Description

A focused course, tailored for you

DORA ICT Controls for Insurance Security Officers

DORA implementation for insurance ISOs: function classification, ICT register, and multi-framework incident reporting.

The ICT third-party register has been to risk committee twice and still has open classification items. The question is always the same: which insurance business functions qualify as critical versus important under DORA, and does the classification hold up when ACPR examiners arrive with the DORA technical standards in hand?

$199 one-time

Tailored to your situation. Access within 24 hours. 30-day money-back.

Includes a hand-built implementation playbook delivered alongside course access, generated for your specific situation.

Why this course

DORA was drafted with banks in mind. The EBA technical standards and the RTS on ICT risk management read as banking documents. For an insurance entity, the classification exercise requires deliberate mapping work: underwriting systems, claims adjudication platforms, actuarial engines, and policy administration infrastructure all need to be assessed against criteria written for banking business functions. Every ambiguous classification carries regulatory risk because an ACPR examination will test the rationale, not just the conclusion. The situation compounds when the insurance entity operates within a banking group, because the group-level DORA framework inherits banking assumptions that do not translate cleanly to insurance supervisory requirements. An ISO caught between the group security framework and the entity's own ACPR relationship has to document the adaptation explicitly, or the examination will find it.

What you walk away with

Build and maintain the DORA ICT third-party register with documented classification rationale that satisfies ACPR examination requirements.
Apply the critical versus important function classification to insurance-specific business processes with supporting documentation.
Design an incident reporting workflow that handles DORA, GDPR, and Solvency II notifications in a single integrated procedure.
Map DORA ICT continuity requirements to the existing Solvency II BCM framework without duplicating documentation effort.
Structure the DORA testing programme to satisfy regulatory requirements and build an examination evidence file.
Own the DORA governance calendar as ISO, integrating it with the Solvency II annual cycle and the group information security audit programme.

The 12 modules

Module 1. The DORA Framework as an Insurance Entity Understands It

DORA applies to financial entities including insurance companies and reinsurers. This module maps the DORA obligations relevant to the ISO role at an insurance entity: ICT risk management, incident reporting, digital operational resilience testing, and ICT third-party risk. It covers how the EIOPA supervisory guidance supplements the EBA technical standards, which obligations apply immediately versus on a phased basis, and where insurance-specific clarifications and derogations exist in the implementing regulation.

Module 2. Classifying Critical and Important Functions for Insurance

The DORA classification exercise determines which ICT services require full third-party oversight. For an insurance entity, this means applying classification criteria to underwriting systems, claims adjudication platforms, actuarial tools, policy administration infrastructure, and customer portal services. This module provides the decision framework for classification, the documentation required to support each decision, and how to handle ambiguous functions where insurance and banking classification guidance diverge.

Module 3. Building the ICT Third-Party Service Provider Register

DORA Article 28(3) requires a register of all ICT service providers with specific data fields per provider. This module covers the required register structure, how to gather and validate information from procurement and business teams, how to flag critical and important function providers for enhanced oversight, and how to maintain the register through annual review cycles and provider changes without creating a manual maintenance burden.

Module 4. Auditing Supplier Contracts Against DORA Requirements

DORA prescribes minimum contractual provisions for ICT service agreements supporting critical or important functions. This module covers the required contract clauses, how to conduct a gap assessment against your existing supplier portfolio, how to prioritise remediation conversations with critical providers, and how to structure the contract review cycle to maintain ongoing compliance without renegotiating every agreement simultaneously.

Module 5. ICT Risk Assessment for Insurance Business Functions

The ICT risk assessment for an insurance entity must cover the asset inventory, threat scenarios relevant to insurance operations, and the cascade effects of ICT failures on insurance obligations including claims payment cycles, policy renewal windows, and regulatory reporting deadlines. This module provides the assessment methodology, the insurance-specific threat scenarios to model, and the documentation format that satisfies both the DORA ICT risk framework and the ACPR examination cycle.

Module 6. Incident Classification Across DORA, GDPR, and Solvency II

DORA's major ICT incident classification thresholds use criteria including number of affected clients, financial impact, and duration of service outage. For an insurance entity, these interact with GDPR's 72-hour breach notification and Solvency II's own significant event reporting requirements. This module builds the classification decision tree that handles all three frameworks in one triage procedure, identifies which regulator receives notification first, and documents the evidence trail for each.

Module 7. ICT Continuity and Solvency II BCM Alignment

DORA requires documented ICT business continuity plans covering recovery objectives for critical and important functions. For an insurance entity, those recovery objectives must align with Solvency II's Business Continuity Management requirements, especially for claims payment systems and policyholder data access. This module maps DORA continuity requirements onto the existing Solvency II BCM framework, identifying gaps and alignment points to avoid duplicating documentation across both regulatory programmes.

Module 8. Operating as an Insurance Subsidiary Within a Banking Group

Insurance subsidiaries within banking groups face a structural challenge: the parent bank's group-level DORA framework was built for banking business functions and banking regulators. The insurance entity must adapt that framework to its own regulatory relationship with the insurance supervisor while demonstrating alignment with group standards. This module covers the adaptation methodology, how to document the insurance-specific implementation, and how to communicate the differences to group-level auditors and examiners.

