For many CISOs and risk management leaders, understanding and implementing DORA vs NIS2 requirements has become essential. Knowing where your organization stands helps you decide who owns which risks, what evidence you need to show regulators, and how aggressive you need to be about testing resilience.

Both frameworks push you towards better cyber resilience, but they start from different places:

• DORA is a financial sector regulation that goes deep into digital operational resilience for financial entities and their critical ICT (information and communications technology) providers.
• NIS2 is a broader directive that raises cybersecurity requirements across 18 critical sectors via risk management and incident reporting duties for “essential” and “important” entities.

This post presents a practical comparison for security and risk management leaders, with a special focus on the role of application security.

Purpose and scope of DORA and NIS2

At a high level, both DORA and NIS2 aim to prevent small ICT incidents from becoming big societal problems. The main difference is which organizations are covered and what controls and measures are directly prescribed in each regulation.

DORA: Operational resilience for financial entities and ICT providers

DORA (Digital Operational Resilience Act) is an EU regulation that has applied directly in EU member states since 17 January 2025. Its main purpose is to ensure that financial entities can withstand, respond to, and recover from ICT disruptions. To do that, the act defines a harmonized framework for:

• ICT risk management and governance
• ICT incident classification and reporting
• Digital operational resilience testing
• ICT third-party risk management and oversight of critical providers
• Information sharing on cyber threats

Importantly, DORA explicitly states that critical ICT failures aren’t merely IT problems but systemic risks to financial stability, no matter if they stem from cyberattacks, cloud provider outages, or other causes.

NIS2: Cybersecurity baseline for essential and important entities

NIS2 (Network and Information Systems Directive 2, officially EU directive 2022/2555) is the updated EU framework for network and information system security. Unlike DORA, the directive needs to be transposed into national law, so the specific scope may vary slightly depending on the country. Even though NIS2 came into force in January 2023 and EU member states had until 17 October 2024 to transpose it, not all states have completed the process as of early 2026.

Compared to DORA, the purpose of NIS2 is broader:

• Establish a unified legal framework for cybersecurity across 18 critical sectors
• Require risk management measures and incident reporting for “essential” and “important” entities
• Strengthen supervision, enforcement, and cross-border cooperation on cyber incidents

Where DORA is about financial stability and digital operational resilience, NIS2 is about raising the minimum cybersecurity bar for critical services across the EU economy.

Who must comply with NIS2, DORA, or both

At the board level, the first question for any compliance requirement is usually: “Are we in scope?” For DORA and NIS2, this depends on the industry, size, and importance of the organization, with DORA focused squarely on financial entities while NIS2 covers a wider set of economy-critical sectors:

For organizations covered by either regulation, this creates at least three common situations:

1. Large financial entities that are clearly in scope for DORA and often also fall under NIS2 as “essential” entities in the financial or digital infrastructure sectors.
2. Non-financial critical infrastructure operators that are squarely under NIS2 but not DORA.
3. ICT and cloud providers that may be in scope as NIS2 entities and, in some cases, as critical ICT providers under DORA.

Exactly how parallel obligations interact depends on national law and sector-specific regulators, so each organization needs to find its own mapping.

Core focus areas for DORA and NIS2

Both frameworks talk about similar concepts, such as risk management, incident reporting, and testing, but differ in depth and emphasis. In practice, DORA’s emphasis on resilience rather than more generalized security will often drive more prescriptive testing and third-party assurance requirements for financial entities when compared to NIS2 expectations for other sectors.

Key DORA vs. NIS2 differences that matter for CISOs

There are four high-level differences that typically matter most for security and risk management leaders.

Continuous resilience testing vs general security testing

DORA expects sizable financial entities to run a “sound and comprehensive” digital operational resilience testing program that employs a mix of techniques, from vulnerability assessments and scans to penetration tests and threat-led exercises, and is tied directly into the ICT risk management framework. NIS2 clearly expects regular testing as part of risk management but does not define the specific mechanics to the same depth. Member states and sector regulators will often fill this gap with their own guidance and frameworks.

Of the two, DORA is more likely to force you into formal, scoped, and recurring resilience testing, especially on systems supporting critical functions.

