GPRC for Operational Resilience: Delivering on DORA

On the bridge of a starship, everything is connected. Navigation depends on sensors, sensors depend on power, power depends on engineering, and the captain’s decisions depend on the clarity and integrity of the information flowing across the ship. That is the image leaders should carry when they think about the EU Digital Operational Resilience Act (DORA). DORA is not merely another checklist of controls; it is the European Union’s insistence that financial institutions, and the ICT companies that support them, run their digital enterprise like a mission-critical vessel — coordinated from a single command center where governance, performance, risk management, and compliance operate as one.

DORA became applicable in January 2025 with a simple demand that is difficult to execute: prove that your organization can withstand, respond to, and recover from material ICT disruption while maintaining continuity of critical services. Behind that demand is the EU’s recognition that cyber threats, technology failures, concentration in third-party providers, and cross-border interdependencies can destabilize not only a firm but the confidence of markets and citizens.

Fragmented, after-the-fact, paper-driven “resilience” will not suffice. What is required is GPRC — governance, performance, risk management, and compliance — fully orchestrated, not scattered, through a modern architecture. In my GRC 7.0 language, that is GRC Orchestrate: a semantic, data-driven operating model with digital twins, agentic AI, and business-integrated processes that turn regulation into real operational capability.

The EU did not draft DORA to create busywork. It did so because supervisory experience and public incidents showed a pattern: the sector had strong policies but uneven execution; critical dependencies were not mapped; incident data was inconsistent; testing was episodic and narrow; and third-party arrangements outsourced capability without transferring accountability. DORA addresses those weaknesses directly by forcing institutions to demonstrate operational resilience as a continuous competency, not a yearly audit exercise. It harmonizes expectations across the Union, it standardizes incident reporting, it raises the bar for testing, and it brings ICT third-party risk into sharp focus, including oversight of critical providers.

The most effective way to implement DORA is to treat it as an enterprise operating model problem, not as a compliance project. That is where GPRC on the bridge becomes practical: governance sets the mission and the tolerances, performance keeps critical services within range, risk anticipates turbulence and prepares the ship, and compliance ensures that action aligns with obligations and can be evidenced. When this is orchestrated through GRC 7.0, leaders do not merely “meet” DORA—they instrument it.

A digital twin is not a diagram; it is a living model that accepts telemetry and changes state as reality changes.

DORA requires a comprehensive ICT risk management framework that is integrated with business strategy and decision-making. In a legacy model, this often devolves into control inventories and static registers that are disconnected from how services actually run. The GPRC approach begins by identifying critical business services and constructing a digital twin of each service: systems, data, identities, processes, facilities, and third-party dependencies. That twin is not a diagram; it is a living model that accepts telemetry and changes state as reality changes. Governance sets objectives and risk appetite for each service; performance defines the service levels that must be maintained under stress; risk identifies failure modes and scenarios; compliance binds all of this to policy, standards, and regulatory expectations.

Agentic AI enhances this pillar by monitoring the twin for weak signals — control drift, configuration anomalies, concentration in a single cloud region, an uptick in failed jobs on a critical batch process — and escalating when thresholds are reached. The value is not in the alert; it is in the contextualized alert that explains what is happening, why it matters to the mission, and who is accountable to act. Board and executive oversight then becomes grounded in a clear, current picture of operational exposure rather than in abstract risk heatmaps.

DORA standardizes the classification and reporting of significant ICT incidents and requires both timely supervisory notification and disciplined internal handling. Where organizations frequently struggle is not intention but coordination: detection in one system, diagnosis in another, and the business impact understood much later when customers and regulators are already asking questions.

In an orchestrated GPRC model, incident management is bound into the digital twin of each critical service. Detection and triage do not occur in a vacuum; they occur in the context of the service topology, the dependencies, the data flows, and the contractual obligations. Agentic AI helps classify incidents against harmonized severity criteria, drafts the initial supervisory report from structured templates, and routes work to the accountable owners across technology, operations, compliance, communications, and legal. Post-incident reviews are not a ritual, they are a learning loop: findings update the twin, recalibrate thresholds, and trigger policy or control adjustments so the organization demonstrably improves its operational posture over time.

DORA moves the sector from occasional, narrow tests toward regular, risk-informed testing of resilience, including advanced threat-led penetration testing (TLPT) for the most critical institutions. Many firms have long performed good tests, but too often the scope is tool-centric (the firewall, the EDR, the backup job) rather than service-centric. The point of DORA’s testing pillar is not to add more random exercises; it is to validate that critical services continue within tolerances under severe but plausible stress.

