DORA Developments Compilation – October 2024

As financial entities and ICT service providers undergo the final stages of implementation of the Digital Operational Resilience Act (DORA) requirements into their systems and processes, it is imperative to understand the legal developments and ongoing updates arising from EU Member States as they go through their respective transposition and alignment processes. Through TerraLex - our global legal network, which provides us with access to 22,000 lawyers from highly regarded and carefully vetted law firms stretching more than 120 countries – we have collated legal updates focusing on DORA and its implications in EU jurisdictions.

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Slovenia

The Ministry of Finance published a draft Regulation on the Implementation of DORA on 17 September 2024 (Regulation). The Regulation is currently under preparation within the Ministry and comments on its content were permitted until 17 October 2024. Once this phase is complete and any content adjustments have been made, we can expect to see the final version of the draft Regulation.

The Slovenian Regulation on DORA designates competent authorities, specifies reporting standards, lays down the manner in which supervision is to be carried out, the measures to be taken by the competent authorities, the remuneration to be paid for carrying out supervision, and the range of fines for minor offences.

According to the draft Regulation, the competent authorities in Slovenia are: the Bank of Slovenia, the Securities Market Agency (ATVP) and the Insurance Supervision Agency (AZN). The competent authorities can cooperate with Office for Information Security (Urad Republike Slovenije za informacijsko varnost) regarding threat-led penetration tests.

For more information, please contact Tine Mišic of ODI LLP.

Finland 

The parliamentary reply to the government's bill was submitted on 10 October 2024. The Parliament adopted the content of the government bill with some minor technical changes only.

The Finnish Financial Supervisory Authority (the FIN-FSA) is still expected to update its regulations and guidelines for greater alignment with DORA later this year, with the changes set to come into force on 17 January 2025.

In addition to the above, the FIN-FSA has published a dedicated Q&A webpage on DORA. 

For more information, please contact Johanna Heikkinen of Waselius.