Sector specificity vs cross-sector baseline

DORA is tightly scoped to the financial sector, with detailed expectations for ICT governance, incident classification, third-party contracts, and even test types. NIS2 provides a single cybersecurity baseline for many sectors, from healthcare to space. It sets objectives and categories of measures and then leaves room for national and sector-specific interpretation.

If you are in finance, DORA often interacts with potential NIS2 obligations, though some national implementations exempt institutions from NIS2 compliance if covered by DORA. If you run a critical facility like a hospital or a port, NIS2 is likely your primary EU cyber regime.

ICT supplier obligations and oversight

DORA goes further than most frameworks in directly addressing ICT third-party risk and mandating controls:

• Financial entities must maintain detailed registers of ICT contracts and dependencies.
• Contracts must contain specific rights and obligations around access, audit, data location, sub-outsourcing, incident support, and exit.
• Critical ICT providers (for example, large cloud platforms) can be designated and supervised at EU level.

While NIS2 absolutely also expects you to manage supply-chain security and third-party risk, it focuses more on outcomes (e.g., ensuring suppliers meet security standards) than on specific and prescriptive contract language.

Breadth of industries and depth of requirements

Perhaps the most obvious difference between the two regulations is that DORA is deep and narrow, while NIS2 has a wider scope with less detailed requirements. DORA goes into a lot of prescriptive detail but only focuses on financial services plus critical ICT providers that support them. NIS2, on the other hand, provides only high-level security and resilience expectations but covers most large entities across 18 sectors deemed essential or important.

In practice, many business groups, especially those with financial arms and broader critical infrastructure, will have entities that fall under both regimes, separately or combined.

Overlap areas you can treat as shared controls for DORA and NIS2

Despite the differences, there is substantial overlap where you can design once and satisfy multiple requirements. Key shared themes across both DORA and NIS2 include:

• Incident detection and reporting: Both expect robust incident response, classification, and timely reporting to authorities for significant incidents.
• Risk management governance: Both bring cybersecurity and ICT risk into the governance and risk management framework, with clear board-level accountability.
• Security controls and monitoring: Both expect risk-based technical and organizational measures, continuous monitoring, and ongoing improvement.
• Third-party risk awareness: Both elevate supply-chain security, even if DORA is more specific about financial ICT contracts and oversight.

For a CISO running a group-wide program, the practical move is to build a single control framework that can be mapped to both DORA and NIS2 obligations as needed.

How to prepare for both DORA and NIS2

With all the overlaps as well as general security best practices, a lot of the work you do in support of one regulation will support the other. A pragmatic approach for CISOs and risk management leaders might encompass the following steps.

1. Map entities, services, and regulatory scope

The first step is to decide what you’re working with and which regulations you’re subject to:

• Identify which entities in your group are financial entities under DORA, which are essential or important entities under NIS2, and where the two sets overlap.
• Map critical services and business processes, then link them to underlying ICT assets, especially public-facing web applications and APIs that support core functions.

2. Align ICT and cyber risk management frameworks

Rather than building separate frameworks, standardize on a common set of policies, processes, and registers that can satisfy both regimes, including:

• One ICT and cybersecurity risk management framework aligned with recognized standards (for example, ISO/IEC 27001 plus sectoral guidance), mapped to DORA and NIS2 articles and incorporating application security risks.
• A single set of risk registers, asset inventories, and control catalogs that cover business services as well as their underlying applications.
• Clear ownership and accountability at the management and board level for ICT and cyber risk.

3. Enforce a security testing process for critical apps and APIs

DORA explicitly calls out vulnerability assessments, scanning, and penetration testing as part of digital operational resilience testing. For critical services (financial or otherwise) that depend on web applications and APIs, that means:

• Defining a testing strategy that combines vulnerability scanning, penetration testing, resilience testing, and code-level security.
• Prioritizing testing frequency based on business criticality and exposure. For finance, this could mean putting front-door banking portals and payment APIs on tighter cadences.
• Making sure that testing feeds into remediation workflows with SLAs aligned to business risk and impact, not just CVSS scores.

For NIS2 entities, that same continuous testing process becomes evidence of “appropriate and proportionate” technical measures and risk-based security practice.

