Question ID: 2735
Regulation Reference: (EU) 2022/2554 - Digital Operational Resilience Act (DORA)
Topic: ICT risk management (DORA)
Article: 6 of DORA and 2 of RTS
Status: Rejected
Date of submission: 13 Jul 2023
Question
Article 6 of DORA and Article 2 of the RTS on ICT risk management clearly assign to control function specific tasks in ICT risk management and monitoring. my understanding of the Article 2 of the RTS is that control function will be appointed to: 1) Define clear and measurable objectives in terms of ICT & Cyber Resilience in order to keep ICT risk within Risk Appetite limit 2) because of the mandate above, control function defines principles and provisions (what to do to be resilient) in the following areas of the RTS in order to be able to measure the defined objectives: (i) ICT Risk management, (ii) Asset Management, (iii) Encryption, (iv) ICT Security Operations, (v) Network Security, (vi) Physical Security, (vii) Project & Change Management, (ix)Security Awareness and Training , while 1st line of defense will in charge of deciding "how to" implement such principles/provisions in technical terms; 3) In the end, control function execute regularly control testing activities in order to asses the effectiveness of the controls implemented by the 1st line (article 2, 1c) Is my understanding correct? Moreover, considering that most of the remaining activities (e.g risk assessment, risk treatment) are also described in Article 3, is then thus confirmed that the control function is responsible of the implementation of requirements in scope of Article 2 and 3?
Background of the question
I understand that it's not possible to give organizational input to the FE, however the 2 mentioned articles clearly name Control Function. How to map the tasks assigned to control function on the 3 lines of defense model, setting goal and being able to measure it. I think it's necessary that 2nd Line define provisions on what to do to stay resilient while 1st line defines "how" they are going to implement such provisions on a technical basis. Clarification will be beneficial
EIOPA answer
This question has been rejected because the matter it refers to is related to draft Standards not yet in force.