Harmonizing DORA: How to Stop Duplicating Controls and Build a Single Resilience Framework for European FinServ

European financial services firms face a regulatory paradox: DORA was designed to harmonize digital operational resilience requirements, yet its implementation is creating unprecedented control duplication. Firms are building separate control sets for DORA, NIS2, PSD2 strong authentication, ECB TIBER-EU, and existing national regulations — multiplying compliance costs while fragmenting their resilience posture. This paper provides a practical framework for true harmonization: mapping control overlaps across all applicable regulations, identifying a minimum effective control set that satisfies all requirements simultaneously, and building a single resilience framework that reduces both cost and complexity.

The framework includes detailed control mapping matrices, implementation prioritisation guidance, and evidence management strategies that allow single controls to serve multiple regulatory purposes.