DORA vs. NIS2: What’s the Difference, and Do You Need to Comply with Both?

Cyber threats have evolved dramatically over the past decade. Attacks that once targeted individual companies now impact entire sectors, disrupt national infrastructure, and threaten the stability of financial systems. Recognizing this growing risk, the European Union has introduced a series of cybersecurity regulations aimed at strengthening digital resilience across both critical services and financial institutions.

Two of the most prominent and wide-reaching regulations in this space are the Digital Operational Resilience Act (DORA) and the Network and Information Security Directive (NIS2). At first glance, they might appear to cover similar ground. Both are designed to improve cybersecurity readiness and ensure business continuity during ICT-related disruptions. But look closer, and key differences in scope, enforcement, and applicability emerge.

If you’re unsure how to manage compliance efficiently or whether your organization falls under one, both, or neither, this guide will help clarify the landscape.

Why the EU Introduced Both DORA and NIS2

In the past decade, cybersecurity has evolved from a technical silo into a core strategic issue. The EU introduced both DORA and NIS2 in response to growing digital interdependence and an alarming increase in cyberattacks on essential services. High-profile ransomware incidents, data breaches, and supply chain attacks have demonstrated that disruptions in one organization can quickly affect entire industries or regions.

NIS2 emerged to address vulnerabilities across a wide range of critical sectors, while DORA was developed with a sharper focus on financial system stability. This sector-specific regulation acknowledges that a single ICT incident in a major bank, payment institution, or financial infrastructure provider could trigger systemic risk across Europe’s economy.

Rather than duplicating efforts, the EU designed these two frameworks to complement each other. Together, they cover a spectrum of digital risks that no single regulation could adequately address alone.

What Is DORA?

The Digital Operational Resilience Act (DORA) is a binding EU regulation that entered into force in January 2025. It focuses specifically on the financial sector and its dependence on digital technology.

DORA’s primary goal is to ensure that financial entities can withstand, respond to, and recover from ICT-related incidents. DORA sets uniform rules for managing ICT risks within the financial sector. It requires regulated entities to:

• Implement and test ICT risk management frameworks
• Report major ICT-related incidents within specific timeframes
• Classify and oversee critical third-party ICT service providers
• Conduct resilience testing
• Participate in information-sharing arrangements

One of DORA’s defining characteristics is its sector-specific scope. It is tailored for financial entities, including banks, insurers, investment firms, payment service providers, pension providers, credit rating agencies, and crypto-asset service providers.

In addition, DORA brings ICT vendors under its regulatory umbrella. Any third-party provider that delivers critical digital services to financial institutions may also fall within the scope - either directly or indirectly through supervisory mechanisms.

Because DORA is a regulation, it applies uniformly across all EU member states without the need for national transposition. This ensures legal consistency and simplifies compliance strategies for multinational financial institutions.

What Is NIS2?

The Network and Information Security Directive (NIS2) is an updated version of the original NIS Directive, which was adopted in 2016. NIS2 came into force in January 2023, with member states required to transpose it into national legislation by October 2024.

NIS2 takes a horizontal, cross-sector approach to cybersecurity. It covers a wide range of industries deemed essential or important to societal and economic function. These include energy, transport, health, water, digital infrastructure (e.g., DNS providers, data centers), public administration, ICT services, and space and manufacturing (for certain sectors)

Entities under NIS2 are categorized as either essential or important depending on their criticality. Both categories face obligations like:

• Implementing risk management and security measures
• Reporting significant incidents within 24 hours
• Ensuring senior management accountability for cybersecurity
• Undergoing supervision by national regulatory authorities

Because NIS2 is a directive, its enforcement varies slightly between member states, depending on how each country transposes it into domestic law.

Let’s visualize the differences with a quick side-by-side comparison:

Key Differences Between DORA and NIS2

While both regulations address cybersecurity and operational resilience, they differ in several fundamental ways:

1. Scope of Application
DORA is sector-specific, focusing solely on the financial sector and its digital service providers. NIS2 is cross-sectoral, covering a broader range of essential and important industries across the EU economy.

