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The DORA regulation came into force on 17 January – check the position of the FSC

The Polish Financial Supervision Authority (the PFSA) has published its position on the application of DORA Regulation by financial entities. DORA Regulation is an act of EU law, which is subject to direct application as of January 17, 2025.

However, the implementation of certain issues arising from DORA, requires the adoption of national regulations – which has not yet occurred in Poland. The KNF’s announcement fills this temporary vacuum.

Supervision of the FSA over compliance with DORA

The FSC’s tasks of supervising compliance with DORA in part derive directly from the content of the regulation, so delays in enacting a national law do not affect the regulator’s role in this regard. The FSC has been taking on the role of supervisor since the first day of application of DORA, as exemplified by the Supervisory Priorities for 2025 (available here), where the issues of effective and efficient supervision of the ICT risks of financial market entities under DORA regulation are addressed.

Difficulties with the implementation of national regulations are no excuse for financial entities, which the FSC expects to be ready to apply DORA from day one (17.01.2025). In its position, the FSC explicitly requires compliance with the conditions set forth in the EUN’s position on the application of DORA (available here).

Difficulties with the implementation of national regulations are no excuse for financial entities, which the FSC expects to be ready to apply DORA from day one (17.01.2025). In its position, the FSC explicitly requires compliance with the conditions set forth in the EUN's position on the application of DORA (available here).

Reporting

The FSC is actively preparing to receive the reports resulting from DORA by preparing IT systems. Reporting obligations will be carried out by financial entities only in electronic form using ICT systems designated by the FSC.

The new rules will also apply to incident reporting. The existing regulations have been replaced by the DORA regulation and the relevant Regulatory Technical Standards (RTS).

The FSC has prepared a summary of reporting obligations under DORA, which is available on the regulator’s website (available here).

Existing sector regulations

As DORA cross-cuttingly regulates digital resilience, including ICT systems, the FSC announced the repeal of sectoral regulations, including the famous cloud announcement.

 The DORA regulation came into force on 17 January - check the position of the FSC

Important changes

The FSC is taking on the role of supervising the application of DORA despite the shortcomings of the national legislature. The area of ICT as a key to the proper functioning of the financial market is entering a new stage determined by DORA regulations. As specialists in this matter, we provide assistance in the proper implementation and application of the new legal solutions. We invite you to contact us.

Author team leader DKP Legal Alicja Mruczkiewicz
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