DORA Compliance for Procurement | What EU Financial Leaders Must Know

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As European financial institutions begin operating under the Digital Operational Resilience Act (DORA), the procurement function becomes a critical node in compliance. Missteps in vendor selection, contractual design or oversight can expose a bank or insurer to regulatory scrutiny, operational interruptions or legal risk. This guide explains how procurement, sourcing and vendor management teams must adapt, and shows how Zycus’s latest technologies help.

TL;DR

DORA compliance for procurement is now a legal and operational priority for EU financial institutions.
Banks and insurers must embed resilience, traceability, and oversight into every vendor and ICT contract.
Procurement teams play a central role in enforcing DORA clauses, auditing subcontractors, and managing continuous vendor monitoring.
Cross-functional collaboration between procurement, risk, cyber, and legal teams is essential for regulatory readiness.
Zycus’s Merlin Agentic AI Platform enables automation of DORA compliance gates, supplier resilience checks, and transparent audit trails.
Acting early ensures financial leaders build resilient, compliant, and future-ready procurement operations under the EU’s 2025 DORA mandate.

What is DORA and Why Procurement Matters

DORA (Regulation (EU) 2022/2554) entered into application on 17 January 2025. It mandates that financial entities and certain ICT third-party providers adopt robust digital operational resilience guardrails across multiple pillars: ICT risk management, incident management, operational resilience testing, third-party oversight, and information sharing.

Procurement plays a strategic compliance role under DORA in several ways:

Third-Party Risk Management (TPRM): DORA forces financial institutions to rigorously classify, monitor and audit ICT service providers, especially those deemed “critical or important.”
Contractual Clauses & Oversight: Procurement must embed clauses that permit audit, exit, subcontracting control, data access, and incident reporting in vendor contracts.
Operational Resilience Testing: Procurement must ensure vendors support threat-led penetration testing (TLPT) and resilience test requirements.
Incident Reporting and Response: Contracts must enforce timely reporting of ICT incidents, root cause readiness and coordinated response.
Subcontracting Controls: DORA’s Delegated Regulation 2025/532 adds detailed standards for ICT subcontracting, obliging that obligations flow down to sub-vendors and that oversight extends to them.

Procurement leaders must evolve from transactional sourcing to active resilience architects.

Key Procurement Adaptations Under DORA

Below are six adaptation priorities that procurement teams in regulated financial institutions must take now.

1. Criticality Mapping & Vendor Segmentation

Not every vendor is subject to the same DORA scrutiny. Procurement must classify ICT providers by criticality (service disruption impact, systemic risk) and apply stricter diligence, audit rights and resilience clauses to those in “critical or important” categories.

2. Enhanced Due Diligence & Questionnaires

Standard supplier questionnaires must expand to capture DORA-relevant data: cybersecurity posture, incident history, subcontracting structure, capacity for TLPT, disaster recovery plans, audit readiness, compliance frameworks (ISO, NIST etc.).

3. Contract Design with Built-In Resilience

Vendor contracts should include:

Rights of audit and inspection for critical providers
Clauses that forbid subcontracting without prior written consent
Exit strategy and data migration provisions
Obligation to report ICT incidents within specified timelines
Support for operational resilience testing and penetration exercises
Flow-down of DORA obligations into subcontractor arrangements

4. Monitoring, Auditing & Compliance Gatekeeping

After contract award, procurement must maintain continuous oversight:

Periodic audits or sampling of vendor compliance
Use of dashboards and trigger alerts if risk metrics change
Regular reviews of subcontracting changes
Ensure vendors maintain versioned logs, evidence trails and transparency

5. Integration with Risk, Legal and Cyber Teams

Procurement cannot work in isolation. A cross-functional DORA working group must integrate procurement, cyber, legal, risk and compliance to maintain alignment, establish control frameworks and validate agent or platform behaviour.

6. Tooling That Provides Traceability & Automation

Manual tracking of hundreds of vendor contracts becomes unsustainable. Procurements teams need systems that provide traceability, versioning, alerts, and decision workflows tied to risk thresholds.

How Zycus’s Platform Is Helping Financial Procurement Meet DORA

Zycus’s recent innovations align tightly with those adaptation priorities above. Below are key platform capabilities that help procurement teams in regulated financial settings.

