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DORA Art. 3(22) · Art. 5(2) · Art. 8

Evaluate your DORA CIFs with an auditable methodology

5 guided steps, the 4 Art. 3(22) criteria operationalized, AI justification in 15 seconds, approval workflow and review cadence. ESA-audit-ready output (EBA/ESMA/EIOPA) and ACPR/AMF/BaFin.

5-step methodology

From raw function listing to approved and reviewed CIF — no spreadsheet, no reinvention.

Step 1

Identify

Inventory of ICT-supported functions: market operations, payments, KYC, credit issuance, services to authorised clients, prudential reporting. Import from your existing process registry or let AI derive from your authorised activities.

Step 2

Score (4 criteria)

For each function, check the 4 Art. 3(22) impact criteria with quantified thresholds: financial impact (€), continuity impact (customers affected, downtime hours), authorisation impact, other regulatory obligations (MiFID, AMLD, FATCA thresholds…).

Step 3

Justify (AI in 15 s)

ResiPlan AI drafts the criticality justification from the name, business area and checked criteria. Audit-ready tone, explicit DORA references, structure 'what makes the function critical + Art. 3(22) reference'. Saves 2 h per CIF.

Step 4

Approve

Workflow draft → review → approved by the management body or its delegate (e.g. CISO + CRO). Timestamped trace of approver and date. Dashboard of CIFs pending review.

Step 5

Review

Quarterly, semi-annual or annual cadence (configurable per CIF). Auto-reminders, diff vs N-1 version, re-justification request if a criterion or threshold changed. Covers Art. 5(2) 'regularly review' obligation.

The 4 Art. 3(22) criteria — operationalized

Each criterion must come with quantified thresholds. ResiPlan guides you to defendable thresholds.

1. Financial performance

Unavailability of the function or quality degradation would materially affect the entity's financial performance (revenue, cost, valuation, exposure).

Typical thresholds: Quantified thresholds: estimated annual loss € · % of revenue

2. Continuity of authorised activities

Loss of continuity would prevent the entity from providing the authorised service to clients (payments, markets, custody, advisory, etc.).

Typical thresholds: Thresholds: customers affected · MTPD hours · revenue loss/hr

3. Authorisation conditions

Failure would jeopardize compliance with authorisation conditions, registry entry or equivalence regimes (MiFID II, AIFMD, CRR, IDD…).

Typical thresholds: Criteria: capital threshold breach · IT outsourcing breach

4. Other regulatory obligations

Missed prudential reporting, failed Art. 17 incident notifications, AMLD obligations, MiFIR transaction reporting, EMIR clearing, FATCA/CRS, sanctions screening.

Typical thresholds: Thresholds: missed reports · legal deadline breached

Decision matrix

ProfileDORA statusConsequences
No criterion checkedOut of DORA scope
1 criterion checked, thresholds below limitsImportant function (to document)Annual review sufficient
≥1 criterion + thresholds breachedCIF — Critical or Important FunctionSemi-annual review, TLPT scope
≥2 criteria + systemic impactPriority CIF (TLPT mandatory)Quarterly review, exit plan Art. 28(7)(j)
Step 3 — AI

Criticality justification, written in 15 seconds

ResiPlan AI receives the name, business area and checked criteria; it produces an audit-ready, structured text with explicit DORA references and quantified thresholds. You edit before approval. Typical saving: 2 h per CIF, ~80 h on a 40-function registry.

Explicit Art. 3(22) citations · ESA-friendly tone
Example — AI output
"The function "MTS clearing" is a CIF within the meaning of DORA Art. 3(22) because (i) unavailability would affect the entity's financial performance (estimated annual loss > 5% of net income), (ii) disruption would prevent provision of clearing services to authorised institutional clients, (iii) it conditions compliance with EMIR transaction reporting obligations. RTO 4 h, RPO 15 min, MTPD 24 h. Reference: DORA Art. 3(22), 5(2) and 8(1)."

Approval workflow

Per DORA Art. 5(2) — the management body approves, reviews and revises.

Draft
CIF owner
Under review
CISO + CRO
Approved
Management body
Re-review
Auto at T+review

Every transition is timestamped, signed by the user and traced in the audit log. A PDF export of the approval file is available for ESAs.

DORA articles covered

Art. 3(22)
CIF definition — 4 criteria
Art. 5(2)
Regular review by management body
Art. 6
ICT risk management framework
Art. 8
Identification, classification, documentation
Art. 11
Response and recovery — RTO/RPO/MTPD
Art. 17
Major incident reporting
Art. 26-27
TLPT scope (priority CIFs)
Art. 28
ICT third-party risk (CIF mappings)
Art. 31
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DORA CIF evaluation — auditable Art. 3(22) methodology | ResiPlan