The digital operational resilience act: challenges and some reflections on the adequacy of Europe’s architecture for financial supervision

Abstract The paper critically analyses the Digital Operational Resilience Act (DORA) within the European Union (EU) with respect to challenges such as supervision and the oversight framework coordination. It delves into the adequacy of the European System of Financial Supervision (ESFS) in ensuring compliance with this regulation, highlighting issues of fragmented supervision at national level and inconsistent approaches. The main argument suggests that while the DORA Regulation is a positive step for harmonising digital operational resilience regulation, it brings about challenges in supervisory convergence and cooperation due to the existing fragmented supervisory architecture. The authors propose potential solutions like a more centralised supervision model to address these challenges. The paper follows a structured format with an overview of the DORA Regulation, discussion on identified challenges, and a concluding section.