Merlin Agentic AI: Orchestrated Intelligence Under Governance

Zycus’s Merlin Agentic AI Platform provides low-code orchestration of intelligent agents across procurement workflows. These agents act under configurable guardrails, apply policy checks, monitor risk metrics, and maintain audit trails.

In a DORA context, agents can monitor vendor risk scores, flag deviations from contractual KPIs, signal subcontractor changes, and support compliance gates before awarding or renewing ICT contracts.

Supplier Performance & Risk Module

The Agentic AI for Supplier Management module automates insights and compliance monitoring across supplier bases. It can enrich vendor profiles, flag anomalies, and generate real-time risk indicators.

For financial procurement, this means early warning of vendor risk shifts that may require remediation or contract renegotiation.

Intelligence in Contract Compliance

Zycus is embedding intelligence in its contract modules, enabling metadata extraction, clause risk scoring, and continuous obligation monitoring. These capabilities support design of DORA-compliant clauses and ongoing contract vigilance.

Supply Chain Resilience Agent

Zycus’s Agentic AI for Supply Chain Resilience combines intake, negotiation, and risk detection to propose alternative sourcing or mitigate disruption. In a regulated environment, it helps procurement stay ahead of vendor disruptions that could impair operational resilience.

Market Recognition & Strategic Direction

Zycus is recognized as a Customers’ Choice in 2025 Gartner® Peer Insights™ “Voice of the Customer” for Source-to-Pay Suites. Zycus is also named a Leader in IDC MarketScape: Worldwide AI-Enabled Source-to-Pay 2025 Vendor Assessment.

By shifting from AI as a tool to AI as an architecture, Zycus positions procurement teams to meet rising regulatory demands.

Practical Steps for Procurement Leaders in 2025 and Beyond

Gap Assess your vendor estate against DORA’s due diligence, resilience and reporting requirements.
Pilot resilience agents in critical ICT contracts to validate automation, alerts, and audit logs.
Embed DORA clauses as non-negotiables in all new ICT vendor agreements, even for non-critical providers.
Set up cross-functional oversight desks where procurement, cyber, legal and risk review flagged incidents or deviations.
Iterate agent logic with compliance rules and refine over time—don’t deploy full autonomy initially.
Focus on traceability, not speed—regulators will want audit logs, decision trails, overrides, and model explainability.

Final Word

Procurement in regulated financial institutions now operates under a new paradigm. Compliance is no longer an afterthought but baked into vendor engagement, contract design, and continuous monitoring. Under DORA, procurement teams must elevate their role—not merely acquiring ICT services but ensuring those services uphold digital resilience standards at every level.

Zycus’s agentic platform and AI-enabled modules give procurement teams the tools to manage risk with intelligence, transparency and scale. If your procurement architecture lacks resilience, traceability or orchestration, regulatory review will expose gaps. The better path is to adapt now—align your sourcing practice with DORA’s pillars, deploy intelligent agents under guardrails, and build procurement as a pillar of digital resilience.

Get started with Zycus today.

FAQs

Q1. What is DORA and why does it matter for procurement?
DORA requires financial institutions to strengthen ICT resilience, vendor oversight, and third-party risk management—making procurement essential to regulatory compliance.

Q2. What changes must procurement teams implement under DORA?
Teams must classify vendors by criticality, enforce DORA clauses in contracts, enable ICT risk audits, and ensure traceable supplier monitoring.

Q3. How can Zycus support DORA compliance?
Zycus’s Merlin Agentic AI Platform automates vendor risk tracking, clause validation, and audit workflows, ensuring compliance and resilience.

Q4. What are the key risks of non-compliance?
Failure to comply with DORA can lead to operational disruptions, regulatory penalties, and loss of trust from stakeholders and customers.

Q5. What’s the next step for financial CPOs?
Integrate compliance automation, data traceability, and agentic oversight into procurement systems to meet DORA’s 2025 enforcement standards.

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Anthony Gray

VP, Northern Europe at Zycus. With 20+ years in Telco, AI, Knowledge Management and Procurement Tech, Anthony helps enterprises digitally transform and scale smarter.