Art.27 Requirements for testers for the carrying out of TLPT
Entities required to perform TLPT use only testers that are highly suitable and reputable, have the technical and organisational capability and specific expertise in threat intelligence, penetration and red team testing, hold certification from a Member State accreditation body or subscribe to a formal code of conduct or ethics framework, give independent assurance or an audit report on how they manage TLPT risks (including protection of confidential information and redress), and hold full professional indemnity insurance that also covers misconduct and negligence. These conditions apply to every tester, internal or external. Internal testers may be used only where the competent authority or the designated TLPT authority has approved it, the authority has verified sufficient dedicated resources and no conflicts of interest, and the threat intelligence provider is external (Art. 27(2)). Contracts with external testers must require sound management of TLPT results and data so they create no risk to the entity (Art. 27(3)).
Source: DORA (Regulation (EU) 2022/2554), Art.27. 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.
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
- Tester due-diligence file per TLPT: reputation checks, certifications or code-of-conduct adherence, and expertise evidence · Document repository
- Independent assurance or audit report from the tester on its TLPT risk management · Policy repository / GRC workspace
- Professional indemnity insurance certificate covering misconduct and negligence · Document repository
- Authority approval for internal testers, with the contract for the external threat intelligence provider · Vendor register / contract repository
- External tester contract clauses governing handling and destruction of TLPT results · Vendor register / contract repository
governing documentDocuments that govern the control
none for this control
First move
Common gaps auditors find
- Internal testers used without authority approval
- Insurance does not cover negligence
- Threat intelligence sourced in-house when internal testers are used
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.
Build my evidence sheetArt.26 Advanced testing of ICT tools, systems and processes based on TLPT · Art.28 ICT third-party risk: general principles