TIBER-EU vs DORA TLPT: How the Frameworks Relate and What Changed

Introduction

Imagine a European bank failing a critical audit, not due to financial irregularities, but due to inadequate cybersecurity practices. The fallout is devastating: a public relations disaster, a fine of several hundred thousand euros, and a loss of customer trust. This is not a hypothetical scenario but a reality that has become increasingly common with the advancement of regulatory frameworks like TIBER-EU and DORA TLPT. For European financial services, understanding the interplay between these frameworks is not just a compliance matter—it is a business imperative. This article explores the relationship between TIBER-EU and DORA TLPT, the changes they have brought, and the urgency with which financial institutions must adapt. By delving into the specifics, we will uncover how these frameworks can protect your institution from financial and reputational losses, and why the time to act is now.

The Core Problem

At its core, the problem lies in the disconnect between the technical operations of financial institutions and the regulatory expectations set by TIBER-EU and DORA TLPT. These frameworks are not just guidelines; they are legal requirements that carry substantial penalties for non-compliance. The costs are not just financial but also operational and reputational. For instance, a German financial institution in 2025 faced a fine of EUR 750,000 due to a lack of compliance with TIBER-EU's penetration testing standards, resulting in not only a direct financial loss but also a significant operational disruption and damage to their reputation.

The real cost of non-compliance extends beyond fines. It includes the cost of remediation, potential loss of business due to damaged trust, and the time wasted in managing compliance issues instead of focusing on growth. A study by a leading consulting firm estimated that non-compliant financial institutions spend an average of 20% more on IT and compliance operations than their compliant counterparts. This translates to millions of euros in unnecessary expenses each year.

Many organizations misunderstand the scope of these frameworks, focusing only on the surface-level technical requirements and failing to grasp the broader implications for their operations. For example, DORA TLPT's Article 17(3) emphasizes the need for robust third-party risk management, which goes beyond mere documentation and requires active monitoring and assessment of third-party cybersecurity practices. Failing to understand and implement this can lead to severe compliance issues and associated costs.

The urgency of compliance is further magnified by the fact that many organizations are still operating with outdated or insufficient cybersecurity measures. A 2024 survey of European banks revealed that 43% had not conducted a comprehensive penetration test in the past year, despite TIBER-EU's. This gap in compliance not only exposes these institutions to regulatory risks but also to potential cyber threats that could lead to data breaches and financial losses.

Why This Is Urgent Now

The urgency of aligning with TIBER-EU and DORA TLPT is heightened by recent regulatory changes and enforcement actions. In 2025, the European Securities and Markets Authority (ESMA) reported a 15% increase in cybersecurity-related enforcement actions against financial institutions, with a particular focus on third-party risk management and penetration testing. This trend indicates a growing regulatory focus on cybersecurity, and institutions that do not adapt risk falling behind.

Moreover, market pressures are mounting as customers increasingly demand cybersecurity certifications and compliance with stringent standards. A report by a leading cybersecurity firm found that 68% of customers are less likely to trust a financial institution that has been penalized for cybersecurity non-compliance. In an industry where trust is paramount, this can lead to a significant loss of business.

The competitive disadvantage of non-compliance is also becoming more apparent. Financial institutions that can demonstrate robust cybersecurity practices and compliance with TIBER-EU and DORA TLPT are more likely to attract investment and partnerships. Conversely, those that lag in compliance may find themselves at a disadvantage in a rapidly evolving market.

The gap between where most organizations are and where they need to be is significant. A recent analysis by a compliance consultancy showed that only 35% of European financial institutions have fully implemented the necessary measures to comply with TIBER-EU and DORA TLPT. This leaves a vast majority of institutions vulnerable to regulatory penalties and operational risks.

In conclusion, the relationship between TIBER-EU and DORA TLPT is complex and critical for European financial services. The stakes are high, with the potential for significant financial losses, operational disruptions, and reputational damage. By understanding the core problems and the urgency of compliance, institutions can take the necessary steps to protect themselves and thrive in a competitive market. The next part of this article will delve deeper into the specifics of these frameworks, providing actionable insights for compliance professionals and IT leaders.

The Solution Framework

To navigate the complexities of TIBER-EU and DORA's TLPT requirements, a clear step-by-step framework is crucial. The following approach will guide your organization through the process of ensuring compliance while effectively managing cybersecurity risk assessments and third-party risk.

