This guide provides realistic cost ranges and factors to consider when budgeting for DORA compliance.
Key Takeaways
| Point |
Summary |
| Variable costs |
Compliance costs range from tens of thousands to millions of euros |
| Size dependent |
Larger, more complex entities face higher costs |
| Maturity matters |
Organizations with existing frameworks have lower incremental costs |
| Ongoing investment |
Compliance requires continuing, not one-time, investment |
| Penalty comparison |
Non-compliance penalties can far exceed compliance costs |
Quick Answer: DORA compliance costs vary widely based on organization size and maturity. Smaller fintechs with existing security programs may spend 20,000 to 100,000 annually, while larger financial institutions could invest several hundred thousand to millions annually. Key cost drivers include ICT risk management framework development, testing programs (especially TLPT), third-party risk management, and staff or external expertise. Proportionality allows smaller entities to implement appropriate measures without excessive spending.
Cost Categories
One-Time Implementation Costs
| Category |
Description |
| Gap assessment |
Evaluating current state against requirements |
| Framework development |
Creating policies, procedures, documentation |
| Technology implementation |
Tools for monitoring, compliance, reporting |
| Contract remediation |
Reviewing and amending third-party contracts |
| Initial testing |
Baseline testing activities |
| Training |
Initial staff and management training |
| External expertise |
Consultants, legal review, specialist support |
Ongoing Annual Costs
| Category |
Description |
| Staff |
Dedicated compliance personnel or allocated time |
| Testing |
Vulnerability assessments, penetration testing, TLPT |
| Tools and platforms |
Compliance, GRC, and security tools |
| Training |
Ongoing staff and management training |
| Third-party monitoring |
Provider oversight and assessments |
| Audit and assurance |
Internal audit, external validation |
| Incident management |
Response capabilities, reporting infrastructure |
Cost Ranges by Entity Size
Microenterprises and Small Fintechs
| Cost Type |
Range (Annual) |
| Implementation (first year) |
15,000 - 50,000 |
| Ongoing compliance |
10,000 - 40,000 |
| Testing |
5,000 - 20,000 |
| External support |
10,000 - 30,000 |
| Total first year |
40,000 - 140,000 |
| Total ongoing (annual) |
20,000 - 80,000 |
Microenterprises benefit from simplified requirements and proportionate measures.
Mid-Sized Financial Entities
| Cost Type |
Range (Annual) |
| Implementation (first year) |
50,000 - 200,000 |
| Ongoing compliance |
30,000 - 100,000 |
| Testing |
20,000 - 80,000 |
| External support |
30,000 - 100,000 |
| TLPT (if designated) |
100,000 - 300,000 (every 3 years) |
| Total first year |
130,000 - 480,000 |
| Total ongoing (annual) |
80,000 - 280,000 |
Larger Financial Institutions
| Cost Type |
Range (Annual) |
| Implementation (first year) |
200,000 - 1,000,000+ |
| Ongoing compliance |
100,000 - 500,000+ |
| Testing (non-TLPT) |
50,000 - 200,000 |
| TLPT |
300,000 - 1,000,000+ (every 3 years) |
| External support |
100,000 - 500,000+ |
| Technology |
50,000 - 300,000+ |
| Total first year |
500,000 - 2,500,000+ |
| Total ongoing (annual) |
300,000 - 1,200,000+ |
Key Cost Drivers
Organizational Factors
| Factor |
Impact on Cost |
| Entity size |
Larger entities have more systems, people, and complexity |
| Geographic spread |
Multi-jurisdiction operations increase complexity |
| Group structure |
Groups require consolidated compliance |
| Current maturity |
Lower maturity means more to build |
| Existing certifications |
ISO 27001 reduces incremental effort |
Scope Factors
| Factor |
Impact on Cost |
| Number of critical functions |
More critical functions require more attention |
| ICT complexity |
Complex architectures need more documentation and testing |
| Third-party count |
More providers mean more RoI entries and contracts |
| TLPT designation |
TLPT adds significant testing costs |
Approach Factors
| Factor |
Impact on Cost |
| Internal vs. external |
External expertise costs more but may be faster |
| Build vs. buy tools |
Technology platforms have varying costs |
| Compliance-only vs. improvement |
Minimal compliance costs less than building excellence |
Cost Component Details
ICT Risk Management Framework
| Component |
Cost Range |
| Policy development |
10,000 - 50,000 |
| Procedure documentation |
10,000 - 40,000 |
| Risk assessment |
10,000 - 50,000 |
| Business impact analysis |
5,000 - 30,000 |
| Training development |
5,000 - 20,000 |
Testing Costs
| Testing Type |
Cost Range |
| Vulnerability assessment |
5,000 - 25,000 per assessment |
| Penetration testing |
10,000 - 50,000 per test |
| TLPT (full engagement) |
200,000 - 1,000,000+ |
| Business continuity testing |
5,000 - 30,000 |
| Backup recovery testing |
2,000 - 10,000 |
Third-Party Risk Management
| Component |
Cost Range |
| Contract review (per contract) |
1,000 - 5,000 |
| Due diligence (per provider) |
500 - 5,000 |
| RoI preparation |
10,000 - 50,000 |
| Ongoing monitoring (annual) |
10,000 - 100,000 |
External Support
| Support Type |
Cost Range |
| Gap assessment |
10,000 - 50,000 |
| Implementation support |
30,000 - 200,000+ |
| Managed compliance (annual) |
30,000 - 150,000 |
| Legal review |
10,000 - 50,000 |
| Audit support |
10,000 - 40,000 |
Return on Investment
Penalty Avoidance
Non-compliance penalties can reach 2% of annual worldwide turnover. For a company with 50 million turnover, this is up to 1 million. Compliance investment is typically a fraction of potential penalties.
