Article 19 Digital Operational Resilience Act (DORA), Centralisation of Reporting of Major ICT-Related Incidents

The concept of centralizing ICT incident reporting through a single EU Hub represents a significant step towards enhancing the efficiency, consistency, and effectiveness of incident management across the European financial sector. The European Supervisory Authorities (ESAs), in collaboration with the European Central Bank (ECB) and the European Union Agency for Cybersecurity (ENISA), have been tasked with evaluating the feasibility of this initiative. This joint report aims to provide a comprehensive analysis of the potential for establishing such a centralized reporting mechanism, highlighting the prerequisites, benefits, limitations, risks, and operational aspects involved.

Preparation Of The Joint Report

Objective

The primary objective of this report is to assess the feasibility of further centralizing ICT incident reporting by creating a single EU Hub. This centralized hub would serve as a unified platform for financial entities to report major ICT-related incidents, streamlining the reporting process, reducing associated costs, and enhancing supervisory convergence through thematic analyses.

Collaboration

The preparation of this joint report involves extensive collaboration between the ESAs, the ECB, and ENISA. This collaborative effort ensures that the report benefits from a wide range of expertise and perspectives, covering all relevant aspects of ICT incident reporting and management.

Contents Of The Report

Prerequisites

• Regulatory Framework: Establishing a centralized EU Hub requires a robust regulatory framework that defines the legal basis for its operation, governance structure, and reporting obligations.

• Technological Infrastructure: The hub must be supported by advanced technological infrastructure capable of handling large volumes of data securely and efficiently.

• Interoperability: Ensuring interoperability with existing national reporting systems is crucial to facilitate seamless integration and data exchange.

• Data Privacy and Security: Strong measures must be in place to protect the confidentiality, integrity, and availability of reported data.

Benefits, Limitations, and Risks

• Benefits:

• Streamlined Reporting: A centralized hub would simplify the reporting process for financial entities, reducing the administrative burden and ensuring consistency in the data reported.

• Cost Reduction: Centralizing reporting can lead to economies of scale, reducing the overall costs associated with ICT incident reporting.

• Enhanced Supervisory Convergence: Thematic analyses and centralized data collection would facilitate a more coordinated supervisory approach across the EU.

• Improved Incident Management: Centralization would enable quicker identification of systemic risks and facilitate more effective incident response and management.

• Limitations:

• Initial Setup Costs: Establishing the hub would require significant initial investment in technology and infrastructure.

• Resistance to Change: Financial entities and national authorities may resist transitioning from established national systems to a centralized EU Hub.

• Complex Governance: Ensuring effective governance and management of the hub across multiple jurisdictions can be challenging.

• Risks:

• Data Security: Centralizing sensitive incident data increases the risk of cyberattacks and data breaches.

• Operational Risks: Any disruptions in the hub’s operations could impact the entire reporting ecosystem.

• Compliance Risks: Ensuring all financial entities comply with the new centralized reporting requirements may be challenging.

Operational Management

• Governance Structure: Define a clear governance structure with roles and responsibilities for managing the EU Hub.

• Operational Procedures: Establish detailed operational procedures for the day-to-day management of the hub.

• Incident Handling: Develop protocols for handling and responding to incidents reported through the hub.

Membership Conditions

• Eligibility Criteria: Define the criteria for financial entities to become members of the EU Hub.

• Registration Process: Establish a streamlined process for entities to register and gain access to the hub.

Access Modalities

• Access Procedures: Define the procedures for financial entities and national competent authorities to access the EU Hub.

• Data Sharing Protocols: Develop protocols for sharing data between the hub and national authorities.

Cost Assessment

• Initial Investment: Conduct a preliminary evaluation of the financial costs for setting up the hub, including infrastructure, technology, and expertise.

• Operational Costs: Assess the ongoing costs of maintaining the hub, including staffing, technology upgrades, and security measures.

• Cost-Benefit Analysis: Compare the costs with the potential benefits of a centralized reporting system.

Submission Of The Report

The ESAs will deliver the joint report to the European Parliament, the Council, and the Commission by [insert date, three years after the date of entry into force]. This timeline ensures that there is sufficient time to conduct a thorough analysis and gather input from all relevant stakeholders.

The feasibility report on centralizing ICT incident reporting aims to provide a detailed evaluation of the potential for creating a single EU Hub. This initiative represents a significant opportunity to enhance the efficiency and effectiveness of ICT incident management across the European financial sector. By addressing the prerequisites, benefits, limitations, risks, and operational aspects, the report will provide valuable insights into the feasibility and potential impact of this ambitious project.