiFID II Assessment

Assess Digital Operational Resilience Act (DORA), PSD2, and MiFID II compliance for "$ARGUMENTS". Evaluate ICT risk management, incident reporting, operational resilience testing, and third-party risk management.

Prerequisites

Read .metapowers/compliance/$ARGUMENTS/00-scope.md. If this file does not exist, tell the user:

Phase 0 (Scope) has not been completed for "$ARGUMENTS". Run /compliance:regulatory-landscape $ARGUMENTS first, or use --skip-checks to bypass.

If --skip-checks is present in $ARGUMENTS, skip this check.

Process

1. Read context files:

   • Read plugins/compliance/shared/grc-lifecycle-guide.md for GRC methodology reference
   • Read plugins/compliance/shared/assessment-template.md for output structure
   • Read .metapowers/compliance/$ARGUMENTS/00-scope.md for scope and control framework context

2. DORA (Digital Operational Resilience Act) assessment:

   • ICT Risk Management Framework:
     • Assess ICT risk management strategy and policies
     • Evaluate ICT asset inventory and dependency mapping
     • Review ICT risk identification, protection, detection, response, and recovery capabilities
     • Assess business impact analysis for ICT disruptions
     • Evaluate ICT change management and patch management
   • Incident Reporting:
     • Assess major ICT incident classification methodology
     • Evaluate reporting timelines: initial notification (within 4 hours of classification), intermediate report (within 72 hours), final report (within 1 month)
     • Review incident root cause analysis and post-incident review processes
     • Assess significant cyber threat voluntary reporting
   • Digital Operational Resilience Testing:
     • Assess basic testing program (vulnerability assessments, network security, gap analysis, software security, source code reviews, performance testing)
     • Evaluate Threat-Led Penetration Testing (TLPT) requirements for significant entities
     • Review testing frequency and scope adequacy
     • Assess use of qualified external testers
   • Third-Party Risk Management:
     • Assess register of all ICT third-party service providers
     • Evaluate contractual arrangements with ICT providers (SLA, audit rights, exit strategies)
     • Review concentration risk assessment for critical ICT providers
     • Assess oversight of critical third-party providers by European Supervisory Authorities
   • Information Sharing:
     • Assess participation in cyber threat information sharing arrangements
     • Evaluate information sharing agreements and mechanisms

3. PSD2 (Payment Services Directive 2) assessment:

   • Assess Strong Customer Authentication (SCA) implementation
   • Evaluate SCA exemptions application (low-value, trusted beneficiary, TRA)
   • Review secure communication standards for payment initiation and account information
   • Assess incident reporting to competent authority (major operational/security incidents)
   • Evaluate fraud monitoring and reporting mechanisms
   • Review API and third-party provider (TPP) access security

4. MiFID II assessment:

   • Assess algorithmic trading controls and circuit breakers
   • Evaluate business continuity arrangements for trading systems
   • Review record keeping requirements (communications, transactions, orders)
   • Assess IT governance and operational risk management
   • Evaluate outsourcing arrangements for critical/important functions
   • Review disaster recovery and system resilience

5. ICT risk management maturity:

   • Score overall ICT risk management maturity (initial, developing, defined, managed, optimized)
   • Identify areas where maturity falls below regulatory expectations
   • Compare maturity across DORA, PSD2, and MiFID II requirements
   • Prioritize maturity improvement areas by regulatory impact

6. Write the artifact to .metapowers/compliance/$ARGUMENTS/01-assess/dora.md following the assessment template structure with:

   • DORA ICT Risk Management — framework maturity and gap assessment
   • DORA Incident Reporting — classification methodology and timeline readiness
   • DORA Resilience Testing — basic testing and TLPT readiness
   • DORA Third-Party Risk — provider register, contract assessment, concentration risk
   • PSD2 Assessment — SCA compliance, secure communication, incident reporting
   • MiFID II Assessment — algorithmic controls, BCP, record keeping
   • ICT Maturity Score — overall and per-domain maturity levels
   • Evidence Inventory — existing evidence and evidence gaps
   • Remediation Priorities — ranked list of gaps to address

Output

The DORA/PSD2/MiFID II assessment written to .metapowers/compliance/$ARGUMENTS/01-assess/dora.md. Present a summary to the user highlighting:

• Overall ICT risk management maturity level
• DORA readiness score across all five pillars
• PSD2 SCA compliance status
• Top 3 gaps requiring remediation