Module 9. DORA and Solvency II Pillar 2 Integration

Solvency II Pillar 2 requires ICT risk to be assessed and reported in the Own Risk and Solvency Assessment. DORA creates parallel ICT risk governance obligations. This module covers how to present DORA ICT risk findings in the ORSA, how to use the DORA ICT risk assessment as the evidence base for Solvency II operational risk capital considerations, and how to run a single assessment process that feeds both regulatory frameworks without duplicating effort.

Module 10. Digital Operational Resilience Testing for Insurance Entities

DORA Chapter IV requires financial entities to test ICT systems through vulnerability assessments, penetration tests, and for significant entities, Threat-Led Penetration Testing. This module covers the testing obligations relevant to an insurance entity, how to scope testing against the classified critical and important function inventory, how to manage findings through to remediation, and how to build the testing evidence file that satisfies both DORA requirements and ACPR examination requests.

Module 11. ACPR Examination Readiness for DORA Implementation

The ACPR examines French insurance entities on DORA compliance through on-site inspections and documentary reviews. Examiners request the ICT register, incident logs, contractual gap assessments, and testing results. This module covers what ACPR examiners look for, how to structure the DORA evidence file, how to brief senior management before an inspection, and how to manage the finding response process from initial observation through to formal closure.

Module 12. The ISO's DORA Governance Calendar and Ongoing Compliance

DORA compliance is not a one-time implementation exercise. The ICT register must be maintained, incident simulations conducted annually, third-party contract reviews completed on cycle, and testing programmes refreshed regularly. This module builds the ISO's DORA governance calendar, integrating DORA obligations with the Solvency II annual cycle, the ACPR reporting calendar, and the group information security audit programme, so the ISO owns ongoing compliance without duplicating effort across frameworks.

How this addresses your situation

Specific modules that map to what you said you are dealing with.

ICT register has open classification items after risk committee review: Modules 2 and 3

Incident matrix misaligned between DORA four-hour notification and Solvency II reporting requirements: Module 6

Group-level DORA framework does not map cleanly onto insurance business functions: Modules 8 and 9

ACPR examination cycle approaching with no consolidated evidence file: Module 11

What you get with this course

12 written modules covering the full DORA implementation lifecycle for insurance entities, from function classification through examination readiness
Downloadable ICT third-party register template pre-structured for DORA Article 28(3) requirements
Incident classification decision-tree template aligned across DORA, GDPR, and Solvency II
ACPR examination evidence file structure template with section-by-section guidance
Hand-built implementation playbook scoped to insurance entity DORA requirements, delivered alongside course access

What you will have in hand by Day 1, Week 1, Month 1

Within 24 hours your account in the learning environment is provisioned and the tailored implementation playbook is delivered alongside it.

Before and after

Before

The ICT register has open classification items from the last risk committee review, the incident threshold matrix is misaligned between DORA and Solvency II, and the ACPR examination cycle is approaching with no consolidated evidence file.

After

The ICT third-party register is classified, documented, and examination-ready. Incident reporting runs on one integrated procedure across DORA, GDPR, and Solvency II. The ACPR evidence file is structured and owned by the ISO.

What happens if you do not address this

The ACPR has begun supervisory reviews of DORA implementation for insurance entities. An ISO who cannot produce a classified ICT register with documented rationale, or whose incident classification matrix has not been aligned across DORA and Solvency II, faces direct findings in the examination report, remediation orders, and escalation to senior management.

Who it is for

Information Security Officers at insurance entities with direct ACPR supervisory relationships, particularly those operating within banking groups where the group-level DORA framework needs insurance-specific adaptation. The audience has working knowledge of information security principles and has engaged with either Solvency II operational risk requirements, DORA obligations, or both. They are currently working through the ICT third-party register, incident classification matrix, or both, and are preparing for ACPR examination readiness.

Who this is NOT for. This course is not for information security generalists without regulatory exposure. It assumes familiarity with the ISO role in a regulated financial entity and working knowledge of either Solvency II, DORA, or NIS2. It does not teach foundational information security concepts.

How it arrives

Text-based course in the Art of Service learning environment, plus downloadable templates and worked examples for every module, plus the hand-built implementation playbook delivered alongside course access.

Time investment. Approximately three hours of reading per week over four weeks, plus hands-on work time applying each module's templates to your entity's ICT register and control documentation.

Why $199 is the right number

Working through EIOPA and EBA guidance documents independently and mapping them to your entity's existing ICT risk framework is possible but typically takes several months and produces classifications that get revisited at every risk committee cycle. The course compresses that into a structured methodology with insurance-specific worked examples.

FAQ

Does this course cover NIS2 alongside DORA?

Yes. Module 2 covers the overlap between DORA's critical function classification and NIS2's essential service designation for financial entities, and Module 6 covers how to handle the different incident reporting timelines across both frameworks.

Our DORA requirements were implemented at group level by the parent bank. Does this course still apply?

Yes. The course specifically addresses operating as an insurance subsidiary within a banking group: implementing DORA controls that align with the group framework while maintaining the insurance entity's own regulatory relationship with the insurance supervisor. Module 8 covers this directly.

Does the course cover ACPR examination practices specifically, or only the DORA text itself?

Both. Modules 1 through 10 are framework-grounded. Module 11 is specifically about ACPR examination readiness: what examiners request, how to structure the evidence file, and how to manage the finding response process through to closure.

30-day money-back guarantee. If after a week of working through the materials this is not what you needed, reply to the receipt email and a full refund is processed. No questions, no forms.

Within 24 hours your account in the learning environment is provisioned and the tailored implementation playbook is delivered alongside it.