EvidenceSheet
DORA (Regulation (EU) 2022/2554) · DORA Chapter II: ICT Risk Management

Art.16 Simplified ICT risk management framework

Articles 5 to 15 are disapplied for: investment firms that are small and non-interconnected; payment institutions and electronic money institutions exempted under their directives; institutions exempted under Directive 2013/36/EU where the Member State has not used the Article 2(4) option; and small occupational retirement institutions (IORPs). These entities instead keep a sound, documented ICT risk management framework, monitor ICT systems continuously, use resilient and updated systems that protect data, detect anomalies and handle incidents quickly, identify key ICT third-party dependencies, keep business continuity plans with at least backup and restoration measures, test those plans and controls regularly, and apply lessons and training according to their risk profile. The framework is reviewed periodically and after major incidents, with a review report available on request (Art. 16(2)). The detailed requirements are in Title III (Articles 28 to 41) of Commission Delegated Regulation (EU) 2024/1774. These entities are also excluded from TLPT (Art. 26(1)) and from the ICT third-party risk strategy duty (Art. 28(2)).

Source: DORA (Regulation (EU) 2022/2554), Art.16. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open DORA (Regulation (EU) 2022/2554) in the compliance library.

Scope: Applies only to the entities named in Article 16(1), and for them Articles 5 to 15 do not apply: use this row or Articles 5 to 15, not both.

Applies to the financial entities listed in Article 2. Many duties are lighter or absent for microenterprises and for the entities in Article 16(1); each statement says where. Article 19 carries the reporting clocks of Delegated Regulation (EU) 2025/301, Article 5.

5
artefacts
0
held by a system
2
at each review
hard
to go live
Document repository
where the evidence lives
teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

none for this control

periodic reviewEvidence produced at each review

  • Eligibility assessment showing which Article 16(1) category the entity falls in, with the supporting licence or exemption · Document repository
  • Gap assessment against Title III of Delegated Regulation (EU)/1774 · Document repository

governing documentDocuments that govern the control

  • Simplified ICT risk management framework document with periodic and post-incident review records · Document repository
  • Business continuity plan with backup and restoration measures, and regular test results · Policy repository / GRC workspace
  • List of key ICT third-party dependencies · Vendor register / contract repository

First move

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

Common gaps auditors find

Do this for your whole sheet

Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.

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Art.14 Communication · Art.17 ICT-related incident management process