4. Standardize incident response and reporting workflows

Build a single incident lifecycle that can support different reporting obligations (DORA’s detailed incident classification and reporting requirements as well as national-level reporting and supervisory expectations under NIS2):

• One incident taxonomy and severity model that covers ICT incidents under DORA and significant cyber incidents under NIS2.
• Playbooks that include regulatory notification triggers and templates, so teams do not have to improvise under pressure.
• Centralized logging and monitoring across infrastructure, applications, and third-party services to support timely detection and investigation.

5. Rationalize third-party assurance and security addenda

Treat supplier security as a first-class risk area rather than a procurement checkbox. If you are an ICT provider, assume your customers will ask questions around this and be ready with answers:

• Maintain a single register of ICT and critical suppliers with data on services provided, locations, data flows, and resilience dependencies.
• Use standardized security addenda and due-diligence questionnaires that incorporate DORA-style expectations (e.g., audit rights, incident notification, access to logs, sub-outsourcing transparency), adapted as needed for NIS2 entities.
• Ask for concrete evidence, from certifications and pentest summaries to uptime and incident statistics, rather than relying only on policy statements.

Invicti’s role in a DORA and NIS2 world

Neither DORA nor NIS2 can be “solved” by a single tool, but some technologies can do a disproportionate amount of heavy lifting in showing that you understand, monitor, and reduce digital risk. Invicti focuses on the application layer, which is where many critical business services live today. 

The Invicti platform is built around a DAST-first approach that is designed for continuous discovery and accurate security testing of modern web applications and APIs. Here’s how that helps in the context of DORA and NIS2.

Validating exploitable vulnerabilities that threaten operational continuity

Invicti’s proof-based scanning uses safe, read-only payloads and automatic confirmation steps to prove that a wide range of vulnerabilities are actually exploitable, not just potential or theoretical. That significantly reduces false positives and pushes truly exploitable issues to the top of the queue.

From a DORA and NIS2 perspective, this lets you clearly link validated vulnerabilities to specific business services and resilience risks. That way, you can demonstrate that you are not only scanning but also verifying and remediating issues that could disrupt critical operations.

For CISOs, this turns “we ran a scan” into “here are some real issues that could take down a critical service, and here is how we handled them.”

Continuous testing to support resilience mandates

Because Invicti is built for automated testing in a continuous process, you can:

• Schedule recurring scans for critical applications and APIs that support DORA-relevant services (e.g., online banking, trading platforms, insurance portals).
• Integrate scans into CI/CD pipelines so new releases are tested before they reach production to support both resilience and secure-by-design expectations.
• Track remediation and retesting over time to create an audit trail that can support supervisory conversations under both DORA and NIS2.

This aligns directly with DORA’s expectation for structured, ongoing digital operational resilience testing and provides strong evidence of risk-based security practice under NIS2.

Using AI-backed prioritization and ASPM to focus on real risk

On the Invicti platform, application security posture management (ASPM) combined with AI-backed Predictive Risk Scoring helps you:

• Identify your riskiest web assets based on exposure, business context, and vulnerability data.
• Prioritize remediation where it most reduces operational and compliance risk, rather than chasing every finding equally.
• Maintain a live view of your application and API attack surface across business units and entities.

For both DORA and NIS2 programs, this supports a defensible story: you know where your critical application risks are, you can show why you are prioritizing certain fixes, and you can link that back to business continuity.

A unified platform for testing, evidence, and reporting

Finally, Invicti’s unified platform combines multi-level security testing and asset discovery within a centralized vulnerability management and reporting system integrated into issue trackers and DevSecOps pipelines. That means your teams can use a single system of record for application-layer vulnerabilities, remediation status, and testing history – useful both for internal governance and as supporting evidence for regulators and auditors.

Conclusion: Strengthening DORA and NIS2 resilience with application-layer visibility

DORA and NIS2 both push organizations to demonstrate that they understand their digital risks and can keep critical services running when something goes wrong. Application security sits at the center of that reality. The most direct way to show control over those risks is to continuously identify and validate the vulnerabilities that could disrupt the services regulators care about.

Invicti helps you do exactly that by providing a DAST-first platform that focuses on real, exploitable issues in your web applications and APIs. With proof-based scanning, continuous testing, and ASPM-driven prioritization, teams can build a repeatable process for finding, validating, and addressing the vulnerabilities that matter most.

If you are looking into how DORA or NIS2 obligations affect your application security program and capabilities, request a demo to see how Invicti can support a clearer, evidence-driven approach to operational resilience.