EvidenceSheet

Art.26 Advanced testing of ICT tools, systems and processes based on TLPT

Only financial entities that their competent authority has identified for TLPT (under Article 26(8), third subparagraph, on impact, financial stability and ICT risk profile, applying Article 4(2)) must carry out threat-led penetration testing; Article 16(1) entities and microenterprises are excluded. Identified entities test at least every 3 years, a frequency the authority may shorten or extend for the entity's risk profile. Each test covers some or all of the critical or important functions on live production systems, including outsourced ones; the entity's scoping assessment is validated by the authority; ICT third-party providers in scope take part, or join pooled testing where their participation would harm other customers; risk management controls limit impact on data, assets and services; after testing, a summary of findings, remediation plans and documentation go to the TLPT authority, which issues an attestation. Testers meet Article 27; entities using internal testers contract external testers every third test, and significant credit institutions use only external testers.

Source: DORA (Regulation (EU) 2022/2554), Art.26. 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.

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
3
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

  • TLPT scoping assessment of critical or important functions with the authority's validation · Document repository
  • Threat intelligence and red team test reports for tests run on live production systems · Document repository
  • Tester rotation record showing an external tester at least every third test where internal testers are used · Document repository

governing documentDocuments that govern the control

  • Competent authority notice identifying the entity for TLPT, and any change to the test frequency · Policy repository / GRC workspace
  • Summary of findings, remediation plans and the TLPT attestation from the authority · 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.25 Testing of ICT tools and systems · Art.27 Requirements for testers for the carrying out of TLPT