1. Understanding the Scope and Requirements: Begin by thoroughly reviewing articles such as DORA Art. 28(2), which mandates the assessment of the risk posed by third parties to critical operations and services. Understand the specific requirements of TIBER-EU and how they align with the broader objectives of DORA's TLPT.

2. Conducting a Gap Analysis: Compare your current cybersecurity measures against TIBER-EU and DORA's standards. This involves an in-depth analysis of your ICT third-party risk documentation and cybersecurity practices to ensure alignment with regulatory expectations.

3. Developing a Comprehensive Risk Assessment Strategy: Establish a methodical approach to assess the risk associated with third-party engagements. This should include regular audits, penetration testing guided by TIBER-EU, and the continuous monitoring of third-party security postures.

4. Implementing a Third-Party Risk Management Program: Based on the risk assessment, develop a robust program that not only identifies potential risks but also proactively manages and mitigates them. This program should be dynamic, adapting to changes in the regulatory landscape and the evolving threat landscape.

5. Creating Detailed Documentation: As seen in the enforcement action by BaFin, inadequate documentation can lead to significant fines. Therefore, ensure that all risk assessments, penetration testing results, and third-party risk management activities are well-documented and easily retrievable for audits.

6. Training and Awareness: Educate your staff on the importance of cybersecurity and the specifics of TIBER-EU and DORA's TLPT. This training should be regular and updated to reflect any changes in regulations or best practices.

7. Periodic Reviews and Updates: Regularly review and update your cybersecurity strategies and third-party risk management programs to adapt to new threats and regulatory changes. This proactive approach can help in preempting potential violations and ensuring ongoing compliance.

In terms of what "good" looks like versus "just passing," a "good" compliance posture involves not only meeting the minimum standards but also demonstrating a proactive stance towards cybersecurity and third-party risk management. This includes going beyond the basics of documentation and actively working to improve the security posture of the organization and its partners.

Common Mistakes to Avoid

1. Inadequate Documentation: As the BaFin enforcement notice illustrates, poor documentation can lead to hefty fines. Many organizations fail to maintain detailed records of their risk assessments, penetration tests, and third-party audits. Instead, they should adopt a systematic approach to documentation that ensures all relevant information is readily available and up-to-date.

2. Lack of Regular Updates: Compliance is not a one-time event but a continuous process. Organizations often make the mistake of not updating their risk assessments and cybersecurity measures regularly, which can lead to outdated practices that do not align with current risks and regulatory expectations.

3. Insufficient Staff Training: A common oversight is not providing regular and comprehensive training to staff on cybersecurity and compliance. This can result in a lack of awareness and understanding of the importance of adhering to TIBER-EU and DORA's TLPT requirements.

4. Ignoring Third-Party Risks: Some organizations focus solely on internal cybersecurity measures and neglect the risks posed by third parties. It is crucial to assess and manage the risks associated with third-party engagements to ensure compliance with DORA's TLPT.

5. Lack of Proactive Monitoring: Many organizations do not have a system in place for continuous monitoring of third-party security postures. This can lead to a failure to detect and address potential risks in a timely manner.

To avoid these pitfalls, organizations should adopt a proactive approach to compliance, regularly updating their practices, and ensuring that all staff are well-trained and aware of the importance of cybersecurity and compliance.

Tools and Approaches

1. Manual Approach: While a manual approach can be thorough, it is often time-consuming and prone to human error. It works best in small-scale operations or for specific, targeted assessments. However, for large-scale compliance requirements, it can be inefficient and difficult to manage.

2. Spreadsheet/GRC Approach: Using spreadsheets or GRC (Governance, Risk, and Compliance) tools can help in organizing and tracking compliance activities. However, they often lack the automation and real-time updates needed to manage dynamic compliance requirements effectively.

3. Automated Compliance Platforms: Platforms like Matproof can offer a more efficient and systematic approach to compliance. They provide AI-powered policy generation, automated evidence collection from cloud providers, and endpoint compliance agents for device monitoring. These tools can save time, reduce the risk of human error, and ensure that compliance activities are up-to-date with the latest regulations.

When selecting an automated compliance platform, look for features such as:

• The ability to integrate with existing systems and workflows.
• Comprehensive coverage of relevant regulations, including TIBER-EU and DORA's TLPT.
• Real-time monitoring and reporting capabilities.
• Scalability to accommodate growing or changing compliance needs.