2. Legal Format
DORA is an EU regulation, making it directly applicable across all member states without the need for individual countries to draft local legislation. NIS2 is a directive, meaning each country must transpose it into national law, potentially leading to minor variations between jurisdictions.

3. Supervisory Model
DORA introduces centralized supervision, largely coordinated at the EU level by bodies like the European Supervisory Authorities (ESAs). NIS2, in contrast, follows a decentralized model where each country designates its own National Competent Authorities (NCAs) to oversee compliance.

4. Level of Prescriptiveness
DORA sets detailed, prescriptive requirements regarding ICT risk management, vendor oversight, testing, and incident response for financial entities. NIS2 focuses more on outcomes and principles, allowing national authorities discretion in interpreting specific controls.

5. Third-Party Oversight
DORA places direct regulatory obligations on critical ICT third-party vendors serving the financial sector. NIS2 emphasizes broader supply chain risk but generally stops short of regulating individual vendors unless they fall into NIS2’s direct scope (e.g., large digital infrastructure providers).

Where the Two Frameworks Overlap

Despite their differences, DORA and NIS2 share several areas of operational and procedural alignment. If your organization falls under both frameworks, you’ll notice overlap in:

• Incident Reporting: Both regulations mandate timely reporting of significant ICT incidents, though reporting timelines and formats may differ.
• Governance Structures: Senior management accountability and board-level involvement in cybersecurity governance are core expectations in both frameworks.
• Vendor Risk Management: Both require oversight and risk assessments for third-party providers, albeit with different levels of prescriptiveness.
• Business Continuity and Testing: Ongoing resilience testing and scenario-based planning are key components under both DORA and NIS2.
• Cultural Shift: Both frameworks signal that cybersecurity can no longer sit solely within IT. Legal, risk, procurement, and executive leadership teams must all play active roles.
• For multinational organizations, especially ICT providers and digital infrastructure firms, this overlap can create complexity, but also an opportunity to build a unified compliance framework that addresses both sets of requirements simultaneously.

What If You Fall Under Both?

This is not just a theoretical issue. Many large organizations - particularly ICT vendors, digital infrastructure providers, and financial software firms - may be subject to both DORA and NIS2.

If that applies to you, it’s critical to develop a compliance alignment strategy. This starts with mapping both sets of obligations against your existing controls and identifying where processes can be unified. For example, you may be able to centralize your incident response playbooks, standardize internal governance, and streamline vendor onboarding processes to address both frameworks simultaneously.

Cross-functional collaboration is essential. Legal, compliance, security, IT, and procurement teams need to coordinate to avoid duplication and reduce gaps. It may also be helpful to appoint a designated program owner responsible for maintaining synergy between DORA and NIS2 implementation.

And remember that while the legal mandates differ, the goal is the same: Proving that your organization is digitally prepared, resilient, and capable of managing real-world disruption.

Looking Ahead: The Broader Regulatory Context

DORA and NIS2 are not isolated initiatives. They are part of a wider EU regulatory trend toward greater digital resilience, cybersecurity accountability, and supply chain transparency.

Upcoming regulations, such as the Cyber Resilience Act (CRA) and EU AI Act, will introduce further requirements around software security and emerging technologies. Organizations that build flexible, scalable compliance frameworks today will be better positioned to adapt as the regulatory landscape continues to evolve.

A New Era of Regulatory Cyber Maturity

DORA and NIS2 are two of the most ambitious cybersecurity regulations ever introduced by the European Union. Together, they mark a significant turning point in how organizations must think about resilience, responsibility, and risk.

Although they serve different sectors and follow different legislative paths, the principles that underpin them are consistent: digital operations must be robust, risks must be managed actively, and disruptions must be recoverable.

For organizations subject to both, the challenge lies in integration. For those subject to one or the other, the message is still clear: cyber resilience is no longer a competitive advantage. It’s a baseline expectation.

Need clarity on how DORA impacts your team? Our DORA Essentials course provides a deeper dive into how the regulation is structured, what it means for your organization, and how to start aligning with its five key pillars. It’s a practical way to move from theory to action - especially for financial institutions and their ICT providers navigating this evolving landscape.