DORA has applied to EU financial entities since 17 January 2025. It asks for an ICT risk-management framework you can show working, including documented change management.
The DORA blueprint gives code evidence for Article 9 (protection and prevention) and Article 10 (detection) on every pull request. From v1.4.0, change-management evidence for every merged change strengthens Article 9. Governance, incident reporting, resilience testing and third-party risk stay with your process.
On the roadmap: the RTS on ICT risk management (Delegated Regulation (EU) 2024/1774), with Article 17 ICT change management from process evidence and Article 16 from code evidence. Its catalog edition still has to be added.
Toevan gives evidence for controls; it never certifies them or claims a framework is covered. Whether the evidence is sufficient is your auditor’s judgement.
Live2
Code evidence today, sealed on every pull request. Always partial: the control also asks for things outside code. Code evidence today: rules in the DORA blueprint check part of this on every pull request.
Art.9Protection and prevention
Ch.II ICT Risk Management
Strengthened in v1.4.0: change management evidence per merged change.
Art.10Detection
Ch.II ICT Risk Management
Supporting1
Toevan records related evidence, today or in v1.4.0, but the duty is organisational, so it never counts as covered.
Art.28General principles
Ch.V Managing of ICT third-party risk
Supporting evidence today: a rule records evidence related to this duty. The duty itself is organisational policy.
Planned4
Can be evidenced from code or GitHub. The rule or mapping is not built yet.
Art.7ICT systems, protocols and tools
Ch.II ICT Risk Management
Art.8Identification
Ch.II ICT Risk Management
Art.12Backup policies and procedures, restoration and recovery procedures and methods
Ch.II ICT Risk Management
Art.25Testing of ICT tools and systems
Ch.IV Digital operational resilience testing
Your organisation20
Policy, people, physical security, contracts, regulatory procedure, operations or external audit. Your organisation evidences these.
Show all 20 controls
Ch.II ICT Risk Management
Art.5Governance and organisationorganisational policyArt.6ICT risk management frameworkorganisational policyArt.11Response and recoveryan operational processArt.13Learning and evolvingan operational processArt.14Communicationan operational processArt.15Further harmonisation of ICT risk management tools, methods, processes and policiesregulatory procedureArt.16Simplified ICT risk management frameworkorganisational policy
Ch.III ICT-related incident management, classification and reporting
Art.17ICT-related incident management processan operational processArt.18Classification of ICT-related incidents and cyber threatsan operational processArt.19Reporting of major ICT-related incidents and voluntary notification of significant cyber threatsregulatory procedureArt.20Harmonisation of reporting content and templatesregulatory procedureArt.21Centralisation of reporting of major ICT-related incidentsregulatory procedureArt.22Supervisory feedbackregulatory procedureArt.23Operational or security payment-related incidents concerning credit institutions, payment institutions, account information service providers, and electronic money institutionsregulatory procedure
Ch.IV Digital operational resilience testing
Art.24General requirements for the performance of digital operational resilience testingorganisational policyArt.26Advanced testing of ICT tools, systems and processes based on TLPTan external assessmentArt.27Requirements for testers for the carrying out of TLPTan external assessment
Ch.V Managing of ICT third-party risk
Art.29Preliminary assessment of ICT concentration risk at entity levelorganisational policyArt.30Key contractual provisionscontracts and vendors
Ch.VI Information-sharing arrangements
Art.45Information-sharing arrangements on cyber threat information and intelligenceregulatory procedure
Using it in an audit
Take the population from the change records (from v1.4.0)
Every merge into a protected branch and every direct push in the period, captured from GitHub as it happened, is a sealed record you can export for sampling. You can re-perform the default branch’s population from git history; designated production branches are planned for v1.4.1.
Read the code evidence for the period
Each pull request carries sealed code results against the blueprint’s rules, pinned to the commit and the rule-set version in force.
Test a sample
For each sampled record, check its results, then verify its signature and its place in the chain offline.
toevan audit verify --path evidence-clone --pub-key toevan.pub
How each fact was obtained
Every fact in a record and a report carries one of six labels, so your auditor knows how far to rely on it.
- Recomputed
- Toevan computed it from the code or git history itself.
- Re-perform it from the same inputs and get the same result.
- Reported + sealed
- GitHub reported it; Toevan captured it at the event and signed it.
- Rely on it as far as you rely on GitHub. Any later change is detectable.
- Declared + sealed
- The organisation declared it, such as a change to what is checked; Toevan signed the declaration and its history.
- See who declared what, when, and every later change.
- Toevan record, not sealed
- Held in Toevan’s database but not sealed in the ledger, such as a waiver today. Nothing protects it by a signature.
- Treat it as Toevan’s statement, and ask the organisation for the approval behind it.
- Consumed
- Taken from another system’s signed record, such as build provenance, and linked by commit or digest. Planned.
- Check the original record independently.
- Not captured
- No reliable source was available. Toevan does not infer it.
- Obtain it from the organisation by other means.
See it in a report
The sample change evidence report shows the evidence as your auditor receives it, with every fact labelled.
Open the sample reportTest the mapping on a real audit.
Bring one repository and an upcoming audit. We’ll set up the blueprint and walk your auditor through verification.