DuoKey

DORA Compliance Brief

4 pages, 2025. For EU financial entities.

What DORA's Article 9 requires for encryption and key management, and how DuoKey's controls map to each requirement. DORA has applied since 17 January 2025, with fines of up to €15 million or 2 percent of annual turnover. Get the brief to check your encryption controls against Article 9, one paragraph at a time, before your supervisor does.

Cover of the DuoKey DORA compliance brief.

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DORA has applied since 17 January 2025. Fines reach €15 million or 2 percent of annual turnover. And according to ECB figures, 60 percent of institutions already reported a cyberattack in 2021, at an average breach cost of $5.85 million.

Article 9 sets specific requirements for encryption and key management. This brief takes them one paragraph at a time, 9.3(b), 9.3(d), 9.4(c), and 9.4(d), and shows which control meets each one.

Download it and check your own controls against the list before your supervisor does.

FAQ

Who is this for?

Security, risk, and compliance staff at banks, insurers, and other financial entities covered by DORA.

Which parts of DORA does it cover?

Article 9, specifically paragraphs 9.3(b), 9.3(d), 9.4(c), and 9.4(d), which cover data protection and cryptographic key management.

Which DuoKey controls does it map?

Distributed key management with multi-party computation, full key lifecycle, zero-trust access rules, fully homomorphic encryption for processing data without decrypting it, and post-quantum readiness.

Is it legal advice or a full DORA programme?

No. It covers the encryption and key-management part of Article 9 only.