IriusRisk Team
The Threat Modeling Experts
February 22, 2024

Threat Modeling: Aligning with DORA's Vision for Digital Operational Resilience

What is DORA, and how does it relate to threat modeling?

In an era where digital threats are evolving at an unprecedented pace, the European Union's Digital Operational Resilience Act (DORA) represents a critical step towards fortifying the operational resilience of entities operating within the financial sector. Although DORA does not explicitly mandate the adoption of threat modeling, it emphasizes comprehensive risk management practices aimed at enhancing the digital resilience of financial entities. This article delves into the synergy between threat modeling and DORA's requirements, highlighting how the former serves as an instrumental strategy in achieving compliance and bolstering digital operational resilience.

Understanding DORA's Core Objectives

DORA aims to ensure that the financial sector's digital infrastructure is robust enough to withstand all types of cyber threats and operational challenges. It encompasses a broad spectrum of risk management requirements, including ICT risk management, incident reporting, digital operational resilience testing, and third-party risk management. These components are designed to create a more secure, resilient financial ecosystem capable of sustaining operational continuity even in the face of sophisticated cyber threats.

The Role of Threat Modeling in DORA Compliance

Threat modeling, a foundational element of secure system design, involves identifying, assessing, and addressing potential threats in the early stages of system development. This proactive approach aligns seamlessly with DORA's risk management framework by offering several key benefits:

1. Early Identification of Vulnerabilities: By systematically identifying potential threats and vulnerabilities before system implementation, threat modeling enables organizations to preemptively address weaknesses that could be exploited in cyber attacks, thereby aligning with DORA's emphasis on ICT risk management.

2. Enhanced Incident Response Preparedness: DORA requires entities to have robust incident response and management capabilities. Threat modeling facilitates the development of detailed incident response strategies by providing insights into the most likely attack vectors and potential impact of different types of cyber incidents.

3. Informed Digital Operational Resilience Testing: DORA advocates for comprehensive testing of digital operational resilience. Through threat modeling, organizations can design more effective testing scenarios that simulate realistic threat scenarios, ensuring that resilience testing is both targeted and meaningful.

4. Effective Third-Party Risk Management: With the increasing reliance on third-party service providers, DORA mandates strict management of third-party risks. Threat modeling extends to evaluating the risks associated with third-party components, ensuring that external services do not introduce unacceptable vulnerabilities.

5. Continuous Risk Management Process: DORA promotes a continuous approach to risk management. Threat modeling, by its nature, is an iterative process that evolves with the system's design, ensuring that risk assessments are updated in line with new threats, technologies, and changes in the operational environment.

Leveraging Threat Modeling for DORA Compliance

To effectively leverage threat modeling in the context of DORA compliance, organizations should:

- Integrate Threat Modeling into the System Development Life Cycle (SDLC): Embed threat modeling practices at the early stages of system design and throughout the SDLC to continuously identify and mitigate risks.

- Adopt a Structured Framework: Utilize established threat modeling methodologies, such as STRIDE or PASTA, to systematically identify, assess, and address threats in a manner that aligns with DORA's risk management objectives.

- Foster Cross-Functional Collaboration: Encourage collaboration between developers, security engineers, and operational teams to ensure a holistic understanding of potential threats and more effective risk mitigation strategies.

- Document and Review Threat Modeling Outputs: Maintain comprehensive documentation of threat modeling activities, findings, and remediation actions to demonstrate compliance with DORA's risk management and resilience testing requirements.


While DORA may not explicitly require threat modeling, it is clear that the practice offers significant value in navigating the regulation's comprehensive risk management and resilience testing requirements. By adopting threat modeling, organizations can not only enhance their compliance posture but also significantly improve their operational resilience against the backdrop of an increasingly hostile digital landscape. In essence, threat modeling does not just facilitate compliance with DORA—it empowers organizations to proactively safeguard their digital operational resilience, ensuring continuity and security in the digital age.