Under the EU’s Digital Operational Resilience Act (DORA), the bar has changed. Regulators are adopting a new mantra:
“Show us, don’t tell us.”
That shift sounds small, but in practice, it’s massive — especially for trading and post-trade systems, where resilience depends on a complex web of internal and external dependencies.
Let’s look at the five most common gaps we’re seeing, and why they matter.
Many firms still test systems in isolation: a DR test for one application here, a vendor failover simulation there. But DORA requires end-to-end resilience testing — meaning a full workflow, across systems and providers, must be proven to recover and operate under stress.
In post-trade environments, that means more than just bringing a matching engine or settlement module back online. You need to show that trade data, reconciliation, client reporting, and payment messages all continue to flow correctly after a disruption.
If you’ve never tested the entire trade lifecycle under a real-world failure scenario, DORA will expose that gap quickly.
DORA puts heavy emphasis on third-party risk, and rightly so. Brokers rely on a growing number of service providers — cloud platforms, market data vendors, reconciliation tools, messaging hubs — to keep operations running.
The problem: most firms don’t have a clear, structured view of how each dependency impacts their operational resilience.
A spreadsheet of vendor contacts isn’t enough. Regulators will want to see mapped dependencies, impact assessments, and evidence that you’ve tested recovery scenarios with your key vendors.
Even if your internal systems are robust, one untested external dependency can undermine your entire resilience posture.
When something breaks, does everyone know what to do — or does the process depend on who’s on call?
In many firms, incident response lives in multiple places: IT has a playbook, ops has a separate one, and compliance documents something else entirely. That fragmentation slows down response times and creates confusion — especially when regulators expect coordinated, documented evidence of how incidents are handled and communicated.
DORA requires a unified incident management framework that links detection, escalation, and recovery across teams. It’s not just about fixing the issue — it’s about proving that you can manage and learn from it consistently.
If you can’t trace how data moves across your systems — and who touched what — auditors will flag it immediately.
Strong data lineage and audit trails aren’t just technical niceties; they’re core to DORA compliance. You’ll need to show exactly how trade data flows through the chain: from capture, to enrichment, to confirmation, to settlement. That means clear logging, time-stamped records, and immutable change histories.
In many legacy setups, data lineage is buried across multiple systems, each with its own format and retention policy. Bringing that together takes planning — but it’s one of the most tangible ways to demonstrate resilience.
Many brokers still rely on systems that were never designed with governance in mind. They perform the job well enough day-to-day, but they lack the observability, traceability, and automation that DORA now expects.
You can’t simply bolt governance on top of legacy systems — at least not effectively. To meet DORA’s “show us” standard, firms will need to modernise parts of their infrastructure, or at least create robust wrappers that provide the required visibility.
Ignoring this area is risky: it’s often where “unknown unknowns” hide — undocumented interfaces, manual scripts, or old failover processes that no one has tested in years.
The first DORA audits in 2025 won’t hit every broker at once. But every broker must be audit-ready. That’s the key shift: readiness isn’t about ticking a compliance box — it’s about building operational muscle that can be demonstrated at any moment.
We’ve seen this pattern before with other regulations: the first wave exposes weak spots across the industry, and the next wave tightens expectations. The firms that prepare early not only avoid penalties but also run cleaner, more efficient operations as a result.
At AQX Technologies, we work with financial firms to make resilience measurable and demonstrable. That includes mapping dependencies, automating audit trails, and building testable recovery workflows across post-trade environments.
The goal isn’t to create more documentation — it’s to prove operational resilience through data. That’s what DORA demands, and frankly, it’s what modern trading infrastructure should already aim for.
DORA isn’t just a compliance hurdle. It’s an opportunity to get ahead of systemic risk and modernise how resilience is measured across the industry.
If you can confidently say, “Here’s how we recover, and here’s the evidence,” you’re already in a stronger position than most.
The question is: will your firm be ready to show it when the auditors come knocking?
Learn more: www.aqxt.com
Contact our team: https://aqxt.com/contact