MiCA: DORA Compliance

DORA Compliance: A Guide for Crypto Asset Service Providers

Try being DORA Compliant

The Digital Operational Resilience Act (DORA), effective from January 17, 2025, is set to standardize how financial entities, including Crypto Asset Service Providers (CASPs), manage their digital and operational risks. Here’s what CASPs need to know to stay compliant and streamline their operations:

Key Requirements

1. Registers of Information (RoI): CASPs must maintain comprehensive records of all contracts with third-party ICT providers. These registers are vital for:

   • Monitoring third-party ICT risks.

   • Reporting to EU authorities for supervisory and risk management purposes.

   • Facilitating oversight of critical third-party ICT providers.

2. Reporting Standards:

   • The registers must be prepared at entity, sub-consolidated, and consolidated levels.

   • Data formats (e.g., CSV) and unique identifiers like the Legal Entity Identifier (LEI) are mandatory for proper reporting.

Lessons from the DORA - Dry Run Exercise

In 2024, a Dry Run involving over 1,000 financial entities highlighted areas requiring attention:

• Data Quality: Missing mandatory fields and invalid identifiers were common issues.

• Unique Identifiers: Accurate use of LEI codes for CASPs and their third-party providers is crucial.

• Reporting Format: The exercise underscored the importance of adhering to technical formats and ensuring data consistency.

Recommendations for CASPs

1. Enhance Data Completeness: Ensure your RoI is comprehensive and includes all required fields. Missing data may result in feedback loops and resubmissions.

2. Secure LEIs: CASPs must obtain valid LEI codes for themselves and their ICT service providers.

3. Streamline Reporting Tools: Adopt systems that automate compliance processes, such as converting data into the required reporting formats.

4. Stay Updated on Standards: Familiarize your team with the latest Implementing Technical Standards (ITS) and validation rules to avoid errors.

5. Engage Early with Authorities: Collaborate with your national competent authority to ensure smooth onboarding to reporting channels.

Why Compliance Matters

DORA introduces a unified framework that promotes operational resilience and risk management in Europe’s financial sector. For CASPs, compliance isn’t just a regulatory obligation—it’s a step toward greater trust and operational efficiency in a rapidly evolving digital landscape.

For more details on how to prepare for DORA compliance, explore resources provided by the European Supervisory Authorities (ESAs) or consult the latest regulatory guidelines.