The answer to this question is provided by the European Commission.

Insurance intermediaries, reinsurance intermediaries and ancillary insurance intermediaries which are microenterprises or small or medium-sized enterprises are exempted from the scope of DORA as per Article 2(3)(e) of DORA. To qualify as microenterprises or small or medium-sized enterprises under DORA, entities must meet certain thresholds relating to the number of employees, annual turnover and annual balance sheet total that are set out in Article 3(60), (63) and (64) DORA. 

In practice, there are situations where some insurance intermediaries, reinsurance intermediaries and ancillary insurance intermediaries have a very limited activity/resources dedicated to the insurance business, for which they do not have set up a separate legal entity. However, it may appear that the turnover, annual balance sheet total or their number of employees related to their global activities, including both insurance related and insurance unrelated activities are beyond the threshold set out in Article 2(3)(e) of DORA. As a result, those insurance intermediaries, reinsurance intermediaries and ancillary insurance intermediaries are not exempted from the scope of DORA pursuant to Article 2(3)(e) of that regulation. Accordingly, DORA would normally apply to them, despite their very limited activity/resources dedicated to the insurance business. 

However, in light of the principle of proportionality and equal treatment, the calculation of the thresholds for the insurance intermediaries, reinsurance intermediaries and ancillary insurance intermediaries that have a very limited activity/resources dedicated to the insurance business should be done by taking into account only those activities/resources dedicated to the insurance business. Moreover, the guidance set out in DORA Q&A 3100 remains valid.

Disclaimer provided by the European Commission:

The answers clarify provisions already contained in the applicable legislation. They do not extend in any way the rights and obligations deriving from such legislation nor do they introduce any additional requirements for the concerned operators and competent authorities. The answers are merely intended to assist natural or legal persons, including competent authorities and Union institutions and bodies in clarifying the application or implementation of the relevant legal provisions. Only the Court of Justice of the European Union is competent to authoritatively interpret Union law. The views expressed in the internal Commission Decision cannot prejudge the position that the European Commission might take before the Union and national courts.