One of DORA’s core focus areas is the management of outsourcing arrangements. Many compliance and IT functions are already delegated to third-party providers, and DORA significantly raises the bar for such models. Requirements around contractual obligations, risk assessments, exit strategies, and audit rights have become substantially more stringent. As a result, many institutions must now review and adapt their existing outsourcing frameworks to remain compliant and audit-ready.

Stricter Requirements, Growing Challenges
DORA introduces several new obligations for financial institutions, including the maintenance of a detailed register of ICT-related outsourcing arrangements. In addition, all ICT third-party providers must be continuously monitored and integrated into the firm’s overarching risk management systems. Contracts must meet specific minimum requirements, including explicit audit rights and defined exit strategies.

The complexity is particularly high for institutions that outsource multiple key functions – such as compliance, anti-money laundering (AML), or information security. For small and medium-sized firms in particular, building a fully DORA-compliant in-house structure is often not economically viable. This is where specialized outsourcing solutions offer an effective alternative.

“DORA is reshaping regulatory practice, especially in how outsourcing contracts, risk assessments, and supervisory control rights must be structured,” explains Achim Schulz, Managing Director at S+P Compliance Services. “Our model enables financial institutions to respond quickly, efficiently, and in full compliance – without having to build internal capacity.”

DORA-Ready with the S+P Compliance Package
S+P Compliance Services offers a fully documented and DORA-compliant outsourcing solution through its S+P Compliance Package. The service covers key regulatory roles, including:

• Compliance Officer
• Money Laundering Reporting Officer (MLRO)
• Outsourcing Management
• Internal Audit

All services are certified according to ISO 27001, ISO 9001, IDW PS 951, and ISAE 3402, with an additional ESG rating – offering strong assurance for institutions facing increased governance expectations.

One key advantage: the solution is immediately deployable and fully audit-proof. Contracts and service descriptions are already designed to meet DORA’s requirements for supervisory access, contract terms, and exit procedures.

Practical Implementation: How DORA-Compliant Outsourcing Works
Implementation follows a structured process. First, S+P assesses the institution’s regulatory classification and risk profile. Based on this, a tailored proposal is developed covering all required functions. Once the agreement is signed, operations can begin within just a few days.

S+P supports not only the onboarding but also the internal documentation and, if needed, the regulatory outsourcing notification to BaFin. This end-to-end approach ensures rapid execution with a high level of legal certainty. The processes are built to withstand both standard and DORA-specific audits.

For a deeper look into practical implementation, see:
“Mastering DORA Compliance – How to Get Started”

Why Now Is the Time to Act
DORA is no longer a future obligation – it is binding law. This means institutions must already be in a position to fully comply with ICT outsourcing regulations and prove it to supervisors. At the same time, expectations around the governance capability of executive management are rising – including the responsibility to select, monitor, and control external service providers effectively.

Outsourcing central functions in a DORA-compliant manner is not only efficient, it is strategically sound. It relieves internal teams, reduces liability risks, and strengthens digital resilience.

With a modular approach and proven expertise in regulatory implementation, S+P offers a solution that is both efficient and future-proof. For more on S+P’s DORA readiness, visit:
“DORA-ready with S+P” and
“DORA Requirements in Focus”

Conclusion
DORA marks the beginning of a new era in regulatory governance. Financial institutions outsourcing key functions such as compliance, AML, or information security must now ensure these arrangements are fully DORA-compliant and audit-ready.

Solutions like the S+P Compliance Package provide a practical, certified framework that meets these new standards. Institutions that act now will not only ensure compliance – they will strengthen their operational resilience and be better prepared for future supervisory scrutiny.

“DORA is not just another regulation – it’s an invitation to professionalize governance,” says Achim Schulz. “Outsourced functions must now meet the same standards as internal roles – and that’s exactly what we deliver.”

To learn more or schedule a free initial consultation, visit S+P.