DORA-Readiness

DORA

DORA level 2 map: every RTS, every ITS and the guidelines

As of 6 November 2026, there are twelve level 2 acts based on DORA: ten delegated regulations, eight of them RTS, and two implementing regulations (ITS). They are joined by two joint guidelines of the European Supervisory Authorities. The map assigns each text to a DORA chapter and states whether it applies under the full framework, under the simplified framework of Article 16 or only to supervisors and service providers.

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Last updated: 2026-11-06

What counts as level 2, and how binding is it?

Level 2 consists of the legal acts with which the Commission supplements DORA on the basis of specific empowerments in the regulation. Delegated regulations and implementing regulations apply directly, just like DORA. What RTS and ITS are and which acts matter most to most financial entities is covered in the legal overview on the page DORA regulation. This page adds the complete list with official reference, related articles and framework.

BaFin, the German financial supervisor, does not issue its own circulars specifying DORA. The reason is also given on the page DORA regulation. Alongside the regulations there are two joint guidelines of the European Supervisory Authorities (ESAs). How binding they are is answered in the questions below.

How did we check the list?

On 6 November 2026, we queried the Official Journal of the EU (Cellar database) for all legal acts based on DORA. The result is exactly the twelve acts below. We read title, date, publication and empowerment in the German official text. No amending act is recorded for DORA or the twelve acts. There are corrigenda, however, and four of them affect the German version (table further below).

All delegated and implementing regulations enter into force on the twentieth day after their publication in the Official Journal. Delegated Regulation 2024/1502 contains an exception with a later date: the lead overseer applies sub-criterion 1.4 only from 16 January 2025.

Map of the DORA level 2 texts by chapter. Chapter II ICT risk management: Delegated Regulation 2024/1774, Title II full framework, Title III simplified framework under Article 16. Chapter III incidents: Delegated Regulations 2024/1772 and 2025/301, Implementing Regulation 2025/302, both frameworks. Chapter IV testing: Delegated Regulation 2025/1190 on TLPT, only certain financial entities under the full framework. Chapter V Section I third parties: Implementing Regulation 2024/2956 and Delegated Regulation 2025/532 for both frameworks, Delegated Regulation 2024/1773 full framework only. Chapter V Section II oversight framework: Delegated Regulations 2024/1502, 2024/1505, 2025/295 and 2025/420 for supervisors and critical ICT third-party service providers. Guidelines: JC 2024 34 on costs and losses (full framework), JC/GL/2024/36 on cooperation between authorities.
Tap the graphic to open it at full size.Twelve legal acts and two guidelines by DORA chapter and framework. Source: Official Journal of the EU (Cellar query), ESA guidelines JC 2024 34 and JC/GL/2024/36, as of 6 November 2026, own illustration.

The map: all level 2 texts by DORA chapter

How to read the tables: “adopted” is the date of the act, “OJ” the date of publication in the Official Journal. “Basis” is the empowerment on which the act itself relies, as cited in its preamble. Article 20 has no numbered paragraphs, so the acts based on it cite it by position, as the third subparagraph or the fourth paragraph (the German version counts them as paragraphs 3 and 4). “KWG group” means the institutions under Section 1a(2a) of the German Banking Act (KWG), such as factoring and leasing firms. “Specifies” names the DORA articles whose obligations the act fills in. The number links to the German version on EUR-Lex, where the language can be switched.

Chapter II: ICT risk management

Legal actAdopted / OJSubjectBasis / specifiesFrameworkMore on
Delegated Regulation (EU) 2024/1774 (RTS)13 Mar 2024 / 25 Jun 2024tools, methods, processes and policies for ICT risk management, Title II (Articles 2-27), and the simplified framework, Title III (Articles 28-41)Article 15 and Article 16(3) / Articles 5-15 (Title II), Article 16(1) (Title III)Title II: full framework. Title III: Article 16ICT risk management, Article 16

Chapter III: ICT-related incidents

Legal actAdopted / OJSubjectBasis / specifiesFrameworkMore on
Delegated Regulation (EU) 2024/1772 (RTS)13 Mar 2024 / 25 Jun 2024classification of incidents and cyber threats, materiality thresholds, details of reportsArticle 18(4) / Article 18(1) and (2)both, KWG group since 17 January 2025Incident reporting
Delegated Regulation (EU) 2025/301 (RTS)23 Oct 2024 / 20 Feb 2025content and time limits of the initial notification, intermediate and final report, content of voluntary notifications of significant cyber threatsArticle 20, third subparagraph / Article 19(4), Article 20, point (a)both, KWG group since 17 January 2025Incident reporting
Implementing Regulation (EU) 2025/302 (ITS)23 Oct 2024 / 20 Feb 2025standard forms, templates and procedures for reportingArticle 20, fourth paragraph / Article 19, Article 20, point (b)both, KWG group since 17 January 2025Incident reporting

