DORA ICT Risk Management Framework (RMF)
The ICT Risk Management Framework (RMF) and the Simplified ICT Risk Management Framework are both designed to ensure the digital operational resilience of financial entities, but they differ in scope and application based on the size, nature, scale, and complexity of the services provided by the entities.
Scope and Complexity
The ICT Risk Management Framework (RMF) is comprehensive and applies to a broad range of financial entities. It includes detailed strategies, policies, procedures, and ICT tools necessary to protect all ICT assets and relevant physical components. This framework must be reviewed at least once a year and continuously improved based on lessons learned from implementation and monitoring.
The Simplified ICT Risk Management Framework is a streamlined version of the RMF, designed for specific types of companies that are exempted due to their size and the nature, scale, and complexity of their operations. It focuses on essential areas and elements necessary to ensure the confidentiality, integrity, availability, and authenticity of data and services, taking into account the overall risk profile of the institution.
Documentation and Review:
Both frameworks require documentation and periodic review. However, the Simplified ICT Risk Management Framework mandates a proportionate approach, reducing the administrative and operational burden on smaller entities. The frequency of the periodic review for the simplified framework depends on the institution’s risk profile.
Governance and Control:
Financial entities under both frameworks must have an internal governance and control framework with clear responsibilities to enable effective and sound ICT risk management. The simplified framework, however, aims to reduce the complexity and administrative load, making it more manageable for smaller entities.
Applicability
The Simplified ICT Risk Management Framework is applicable to financial entities referred to in Article 16(1) of DORA. These entities are typically smaller in size and have less complex operations compared to those required to implement the full RMF. The simplified framework ensures that these entities can still maintain a high level of digital operational resilience without being overburdened by extensive requirements.
Proportionality
The simplified framework is designed to be proportionate, ensuring that the requirements are not overly burdensome for smaller entities. It provides crucial requirements on ICT risk management while considering the size, nature, scale, and complexity of the services, activities, and operations of the financial entities it applies to.