DORA Fines. Up to 1% of daily turnover and Polish FSA (KNF) supervision.
DORA has applied to the financial sector directly since January 2025. For critical ICT providers it means periodic penalties counted as a percentage of turnover; for financial entities, administrative fines from the Polish FSA (KNF). Below: what is at risk, who is in scope, obligations, and a plan.
What a DORA violation costs
- up to 1% / dayCritical ICT providers ; periodic penalty of up to 1% of average daily worldwide turnover, applied for a maximum of 6 months (Art. 35)
- up to ~21 mln PLNFinancial entities ; administrative fines for violations, per the Polish DORA implementing legislation draft
- up to ~3 mln PLNNatural persons ; personal liability for breach of obligations
- remedial measuresPolish FSA (KNF) ; orders, requirements on providers, and supervisory actions (Art. 50 + national rules)
Based on Regulation 2022/2554 and the Polish DORA implementing legislation draft.
Who DORA applies to
Banks, investment firms, payment institutions and e-money institutions, insurance and reinsurance undertakings, fund managers, and other financial sector entities in the EU.
Critical third-party ICT service providers to the financial sector are subject to direct supervision and separate penalties.
DORA is a regulation; it applies directly (no transposition needed). In Poland supervision is carried out by the Polish FSA (KNF).
Obligations and how to prepare
ICT risk management
ICT risk management framework, policies, roles and responsibilities, continuous monitoring.
ICT vendor register
Classification of critical functions, concentration risk, register in the format required by the Polish FSA (KNF) (SPR-PF-18).
Incident reporting
Classification and reporting of major ICT incidents to the supervisory authority within required timeframes.
Resilience testing
Regular testing; for significant entities also TLPT (threat-led penetration testing).
Vendor register, RTO mismatch, resilience testing, and Polish FSA (KNF) export ; all in the DORA module.
Frequently asked questions about DORA fines
DORA in practice, ready for the Polish FSA (KNF).
30-minute demo: ICT vendor register, concentration risk, RTO mismatch, and SPR-PF-18 export.