Operational Benefits
DORA compliance investments often deliver broader value:
| Benefit |
Impact |
| Improved resilience |
Reduced incident frequency and impact |
| Faster recovery |
Lower business interruption costs |
| Better third-party relationships |
Reduced supply chain risks |
| Customer confidence |
Competitive advantage in B2B relationships |
| Efficiency |
Streamlined processes and better visibility |
Multi-Framework Synergies
Investment in DORA compliance supports other frameworks:
| Framework |
Synergy |
| ISO 27001 |
Significant overlap, shared controls |
| SOC 2 |
Common security and availability requirements |
| NIS 2 |
DORA is lex specialis but shares principles |
| GDPR |
Overlapping incident management |
Budget Planning
First-Year Budget Template
| Category |
Estimated % of Total |
| Assessment and planning |
10-15% |
| Framework development |
20-30% |
| Testing |
15-25% |
| Third-party management |
15-20% |
| External support |
15-25% |
| Training |
5-10% |
| Contingency |
10-15% |
Ongoing Budget Template
| Category |
Estimated % of Total |
| Staff/allocated time |
30-40% |
| Testing (annual) |
15-25% |
| Tools and platforms |
10-20% |
| External support |
15-25% |
| Training |
5-10% |
| Contingency |
5-10% |
Cost Optimization Strategies
Leverage Existing Investments
- Build on ISO 27001 if certified
- Use existing GRC platforms
- Extend current security tools
- Integrate with existing processes
Prioritize Based on Risk
- Focus on critical functions first
- Defer lower-risk activities
- Use proportionality appropriately
- Document risk-based decisions
Consider Managed Services
- External expertise for specialized areas
- Shared services for common functions
- Pay-as-you-go for variable needs
- Managed compliance for ongoing support
Build Efficiency
- Automate evidence collection
- Standardize documentation
- Integrate compliance into operations
- Train staff to reduce external reliance
Common Questions
Is DORA compliance worth the investment?
For most in-scope financial entities, yes. The compliance investment is typically a fraction of potential penalties (up to 2% of annual worldwide turnover). Beyond avoiding fines, DORA compliance delivers operational benefits: improved resilience reduces incident frequency and impact, better third-party management reduces supply chain risks, and demonstrated compliance can be a competitive advantage with enterprise clients and partners who increasingly require supplier compliance.
What is the minimum we can spend?
Minimum spend depends on your size and complexity. Microenterprises with simple operations might achieve compliance for 20,000-40,000 annually. However, cutting corners may create compliance gaps and risk penalties that far exceed savings.
Should we build internal capability or use consultants?
Most organizations use a combination. Build internal ownership and core capabilities, but use consultants for specialized areas (TLPT, legal review, complex assessments). Over time, shift more work internal as capability develops.
How do we justify the budget to leadership?
Frame as risk management: penalty avoidance (up to 2% of turnover), operational resilience (reduced incident impact), and business enablement (customer and partner requirements). Compare compliance cost to potential penalty and business impact scenarios.
Will costs decrease over time?
Implementation costs are front-loaded. Ongoing costs should stabilize, though TLPT (every 3 years for designated entities) creates periodic spikes. Efficiency improvements and automation can reduce costs over time.
What if we cannot afford full compliance?
Apply proportionality: implement appropriate measures for your size and risk profile. Document your approach and rationale. Prioritize highest-risk areas. Consider managed services to spread costs. Engage with regulators transparently about resource constraints.
How Bastion Helps
Bastion helps financial entities achieve cost-effective DORA compliance:
- Efficient implementation: Structured approach minimizing wasted effort
- Right-sized solutions: Proportionate recommendations for your size
- Managed services: Predictable ongoing costs for continuous compliance
- Multi-framework approach: Leverage investments across DORA, ISO 27001, and others
- Transparent pricing: Clear understanding of costs before engagement
Ready to understand your DORA compliance investment? Talk to our team
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