This blog is part of a three part series all about the EU’s Digital Operational Resilience Act (DORA). In part 1, you can find a comprehensive breakdown of the act. It looks at who DORA applies to, dates for DORA compliance, recommended DORA frameworks, DORA violation penalties, and risk controls for DORA. In today’s blog post, we’ll give recommendations on how organizations can manage the cost implications of DORA. Finally, in part 3, we’ll take a look at the role continuous testing plays in DORA compliance. 


In my two decades in cybersecurity, I’ve consistently seen that investing in resilience pays dividends in the long run—particularly in a sector as vulnerable as finance. While compliance with DORA can seem like a heavy financial burden to smaller firms, the cost of a significant cybersecurity incident or operational breakdown will almost certainly dwarf any initial compliance outlay. The short-term financial challenges—such as upgrading infrastructure and hiring specialized personnel—are very real. But the ultimate reward is a framework that not only keeps you within regulatory bounds but protects against real-world threats. DORA is designed to help institutions handle everything from everyday cyber threats to large-scale operational disruptions. In the end, spending to meet these requirements isn’t just about box-ticking; it’s a strategic investment in reliability and market trust.

There’s no question that DORA will intensify competition for skilled cybersecurity talent—especially with the existing global skills shortage. Firms of all sizes will be looking to hire or partner with external services to meet DORA standards for continuous monitoring, operational resilience, and robust testing programs. This is precisely where bug bounty and penetration testing services can help bridge the gap, allowing organizations to tap into a broader pool of ethical hackers and security experts without having to source and train every skill in-house. 

At Bugcrowd, for example, we’ve seen a significant uptick in demand for continuous testing and on-demand security expertise. We’ve developed models that give clients flexible, scalable access to skilled cybersecurity professionals—making DORA compliance more manageable. By leveraging a global community of vetted testers, along with platform-based orchestration, smaller firms can maintain high levels of resilience without necessarily having to support a large internal security team.

 

Cost implications of DORA compliance

Complying with the EU’s Digital Operational Resilience Act (DORA) involves substantial upfront and ongoing investments, particularly for financial institutions that may not yet have mature cybersecurity frameworks. For smaller firms, the cost of compliance can seem daunting, but it’s far less than the financial and reputational damage of a major cybersecurity breach.

Key cost areas include:

Cybersecurity infrastructure upgrades

Many firms will need to modernize their ICT systems to meet DORA’s requirements for operational resilience. This includes investing in advanced monitoring tools, incident response solutions, and secure cloud infrastructures.

Smaller organizations, which often rely on legacy systems, face disproportionately high costs as they may need to replace or overhaul outdated technology entirely.

Operational resilience testing

DORA mandates regular digital operational resilience testing, including penetration testing and vulnerability assessments. This requires not only budgeting for tools and platforms but also engaging external services or expanding internal testing teams.

Unlike one-off testing efforts, DORA emphasizes a continuous and proactive approach, necessitating sustained investment over time.

Workforce expansion and training

Organizations must hire or upskill personnel to meet the regulatory demands for ICT risk management. These roles often include cybersecurity analysts, ICT risk officers, and compliance specialists.

Given the global cybersecurity skills shortage, firms are likely to face fierce competition for talent, driving up salaries and recruitment costs.

Third-party risk management

Ensuring third-party providers meet DORA’s standards can be a significant expense. Firms may need to audit vendors, renegotiate contracts, or even switch to new suppliers with better compliance credentials.

Regulatory reporting and oversight

DORA requires institutions to establish robust reporting mechanisms for incidents and risks. This could involve investing in compliance tools and platforms to automate reporting and maintain audit trails.

 

Staffing challenges and the cybersecurity skills gap

DORA compliance isn’t just a financial challenge—it’s a staffing challenge. Finding the right people to design and execute a resilience framework will be the hardest task for many organizations.

The cybersecurity talent shortage is a well-documented issue, and DORA compliance is expected to exacerbate it. Specifically:

Demand for specialized skills

DORA compliance requires expertise in areas like ICT risk management, incident response, and resilience testing. These are highly specialized skills that are already in short supply across Europe and beyond.

Smaller firms, in particular, may struggle to attract and retain talent in competition with larger organizations offering higher salaries and better benefits.

The cost of training and retention

For organizations unable to hire externally, upskilling existing employees is an alternative, but this comes with its own set of challenges. Training programs are expensive, and the time taken to train staff can delay compliance.

Additionally, retaining trained personnel is increasingly difficult, as cybersecurity professionals are often lured away by competitors or opportunities in other regions.

Over-reliance on third-party services

Smaller organizations may need to rely more heavily on external service providers for testing, monitoring, and compliance management. While this can reduce the internal staffing burden, it adds recurring costs and potential risks associated with vendor reliance.

Burnout and employee turnover

The added pressures of regulatory compliance can lead to burnout among existing staff, particularly in smaller teams where the workload is concentrated. High turnover rates may further destabilize organizations as they try to meet compliance deadlines.

 

How to manage these challenges effectively

Leverage platform-based solutions

Organizations can reduce costs and staffing pressures by adopting platform-based services for activities like continuous penetration testing, incident management, and compliance reporting. These solutions are often scalable and cost-effective. Providers like Bugcrowd offer access to global talent pools and advanced testing frameworks that enable firms to meet resilience standards without scaling internal teams.

Adopt a risk-based approach

Prioritizing resources based on risk can help organizations allocate budgets effectively. Not all systems and processes need the same level of attention, and a strategic focus can prevent overspending.

Collaborate with industry groups

Participation in industry groups or consortiums can provide access to shared resources and expertise, reducing the overall cost of compliance.


In a world of scarce talent, platforms like Bugcrowd provide an opportunity to scale security testing without scaling teams. Stay tuned for part 3 of this series, where I’ll cover the role of continuous testing in DORA compliance.