Chapter IV: Digital operational resilience testing

Legal actAdopted / OJSubjectBasis / specifiesFrameworkMore on
Delegated Regulation (EU) 2025/1190 (RTS)13 Feb 2025 / 18 Jun 2025threat-led penetration testing (TLPT): identification of financial entities, internal testers, scope, methodology, phases, cooperation between authorities, in line with the TIBER-EU frameworkArticle 26(11) / Articles 26, 27only financial entities under the full framework that the authority identifies, never Article 16 or microenterprisesResilience testing

Chapter V Section I: ICT third-party risk

Legal actAdopted / OJSubjectBasis / specifiesFrameworkMore on
Implementing Regulation (EU) 2024/2956 (ITS)29 Nov 2024 / 2 Dec 2024standard templates for the register of informationArticle 28(9) / Article 28(3)both, not for microenterprises of the KWG groupRegister of information
Delegated Regulation (EU) 2024/1773 (RTS)13 Mar 2024 / 25 Jun 2024content of the policy on contractual arrangements for ICT services supporting critical or important functionsArticle 28(10) / Article 28(2)full framework only, without microenterprises, because Article 28(2) does not apply otherwiseICT third-party risk
Delegated Regulation (EU) 2025/532 (RTS)24 Mar 2025 / 2 Jul 2025subcontracting of ICT services supporting critical or important functionsArticle 30(5) / Article 30(2)(a)both, not for microenterprises of the KWG groupICT third-party risk

Chapter V Section II: Oversight framework for critical ICT third-party service providers

Legal actAdopted / OJSubjectBasis / specifiesFrameworkMore on
Delegated Regulation (EU) 2024/150222 Feb 2024 / 30 May 2024criteria for designating ICT third-party service providers as critical: systemic impact, importance of the clients, critical or important functions, substitutability, sources of informationArticle 31(6) / Article 31(2)addressed to the ESAs as overseersDORA for ICT providers
Delegated Regulation (EU) 2024/150522 Feb 2024 / 30 May 2024amount and payment of the oversight fees of critical ICT third-party service providersArticle 43(2) / Article 43(1)critical ICT third-party service providers and the lead overseerDORA for ICT providers
Delegated Regulation (EU) 2025/295 (RTS)24 Oct 2024 / 13 Feb 2025application for voluntary designation as critical, information from critical providers to the overseer, template for subcontracting arrangements, assessment of remediation measuresArticle 41(2) / Article 41(1)(a), (b), (d)ICT third-party service providers and authoritiesDORA for ICT providers
Delegated Regulation (EU) 2025/420 (RTS)16 Dec 2024 / 24 Mar 2025composition, tasks and working arrangements of the joint examination team of ESAs and national authoritiesArticle 41(2) / Article 41(1)(c)authorities onlyDORA for ICT providers

Joint guidelines of the ESAs

GuidelineAdopted / applies fromSubjectBasisFrameworkMore on
JC 2024 34applies from 19 May 2025estimation of the aggregated annual costs and losses caused by major ICT-related incidents, reported at the authority’s requestArticle 11(11) / Article 11(10)full framework without microenterprises, no such report foreseen under the Article 16 frameworkIncident reporting
JC/GL/2024/366 Nov 2024 / 17 Jan 2025cooperation and information exchange between the ESAs and national authorities in the oversight frameworkArticle 32(7)authorities onlyDORA for ICT providers

According to the ESAs’ compliance table, BaFin applies guideline JC 2024 34. On 6 November 2026, we did not find a separate list of adopted guidelines on BaFin’s website.

Which corrigenda affect the German text?

A corrigendum corrects the wording of one or more language versions and applies as if the text had been correct from the start. As with the column codes of the register of information, this can change what institutions submit. Anyone working with an older copy or an early extract reads the wrong wording. The Official Journal lists these four corrigenda for the German version:

Corrigendum ofLegal actProvisionWhat changes
19 Dec 2024DORAArticle 6(8)(h)The communication strategy relates to ICT-related incidents that must be disclosed under Article 14. Before, the German sentence read as if the strategy itself had to be disclosed.
15 May 2025Delegated Regulation 2024/1774Article 22, first subparagraph, point (d)Retention of evidence on incidents refers to Article 8(2) of Delegated Regulation 2024/1772 instead of its Article 15 (all language versions).
3 Jul 2025Delegated Regulation 2025/1190Article 9(6)“Testmanagern” (test managers) instead of “Testleitern” (test leads) in the German text.
19 Sep 2025Implementing Regulation 2024/2956Annex I, templates B_05.01, B_06.01, B_07.01The type of code for the provider is given directly (LEI, EUID, CRN, VAT, PNR, NIN) instead of as a country code with an underscore. The column codes of the function template B_06.01 from the criticality assessment onwards move up by one number (B_06.01.0050 to 0100 instead of 0060 to 0110). Plus two minor corrections (all language versions).

