meta_id 3381129

On August 6, 2026, the Dutch Authority for the Financial Markets (AFM) published DORA-update 7, addressing sector progress and ongoing compliance challenges following the implementation of the Digital Operational Resilience Act (DORA). The AFM identified significant improvements in information register submissions, with European Banking Authority approval rates rising from 40 percent in 2025 to 94 percent in 2026. The AFM attributes this improvement to financial institutions developing better understanding of register completion requirements and formatting standards. However, the AFM emphasised the importance of maintaining focus on register quality and underlying data accuracy to ensure future supervisory requests proceed smoothly. The update highlighted several areas requiring attention from financial institutions. The AFM found that not all supervised entities maintain all mandatory policies and procedures required under DORA, or that existing documentation does not fully align with regulatory requirements. The AFM advised institutions to periodically assess whether their ICT risk management, policies, and procedures remain current and reflect operational practice. For institutions applying group-level policies and procedures, the AFM stressed the importance of verifying that all relevant DORA requirements are fully incorporated, as the licensed entity remains ultimately responsible for DORA compliance. The AFM noted that the number of received DORA incident notifications remains below expectations. Institutions must ensure incidents are detected, classified, and reported within statutory timeframes where required. The AFM provided additional clarification for insurance intermediaries regarding threshold calculations when insurance mediation represents a limited component of total activities, and clarified threshold calculations within group structures. The complete DORA-update 7 is available on the AFM website.