DORA compliance for FinTechs - built for cloud-native teams.
The Digital Operational Resilience Act holds FinTechs to the same standard as global banks. Matproof automates Articles 5 through 45 - from ICT risk management across your cloud stack to third-party registers for every API partner - so your lean team can ship fast and stay compliant.
The Challenge
Why DORA hits FinTechs differently
FinTechs are cloud-native, API-driven, and built to move fast. DORA was written for an industry that moves slowly. The result is a regulatory framework that demands enterprise-grade ICT governance from teams that were designed to be lean and agile.
Cloud-native architecture means every service is an ICT dependency
FinTechs run on dozens of cloud services, managed databases, serverless functions, and third-party APIs. Under DORA Articles 5-16, each of these is an ICT asset that must be identified, classified, and continuously monitored. Traditional asset inventories were not designed for ephemeral infrastructure that scales by the minute.
Rapid deployment cycles clash with change management requirements
Shipping multiple times a day is a FinTech advantage - but DORA Article 9 requires documented change management processes with risk assessments. Reconciling continuous delivery pipelines with regulatory expectations for controlled, auditable changes is a real tension that most FinTechs have not yet resolved.
Small compliance teams vs. enterprise-grade regulatory expectations
DORA applies the same core requirements to a 50-person neobank as to a global institution. FinTechs rarely have dedicated compliance departments, yet supervisors expect the same quality of ICT risk frameworks, incident reporting, and third-party oversight that large banks produce with entire teams.
API-first business models create complex third-party chains
FinTechs depend on payment processors, banking-as-a-service providers, KYC vendors, card issuers, and data aggregators - all connected via APIs. DORA Article 28 requires a complete register of these ICT third-party providers, including sub-outsourcing chains that can run three or four levels deep.
Your Compliance Journey
From gap analysis to audit-ready in weeks
Gap Assessment
Connect your cloud accounts, CI/CD pipelines, and SaaS tools. Matproof automatically discovers your ICT assets, maps existing controls against all DORA requirements, and identifies gaps across Articles 5-45 - purpose-built for cloud-native architectures.
Implementation
Generate DORA-compliant ICT policies tailored to FinTech operations, build your Article 28 third-party register from your actual SaaS stack, and set up incident classification workflows. AI drafts documentation in German and English - your team reviews and approves.
Continuous Monitoring
Evidence is collected automatically from your cloud infrastructure, deployment pipelines, and security tools. ICT risk scores update in real-time as your environment changes. Third-party risk assessments trigger when vendors update terms or new APIs are integrated.
Audit-Ready
Share a read-only audit portal with BaFin or your external auditors. Every control has timestamped evidence from your actual infrastructure, every policy has version history, every incident has a complete audit trail - all generated without manual work.
Key Requirements
DORA articles that matter most for FinTechs
ICT Risk Management Framework
- ICT risk management policy approved by management body (Art. 5)
- Identification of all cloud services, APIs, and SaaS dependencies (Art. 8)
- Protection measures including CI/CD security and patch management (Art. 9)
- Detection of anomalous activities across cloud-native infrastructure (Art. 10)
- Business continuity and disaster recovery for distributed systems (Art. 11-12)
- Learning and evolving from incidents and resilience testing (Art. 13)
ICT Incident Reporting
- Incident classification using ESA criteria (Art. 18)
- Initial notification within 4 hours of classification (Art. 19)
- Intermediate report within 72 hours (Art. 19)
- Final report within one month (Art. 19)
- Voluntary notification of significant cyber threats (Art. 19)
- Root cause analysis and post-incident review (Art. 13)
Third-Party ICT Risk Management
- Complete register of cloud providers, SaaS stack, and API partners (Art. 28(3))
- Pre-contractual risk assessment for new service providers (Art. 28(4))
- Key contractual provisions including audit rights and exit strategies (Art. 30)
- Concentration risk assessment across critical cloud and BaaS providers (Art. 29)
- Sub-outsourcing chain monitoring for nested API dependencies (Art. 29)
- Annual reporting on ICT third-party arrangements to competent authority (Art. 28(3))
Why Matproof
Built for cloud-native compliance teams
Native cloud integrations (AWS, GCP, Azure)
Matproof connects directly to your cloud accounts and reads your actual infrastructure. No manual asset lists - your ICT risk register is built automatically from live cloud resources, container services, and managed databases.
API-first evidence collection from CI/CD pipelines
Pull evidence directly from GitHub, GitLab, or Bitbucket. Deployment logs, code review approvals, security scans, and change management artifacts are captured automatically - turning your existing DevOps workflow into DORA compliance evidence.
Automated Article 28 register for your entire SaaS stack
Import your vendor list or connect your expense management tool. Matproof builds the DORA-compliant third-party register, tracks contract terms, maps sub-outsourcing chains across BaaS, payment, and KYC providers, and triggers re-assessments on changes.
100% EU data residency
All data stored in European data centers. No data leaves the EU. Matproof meets the data localization requirements that financial supervisors expect - critical for FinTechs operating under BaFin, DNB, or AMF supervision.
Frequently asked questions
- Does DORA apply to FinTechs or only to traditional banks?
- DORA applies to virtually all regulated financial entities in the EU, including payment institutions, e-money institutions, investment firms, crypto-asset service providers, and account information service providers. If your FinTech holds any financial services license, DORA almost certainly applies. The scope is defined in Article 2 and covers over 20 categories of financial entities.
- How does Matproof handle cloud-native infrastructure for DORA?
- Matproof connects directly to AWS, GCP, and Azure via read-only API access. It continuously discovers your cloud resources - compute instances, managed databases, serverless functions, container clusters, and storage buckets - and maps them as ICT assets in your DORA risk register. When infrastructure changes (auto-scaling, new services deployed), the register updates automatically. This eliminates the manual asset inventory that DORA Article 8 requires.
- Can Matproof collect evidence from our CI/CD pipeline?
- Yes. Matproof integrates with GitHub, GitLab, Bitbucket, and major CI/CD platforms. It captures deployment records, pull request approvals, security scan results, and infrastructure-as-code changes as compliance evidence. This means your existing DevOps workflow produces the documented change management trail that DORA Article 9 requires - without adding manual steps to your deployment process.
- How does the Article 28 register work for API-heavy FinTechs?
- Matproof maintains a live register of all your ICT third-party service providers, including cloud providers, banking-as-a-service platforms, payment processors, KYC/AML vendors, card networks, and data aggregators. It tracks contract terms, audit rights, exit clauses, and sub-outsourcing chains - including the nested dependencies where your BaaS provider relies on another cloud provider. The register exports in the format required for annual reporting to your national competent authority.
- How long does implementation take for a FinTech?
- Most FinTechs go from kickoff to audit-ready documentation in 3-4 weeks, faster than traditional banks because cloud-native infrastructure is easier to integrate. Week 1: connect your cloud accounts, CI/CD tools, and import your vendor list. Week 2: generate policies, build the Article 28 register, set up incident workflows. Week 3-4: evidence is flowing automatically, your team reviews and refines. We provide guided onboarding with a dedicated compliance engineer.
Get your fintech DORA-ready in 4 weeks.
Book a 30-minute demo and see how Matproof maps to your cloud-native stack. We'll show you the Article 28 register, CI/CD evidence collection, and automated incident reporting.