While DORA enforcement for credit unions begins in 2028, the Central Bank of Ireland’s (CBI) 2025/2026 supervisory agenda has already identified critical gaps in the credit union sector. Our Resilience Hub is built specifically to address the findings from the CBI's latest Thematic Review of IT Risk.
The DORA Resource Hub aligns with the EU’s broader digital finance strategy and complements existing Central Bank of Ireland guidance on ICT risk, outsourcing, and operational resilience. It is designed to help credit unions transition from exemption to full compliance in a structured, evidence-based manner and evidence CBI IT Risk Remediation.
This hub provides Irish credit unions with authoritative guidance, tools, and structured support and independent validation to achieve compliance with the Digital Operational Resilience Act (DORA) by January 2028. It outlines the regulatory context, board-level responsibilities, and practical steps to embed DORA-aligned governance and controls within the credit union.
For credit unions, DORA isn't about building a bank-sized compliance department; it's about rightsizing your existing ICT controls to match your risk profile.
The Digital Operational Resilience Act (DORA) represents a major development in EU financial regulation, establishing a harmonised and directly applicable framework governing ICT risk management, ICT-related incident reporting, digital operational resilience testing, ICT third-party risk management, and cyber-related information-sharing arrangements across the financial sector.
Although DORA became fully applicable to most EU financial entities on 17 January 2025, Irish credit unions benefit from a national exemption period granted under Article 2(4) of DORA until January 2028. This exemption period provides boards with critical time to prepare for compliance in a structured and proportionate manner, while ensuring that governance, risk management, and operational resilience arrangements are capable of meeting DORA’s standards once the exemption expires.
The purpose of this Resource Hub is to assist boards, senior management, and compliance functions in understanding the regulatory expectations arising under DORA and in translating those expectations into practical, board-led, and evidence-based governance outcomes.
Relying on IT vendors to "audit themselves" (marking their own homework).
Independent Assurance: Impartial, third-party validation of your ICT controls.
IT reporting is too technical or vague, preventing meaningful Board "challenge."
Board-Ready Reporting: Translating complex ICT data into defensible governance artifacts.
Business Continuity Plans (BCPs) that aren't tested against "Plausible High-Impact" scenarios.
Resilience Drills: Scenario-based testing that proves you can recover from a total vendor loss.
Incomplete registers and a lack of documented Exit Strategies for critical providers.
TPRM Framework: Full DORA-aligned Register of Information and vendor exit playbooks.
Safeguarding the Management Body. We install the governance frameworks necessary to bridge the gap between regulatory requirements and operational execution. By defining clear lines of responsibility and remediation, we ensure that your institutional oversight is both demonstrable and defensible, protecting leadership from personal liability.
Single-Point Orchestration of Internal & Vendor Teams. We establish the command protocols that govern your entire IT ecosystem, including third-party service providers. We act as the Lead Architect, enforcing a unified blueprint that ensures every resource—from internal engineering to Tier-1 vendors—operates under a single, Board-validated standard.
Board-to-Floor Crisis Alignment. Technical resilience fails without human synchronization. We embed crisis response protocols that ensure the chain of command remains unbroken under pressure. By optimizing the "Human Response Network," we ensure that leadership decisions are translated into immediate, effective technical action during systemic failures.
Reputation Protection & Information Governance. We orchestrate the disclosure strategies and industry-wide communication required during systemic events. By managing the flow of intelligence to regulators and market participants, we protect your firm’s market reputation and ensure that all reporting reflects a state of controlled, professional stability.
Closing the Loop on Evidence. We serve as the strategic lead for regulatory verification and audit defense. Rather than passive compliance, we orchestrate the protocols for proactive "Proof of Life" testing and forensic validation of controls. We ensure that when the regulator arrives, the evidence of your resilience is irrefutable and the governance cycle is complete.
During the transition period, credit unions are expected to strengthen ICT governance arrangements, review and update ICT and outsourcing contracts, and ensure that incident management and operational resilience frameworks can respond effectively to ICT disruptions and cyber threats.
By January 2028, boards will be required to demonstrate to the Central Bank of Ireland that their credit union has in place:
While the exemption delays the point of formal enforcement, it does not remove supervisory expectations. The Central Bank of Ireland has consistently emphasised that firms should align with the spirit and direction of DORA, as well as with existing guidance on ICT risk management, outsourcing, and operational resilience.
Boards should apply DORA’s requirements in a proportionate manner, reflecting the size, complexity, and risk profile of their credit union, while ensuring that all core resilience principles are met.
The Central Bank of Ireland’s Cross-Industry Guidance on Operational Resilience aligns supervisory expectations with DORA and encourages firms not yet directly subject to DORA to adopt equivalent measures as part of their operational resilience frameworks. In practice, supervisory focus is increasingly placed on demonstrable capability, including governance records, testing outcomes, third-party oversight artifacts, and board-level assurance, rather than policy intent alone.
DORA as a Governance and Resilience Framework.
DORA is structured around five core pillars:
Taken together, these pillars establish a comprehensive regulatory framework designed to ensure that financial entities can withstand, respond to, and recover from ICT disruptions and cyber incidents.
For Irish credit unions, this requires a careful review of internal governance structures, enhanced oversight of external ICT and outsourcing providers, and preparation for expanded documentation, reporting, testing, and contractual requirements. Importantly, Boards must be able to evidence oversight, challenge, and assurance through clear decision-making records, structured reporting, and regulator-ready artefacts.
Credit unions are encouraged to participate in sectoral information-sharing initiatives and collaborative testing exercises to strengthen collective resilience and align with DORA’s emphasis on cross-sector cooperation.
Strategic Importance of Early Engagement and Independent Validation (CBI requirement).
In this context, early and proportionate engagement with DORA during the transition period enables boards to enhance institutional resilience, reduce future regulatory and remediation risk, and ensure that compliance obligations are met in a controlled and defensible manner.
Approaching DORA as a governance and resilience framework, rather than as a late-stage compliance exercise, supports:
Our Flagship Programme.
To support credit unions in moving from regulatory interpretation to practical implementation, Tymans Group delivers a dedicated flagship readiness programme, the DORA Evidence Pack.
It is a 12-week program led by the board that helps boards and senior management get ready for DORA compliance by January 2028, while also creating clear evidence that meets the Central Bank of Ireland's expectations for digital operational resilience.
This program ensures you meet the Central Bank's current 'Cross-Industry Guidance on Operational Resilience' and addresses the immediate CBI 2025/2026 concerns while simultaneously building the foundation for the 2028 DORA deadline via independent validation.
By the conclusion of the engagement, the credit union will have:
The engagement produces a defined suite of inspectable artifacts, including:
How Tymans Group Supports Credit Unions.
Tymans Group works alongside boards and senior management teams to translate complex regulatory requirements into defensible governance structures, workable controls, and board-ready evidence.
Our approach combines regulatory insight with practical implementation support, ensuring that compliance is not only achieved but is also capable of being clearly demonstrated to supervisors.
We explicitly provide:
Does your current framework address the CBI’s findings on independent validation?
Then let's discuss how your board can adopt a structured, compliant, and legally informed approach to DORA during the transition period.
We welcome the opportunity to deliver a DORA executive or board briefing and to outline how the DORA evidence pack can be integrated into your governance framework ahead of January 2028.
Engaging early with structured readiness programmes such as the DORA Evidence Pack will position your credit union as a leader in operational resilience and regulatory preparedness.
This intake requires the input of a management body member or CxO. Please provide the institutional context required to initiate a Resilience Diagnostic and determine architectural alignment.
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