The digital twin is decisive here. It allows teams to design tests that reflect actual service dependencies, to run “what-if” simulations before any live exercise, and to observe cascading effects during the event. A payment service twin, for example, can simulate the loss of a messaging gateway or a cloud region and quantify the impact on clearing timelines, liquidity buffers, and customer obligations. Findings flow automatically into remediation backlogs with owners, dates, and metrics; performance dashboards show time to control closure; compliance receives the evidence needed for internal and supervisory reporting. TLPT becomes the capstone, not the starting point: a focused validation of real-world adversary techniques against the services that matter most.

Governance sets objectives and risk appetite for each service; performance defines the service levels that must be maintained under stress; risk identifies failure modes and scenarios; compliance binds all of this to policy, standards, and regulatory expectations.

DORA’s treatment of ICT third-party risk is explicit: institutions must govern the full lifecycle of external technology relationships, maintain a complete register of providers, manage concentration risk, embed termination and substitution plans, and ensure that contracts support supervisory expectations. In practice, the weaknesses are well-known: shadow IT buys, inconsistent due diligence, incomplete contract clauses, limited telemetry from providers, and heroic but ad hoc exit plans when a provider fails or is acquired.

GRC Orchestrate addresses this by giving each material relationship its own third-party digital twin connected to the service twins it supports. Obligations, controls, SLAs, data locations, identity and access boundaries, and resilience commitments are mapped and traceable. Real-time metrics from providers — security posture, change windows, incident notifications, recovery evidence — flow into the twin so the risk picture is not a stale spreadsheet but a living model. Agentic AI monitors for dependency accumulation in a single region or provider and flags concentration risk trends. Most critically, offboarding is engineered in: de-provisioning, data return or destruction, certificate and key rotation, log retention, knowledge transfer, and substitution plans are defined at onboarding and rehearsed through tabletop exercises so the exit, when needed, is predictable, auditable, and safe.

DORA encourages trusted information-sharing arrangements so that firms can exchange cyber threat intelligence and good practices. The intent is not to create another feed to ignore, but to accelerate the sector’s collective learning loop. In a GPRC architecture, shared intelligence is normalized and fused with internal telemetry, mapped to the relevant service and third-party twins, and translated into concrete defensive actions: new detection content, updated playbooks, heightened watch on specific interfaces, and targeted awareness for teams operating the affected services. Agentic AI assists by summarizing long reports into role-specific briefs and by recommending whether to raise alerting thresholds or initiate proactive hunts.

DORA expects boards and senior management to own operational resilience. That is far easier to state than to exercise if the organization cannot present a coherent view of its operational risk and performance posture. The bridge solves that. Performance owners see whether services are within policy thresholds today and where they are drifting. Risk functions see scenario coverage and residual risk in business terms. Compliance sees obligations mapped to policies, controls, and evidence, ready for supervisory engagement. Audit sees traceability from requirement to control to test to result.

This is the exact opposite of a document-centric compliance program. It is assurance by design. When a supervisor asks for evidence, the organization does not assemble a binder; it shows the system — how it works, where it is strong, where it is improving, and who is responsible.

Leaders often ask how to sequence the work. The following pattern has proven pragmatic and defensible:

1. Discover and model critical business services and material ICT providers. Build initial digital twins, even if imperfect. Perfection is not the goal; visibility is.
2. Map obligations to operations: Link DORA requirements to policies, standards, controls, tests, incident workflows, and third-party clauses. Make every obligation traceable to action.
3. Instrument telemetry: Connect systems, providers, and processes to the twins so the risk picture updates as reality changes. Define thresholds that reflect risk appetite and service objectives.
4. Design a test strategy: Move from component tests to service-centric exercises; plan TLPT as a targeted validation rather than a standalone spectacle. Close the loop with tracked remediation.
5. Engineer lifecycle discipline for third parties: Standardize intake, contract clauses, resilience evidence, continuous assurance, and rehearsed exit plans. Treat offboarding as a first-class capability.
6. Build the bridge: Present GPRC dashboards that are role-specific and evidence-rich. Train the crew. Practice decision-making from the bridge in exercises, not only in crises.

Each step reduces operational ambiguity and increases supervisory confidence. More importantly, each step strengthens the organization’s ability to serve customers reliably when the galaxy turns hostile.

DORA is not about avoiding fines. It is about the Prime Directive of modern financial services: preserving trust by ensuring continuity. The regulation codifies what good operators already know—resilience is a system property that only emerges when governance, performance, risk, and compliance are orchestrated in real time. With GRC 7.0 – GRC Orchestrate, organizations gain the architecture to make that orchestration tangible: digital twins that show how services truly work, agentic AI that keeps watch and guides action, and an enterprise bridge where leaders see, decide, and direct with clarity.

Because in the end, resilience is not a certificate on the wall. It is how the ship flies.