The DORA (Digital Operational Resilience Act) regulation imposes an obligation on financial entities to build digital resilience. One of its most critical pillars is cyclical and measurable cybersecurity training. Although the regulations mandate ICT security training, they do not dictate a single specific format. This creates an opportunity to move away from boring presentations in favor of modern education that actually changes employee behavior.

What is the DORA Regulation in the Context of Human Capital?

DORA is an EU regulation aimed at harmonizing digital resilience requirements for the financial sector and its providers. Beyond technical aspects, the regulation places immense emphasis on the human factor.

According to the rules, financial entities must establish comprehensive training and ICT security awareness programs. Why is this so important? Because even the most advanced firewalls won't help if an employee clicks on a well-crafted phishing link.

What Training Obligations Does DORA Impose?

1. Universality: Training for Employees and the Board

DORA requires awareness programs to cover the entire organization. Unlike many previous regulations, training for the Board of Directors and senior management is mandatory here. They are the ones responsible for strategic ICT risk management.

2. Proportionality and Content Personalization

The message must be tailored to the role. The accounting department faces different risks than network administrators. An effective training program must account for these differences. Different threats lurk for a back-office worker than for a network admin or a CFO. DORA requires that education reflects the real-world risk associated with a given role within the ICT structure.

3. Cyclicality and Up-to-Date Knowledge

According to the guidelines, education cannot be a one-off event. Knowledge must be regularly updated to keep pace with evolving cybercriminal methods (e.g., deepfakes, advanced spear phishing, or supply chain attacks).

Important: DORA requires measurability. You must be able to prove to an auditor who was trained, when, and with what result.

DORA and the Supply Chain: Why Subcontractors Must Also Train

Financial institutions do not operate in a vacuum. They use third-party services daily—from cloud providers to software developers. The DORA regulation understands this perfectly, which is why it scrutinizes the security of the entire supply chain.

DORA obliges financial entities to consider risks stemming from third parties, ensuring the regulation covers the entire financial sector supply chain. This means:

• Banks and insurers will cascade security requirements down to their business partners.
• Third-party ICT service providers will have to meet new contractual requirements, including terms for their participation in ICT security training programs.
• In practice, an IT or SaaS provider will also have to prove to the financial institution that their team is regularly trained in cybersecurity.

In short: if your company provides services to the financial sector, a lack of regular cybersecurity training for employees may soon mean difficulties in maintaining or winning key contracts.

Why Training Measurability is the Key to Audit Success

As of January 2025, DORA regulations are fully enforced. Regulators are already verifying the completeness of reports and evidence of training conducted over the past year. To pass an audit successfully, your training platform must generate reports containing:

• Individual progress of each employee.
• Test and quiz results (knowledge verification).
  
• Evidence of the regularity of actions taken (e.g., monthly phishing simulations).
  

Interactive Games vs. Traditional Slides – Which Format to Choose?

Cost and Operational Efficiency

By choosing an Awareness as a Service model, you can reduce the workload for IT and HR departments by up to 90%. Ready-made gamification-based scenarios, such as those in Mission: Cybersecurity, ensure higher engagement than passive learning methods.

Building a Security Culture, Not Just Compliance

DORA emphasizes "resilience." Interactive games allow employees to make mistakes in a safe environment, which permanently changes their habits in reality.

Scenario-based training scheme: Mission: Cybersecurity

Benefits of Implementing an Awareness Building Program

By choosing interactive training forms compliant with DORA, such as our Awareness Building Program at Mission: Cybersecurity, you gain:

• Compliance: You have hard data and reports for regulators.
• Building a Security Culture: Cybersecurity stops being "an IT department issue" and becomes a shared value.
  
• Cost Reduction: The cost of a single incident caused by human error is many times higher than an investment in effective education.

Summary: Your DORA Compliance Checklist

• Did you train the Board in 2025?
• Do you have access to measurability reports for every department? 
• Are your trainings updated with the latest threats?

Frequently Asked Questions (FAQ) – Training Compliance with DORA

Is DORA training mandatory for the Board?

Yes, the DORA regulation strictly requires awareness programs to cover the entire organization, with mandatory training for the Board and senior management. This is crucial as they are responsible for the organization's strategic ICT risk management.

Will a DORA auditor verify training measurability and reports?

Definitely yes. DORA requires measurability – you must be able to prove to an auditor who was trained, when, and with what result. Your platform must generate detailed reports containing individual employee progress and test/quiz results.

How often should cybersecurity training be updated?

According to the guidelines, education cannot be a one-off event. Knowledge provided to employees must be regularly updated with the latest attack vectors to keep up with evolving cybercriminal methods (such as deepfakes or advanced spear phishing).