What evidence do auditors commonly ask for on Art.5 Governance and organisation?

Management body minutes approving the ICT risk management framework, the digital operational resilience strategy and the ICT risk tolerance; Board-approved ICT third-party policy, ICT internal audit plan and ICT budget, each with its review date; Training records for each management body member on ICT risk; Appointment record for the ICT third-party monitoring role or the accountable senior manager (not required of microenterprises).

What is the most common gap auditors find on Art.5?

Board approves the framework once and never revisits plans, audit plans or the third-party policy

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

`Art.5` Governance and organisation

The management body defines, approves and oversees the ICT risk management framework and carries final accountability for ICT risk: it sets ICT roles and governance, approves the digital operational resilience strategy and ICT risk tolerance, approves and reviews the continuity and response plans, the ICT internal audit plans and the ICT third-party policy, allocates budget for resilience, awareness and skills, and receives reporting on third-party arrangements and major incidents. Its members keep their own ICT risk knowledge current through regular training. Entities other than microenterprises must also set up a role to monitor ICT third-party arrangements, or name a senior manager accountable for that exposure (Art. 5(3)). Applied in proportion to size, risk profile and complexity under Article 4(1). Entities listed in Article 16(1) are outside this Article and follow the simplified framework of Article 16 instead.

Source: DORA (Regulation (EU) 2022/2554), Art.5. 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.

artefacts

held by a system

at each review

hard

to go live

Policy repository / GRC workspace

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

Management body minutes approving the ICT risk management framework, the digital operational resilience strategy and the ICT risk tolerance · Policy repository / GRC workspace
Training records for each management body member on ICT risk · HR system / LMS
Appointment record for the ICT third-party monitoring role or the accountable senior manager (not required of microenterprises) · Identity provider / directory

governing documentDocuments that govern the control

Board-approved ICT third-party policy, ICT internal audit plan and ICT budget, each with its review date · 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

Board approves the framework once and never revisits plans, audit plans or the third-party policy
No named owner for ICT third-party exposure in an entity that is not a microenterprise
Management body members with no ICT risk training on record

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 sheet

Art.6 ICT risk management framework