Other corrigenda only affect other language versions, for example the French version of the reporting regulations 2025/301 and 2025/302.

Example: Muster-Factoring GmbH filters the map

Fictitious example, not a client. Muster-Factoring GmbH (23 staff, EUR 61 million total assets) applies the simplified framework under Article 16 from 1 January 2027, and incident reporting since 17 January 2025 (Section 1a(2a) in conjunction with Section 65a(3) KWG). For its register of applicable rules, the compliance officer goes through the map row by row:

Legal actResult for Muster-Factoring GmbHFrom
2024/1774apply Title III (Articles 28-41), not Title II1 Jan 2027
2024/1772, 2025/301, 2025/302apply. Whether Article 8(2) of Delegated Regulation 2024/1772 applies to the KWG group is an open question, explained on the page Incident reportingsince 17 Jan 2025
2024/2956, 2025/532apply, because the institution is not a microenterprise1 Jan 2027
2024/1773do not apply, Article 28(2) does not apply under the Article 16 framework-
2025/1190do not apply, no TLPT under the Article 16 framework-
2024/1502, 2024/1505, 2025/295, 2025/420, JC/GL/2024/36no obligations of its own, for information on the oversight framework only-
JC 2024 34do not apply, no report of costs and losses foreseen under the Article 16 framework-

The result is six legal acts with official reference, status and corrigenda in the register of applicable rules. For the internal policies, the compliance officer decides that they will only cite the version published in the Official Journal from now on. Which obligations follow in detail is shown in the obligations matrix and on the page on Article 16.

Three typical gaps in handling level 2

GapCauseEffectRemedy
Draft cited instead of Official JournalMany implementation projects started in 2023 and 2024 with the ESAs’ final reports, before the Commission had adopted the acts.Policies refer to draft numbers. Places where the adopted version differs go unnoticed.Switch all references to the Official Journal version with number and date, and read the affected sections once against the adopted text.
Corrigenda not followed upCorrigenda appear as separate documents in the Official Journal and are missed when the texts are filed only once.Completion guides and policies work with outdated wording, for example with the old column codes of the function template B_06.01 in the register of information.Record for each act in the register of applicable rules whether corrigenda exist, and check the status at every review of the register (our recommendation).
Oversight acts read as a source of obligationsAll twelve acts supplement DORA, but they are addressed to different parties.Financial entities or providers build processes for fees, examination teams or designation criteria that are aimed at the supervisors or at providers designated as critical.Note the addressee for each act. Only the supervisors designate a provider as critical.

How we help

We compare your policies and evidence with the level 2 texts that apply to your framework and record reference and status. The starting point is the DORA gap analysis. Institutions of the KWG group moving from BAIT to the simplified framework on 1 January 2027 find the matching service in our transition from BAIT.

Frequently asked questions

Which version do we cite in internal policies?+
The version published in the Official Journal with number, date and OJ reference, and for corrected acts also the corrigendum with its date. Consolidated versions on EUR-Lex are a reading aid, only the text in the Official Journal is binding. For the four corrigenda to the German version, see the table above.
What is the difference between an RTS and a delegated regulation?+
Every RTS is adopted as a delegated regulation, but not every delegated regulation is an RTS. The Commission adopted Regulations 2024/1502 (designation criteria) and 2024/1505 (oversight fees) as delegated acts in their own right under Article 31(6) and Article 43(2) DORA. These empowerments do not provide for draft regulatory technical standards. For application, it makes no difference, both apply directly.
Does Delegated Regulation 2024/1774 apply in full to institutions under Article 16?+
No. Title III with Articles 28 to 41 applies to them. Title II with Articles 2 to 27 specifies the full framework of Articles 5 to 15 DORA, which Article 16 institutions do not apply. What Title III requires article by article is set out in the evidence matrix on the page on Article 16.
Are the ESA guidelines binding on us?+
Guidelines are not regulations. Under Article 16(3) of the ESA regulations, authorities and financial entities make every effort to comply with them, and the authorities report whether they apply them. For guideline JC 2024 34, the compliance table reports that BaFin applies it. How this affects an individual case is a question for your legal counsel.
Where can I find the official texts?+
On EUR-Lex under the CELEX number, which is formed from year and number, for example 32024R1774 for Delegated Regulation 2024/1774. The links in the map lead there directly, to the German version. The version published in the Official Journal is binding, and corrigenda are linked to the act on EUR-Lex.

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Sources

This content provides general technical and organisational information and does not constitute legal advice (no legal services within the meaning of the German RDG).