DORA Delivery for Advisory Firms: The Wholesale Model
Compliance consultancies and law firms with EU fintech clients: white-label DORA delivery — three deliverables, five-day turnaround, no retainer commitment.
In this article ↓
- What DORA asks advisory firms to deliver
- Why in-house hiring rarely makes sense
- How the wholesale model works
- The three DORA deliverables
- How to start
- Related reading
- Primary sources
- FAQ
- Is the end client involved in the commissioning process?
- Is there a minimum order or retainer commitment?
- What does the advisory firm need to provide for intake?
- Are the deliverables formatted for NCA submission?
Last reviewed: 16 June 2026
Key takeaways
- DORA requires EU fintech clients to maintain specific operational artefacts — Register of Information, incident classification workflow, board reporting evidence — that require ICT security expertise beyond regulatory advisory.
- A white-label wholesale model lets compliance consultancies and law firms commission these artefacts at fixed prices, under their own brand, without a permanent in-house ICT security hire.
- Three DORA deliverables are available: Register of Information Setup, Incident Classification Framework and Board Reporting Package, each with a five-business-day delivery SLA.
- There is no minimum commitment or retainer — the first project is a single fixed-price commission.
What DORA asks advisory firms to deliver
When a fintech client brings DORA into the compliance engagement, the first layer of work fits naturally into a compliance or legal practice: mapping the regulatory obligations, reviewing existing policies, advising on NCA interactions, helping the management body understand its accountability under DORA Article 5.
The second layer is different. DORA requires financial entities to maintain specific operational artefacts — a Register of Information covering every ICT supplier under DORA Article 28, an incident classification and notification workflow meeting the requirements of the Joint Technical Standards, a board reporting evidence pack that demonstrates management-body oversight of ICT risk. These are not policies or legal opinions. They are structured operational deliverables with required data fields, defined formats and recurring maintenance obligations.
Building and validating these artefacts requires ICT security expertise: familiarity with the ITS template requirements for the Register of Information, with DORA Articles 17–19 incident classification criteria, with what supervisors and partner banks actually look for in a board pack. That expertise sits outside most compliance and legal practices — not because the subject is incomprehensible, but because it is a different operational discipline.
Why in-house hiring rarely makes sense
Adding DORA operational delivery in-house means recruiting a specialist ICT security lead. That hire carries a fixed monthly cost against demand that is project-by-project in nature. DORA readiness work peaks during initial programmes — Register setup, incident framework, board reporting — and slows between review cycles. For most advisory practices, the workload does not justify a permanent hire unless the firm has a large and stable fintech client base.
The alternative — referring the client to a DORA-specialist firm — loses the delivery relationship. The advisory firm stays in the regulatory advisory lane while the specialist builds a direct client relationship on the operational side. The scope that came in through the advisory firm's door goes out through a different door.
Neither outcome is optimal. The fourth option is to maintain the client relationship and commission the operational deliverable from a specialist behind the scenes.
How the wholesale model works
CyAdviso operates a white-label wholesale model for compliance consultancies, law firms and advisory firms with EU fintech clients.
The structure:
- The advisory firm commissions a deliverable at a fixed wholesale price.
- CyAdviso produces the artefact — Register of Information, incident framework or board reporting package — under the advisory firm's brand or without attribution.
- The advisory firm delivers the artefact to the client under its own relationship.
- CyAdviso does not contact the end client directly or develop an independent advisory relationship.
There is no minimum commitment, no retainer and no non-compete. The first project is a single fixed-price deliverable with a five-business-day service-level agreement. Wholesale pricing and full terms are in the partner catalog →.
Advisory firm adding DORA delivery capacity?
Book a 15-minute call with the CyAdviso team — no commitment, see the catalog and wholesale terms first.
Book a free 15-min call →The three DORA deliverables
Three DORA deliverables are currently available for white-label wholesale commissioning:
Register of Information Setup — A complete DORA Article 28 Register for a fintech entity. Covers ICT third-party inventory, service-to-function mapping, criticality assessment, provider categorisation, subcontractor dependencies, contract owner fields and a data-quality validation checklist. Aligned with ITS requirements and NCA submission format.
Incident Classification Framework — DORA Articles 17–19 incident workflow built around the Joint Technical Standards. Includes a classification decision tree with specific threshold criteria, a notification timeline tracker covering initial, intermediate and final notification phases, an evidence retention checklist and NCA routing notes.
Board Reporting Package — DORA Article 5 board reporting evidence pack. Includes a quarterly ICT risk report template, a KPI matrix with suggested indicators calibrated to management-body oversight requirements, a governance evidence summary and a management-body sign-off log.
All three are available as white-label artefacts. Wholesale pricing, five-day delivery terms and the non-compete policy are detailed in the partner catalog →.
How to start
The process begins with a 15-minute call to confirm the deliverable scope and intake requirements. CyAdviso provides a structured intake questionnaire — the advisory firm supplies entity details, function mapping and supplier or incident data depending on the deliverable; CyAdviso builds the artefact and returns it within five business days.
No prior engagement with CyAdviso is required. The deliverable belongs to the advisory firm. End-client introduction is an available option, not the default.
Related reading
- The CyAdviso partner model and catalog
- DORA Third-Party ICT Risk: Articles 28–30 Guide
- DORA Register of Information: 2026 Guide
- DORA Incident Reporting
- DORA Board Responsibilities 2026
Primary sources
- Regulation (EU) 2022/2554 — DORA, EUR-Lex
- EBA Guidelines on ICT and Security Risk Management
- European Banking Authority — Digital Operational Resilience Act
FAQ
Is the end client involved in the commissioning process?
No, by default. CyAdviso operates behind the scenes. The artefact is delivered to the advisory firm, which integrates it into the client engagement under its own brand and relationship. End-client introduction is available as an option, but it is not the default.
Is there a minimum order or retainer commitment?
No. Each deliverable is a standalone fixed-price commission. Advisory firms can start with a single project without any ongoing commitment. Wholesale pricing is in the partner catalog.
What does the advisory firm need to provide for intake?
Intake requirements vary by deliverable. For a Register of Information, the advisory firm provides a supplier list, the services those suppliers provide, the business functions they support and contract ownership. For an incident framework, current workflow documentation and NCA channel. CyAdviso provides a structured intake form at the start of each project.
Are the deliverables formatted for NCA submission?
The Register of Information is aligned with ITS template requirements and the current NCA submission format. The incident framework and board reporting package are structured to meet DORA requirements and should be reviewed by the advisory firm for any jurisdiction-specific adjustments before client delivery.