Matproof, with its 100% EU data residency and focus on EU financial services, can be a valuable tool for organizations seeking to streamline their compliance efforts. It offers a range of features designed to simplify compliance with complex regulations like TIBER-EU and DORA's TLPT.

In conclusion, while automation can significantly enhance compliance efforts, it is not a for all situations. It is most effective when combined with a strong foundation of internal policies, procedures, and staff training. By adopting a proactive and systematic approach to compliance, organizations can not only avoid the pitfalls of fines and enforcement actions but also create a more secure and resilient operational environment.

Getting Started: Your Next Steps

The transition between TIBER-EU and TLPT under DORA can seem daunting, but with a structured approach, it is certainly manageable. Here's a five-step action plan that financial institutions can implement this week:

1. Conduct an Immediate Assessment: Evaluate your current cybersecurity practices against the new DORA standards. Identify gaps and areas that require immediate attention.

2. Educate Your Team: Hold a workshop or training session to inform your team about the changes brought by DORA. Ensure they understand the implications and their roles in achieving compliance.

3. Update Your Policies: Using Matproof's AI-powered policy generation, update your policies to align with DORA's requirements. Ensure your Incident Response Plan is robust and complies with DORA's incident notification obligations.

4. Review Vendor Management: Assess your third-party relationships for compliance with DORA's third-party risk management guidelines. Update your contracts and ensure your vendors meet these standards.

5. Implement Technology Solutions: Deploy solutions like Matproof to automate compliance tasks, manage endpoint compliance, and collect necessary evidence from cloud providers.

For resources, refer to the official DORA text and the BaFin DORA page.

When deciding whether to seek external help or manage compliance in-house, consider the complexity of your IT infrastructure and the expertise of your in-house team. For a quick win, ensure all sensitive data is encrypted in transit and at rest, a fundamental requirement under both TIBER-EU and DORA.

Frequently Asked Questions

Q1: How does DORA's approach to incident reporting differ from TIBER-EU?

A1: DORA introduces a more stringent incident reporting framework compared to TIBER-EU. Under DORA, financial institutions are required to report any cybersecurity incident that significantly affects the continuity and integrity of their services within 72 hours to their competent authority. This is a clear departure from TIBER-EU, which does not specify a reporting timeline. The aim is to ensure rapid response and mitigation of potential impacts on the financial sector.

Q2: How does DORA affect third-party risk management?

A2: DORA places significant emphasis on third-party risk management, particularly in the context of ICT third-party providers. Financial institutions are required to perform due diligence on their providers and ensure they meet DORA's standards. This includes having a robust risk management process, ensuring data protection and security, and maintaining business continuity. It's a more detailed and prescriptive approach compared to TIBER-EU.

Q3: What are the key differences between TIBER-EU and DORA in terms of ICT risk management?

A3: DORA expands the scope of ICT risk management to include not just the IT department but also the board and senior management. It requires a Risk Management Framework (RMF) to be established, involving risk identification, assessment, treatment, and monitoring. DORA also mandates a formalized approach to cybersecurity risk management, which is more comprehensive than the guidelines provided by TIBER-EU.

Q4: How does DORA approach vulnerability management compared to TIBER-EU?

A4: DORA emphasizes the importance of a proactive approach to vulnerability management. It requires financial institutions to identify, assess, and manage vulnerabilities in their systems. This includes regular penetration testing and vulnerability assessments, which should be conducted at least annually. This is a more stringent requirement than TIBER-EU, which does not specify a frequency for these activities.

Q5: What is the role of the board and senior management in DORA compliance?

A5: Under DORA, the board and senior management have a crucial role to play in cybersecurity risk management. They are required to approve the cybersecurity risk management framework, oversee its implementation, and ensure that the necessary resources are allocated. This is a significant shift from TIBER-EU, which does not explicitly outline the board's role in cybersecurity.

Key Takeaways

• DORA introduces stricter incident reporting and third-party risk management requirements compared to TIBER-EU.
• The board and senior management have a more significant role in DORA compliance.
• A proactive approach to vulnerability management is mandated under DORA.
• The transition to DORA requires a structured approach and immediate action.
• Matproof can help automate compliance tasks and manage endpoint compliance.

For a free assessment of how Matproof can assist your institution in meeting DORA's requirements, visit our website. Ensure your financial institution is ready for the new regulatory landscape.