DORA for Non-Financial-Services Executives: Why Your Vendors Might Already Be In Scope
You don't have to be a bank for DORA to matter to your business. If your customers are EU financial entities, their DORA obligations are quietly becoming your contract terms.
September 16, 2026
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DORA for Non-Financial-Services Executives: Why Your Vendors Might Already Be In Scope
If your company doesn't sell directly into EU financial services, DORA can still reach you indirectly and materially. Every DORA-regulated financial entity is now required to include specific contractual provisions in its agreements with ICT third-party providers — audit rights, exit strategies, incident-notification obligations, and more — provisions that flow downstream into vendor contracts regardless of where the vendor itself is headquartered.
What to actually check
- Are any of our customers EU-regulated financial entities (banks, insurers, investment firms, payment institutions)? If so, expect DORA contract-clause requests during renewal.
- Could our product be significant enough to a customer's operational resilience that we'd be a candidate for "critical ICT third-party provider" designation?
- Do our incident-notification SLAs to financial-sector customers actually match DORA's own reporting timelines, or are we relying on a generic SLA that predates DORA?
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