DORA-Compliant Disaster Recovery: Infrastructure Architecture for Financial Institutions

DORA Articles 11 and 12 require ICT business continuity management and disaster recovery with specific technical requirements. For financial infrastructure, "best effort" recovery isn't acceptable — you need defined RTOs, RPOs, and tested recovery procedures.

DORA-Specific DR Requirements

• Dedicated ICT business continuity policy — Separate from general business continuity, focused on technology infrastructure
• Impact analysis — Quantified impact of severe disruptions to ICT systems on business functions
• Recovery objectives — Defined RTO and RPO for every critical ICT system, with justification
• Secondary processing site — Geographically separated, capable of ensuring continuity of critical functions
• Annual testing — DR plans tested at least annually with documented results and remediation of gaps

Infrastructure Architecture

Multi-Region Active-Active

For critical systems (payments, trading, core banking), active-active deployment across regions. Both sites serve traffic. Failover is automatic and seamless. No RTO — the system never goes down, it just shifts load.

Active-Passive with Automated Failover

For important but not critical systems: warm standby in a secondary region. Automated failover with DNS-based or load-balancer-based switching. Target RTO: 15-30 minutes. Regular failover drills to validate.

Immutable Backup Infrastructure

Ransomware-resilient backups: air-gapped or immutable storage, encryption with separate key management, automated restoration testing (not just backup verification), cross-region replication with independent access controls.

Testing Infrastructure

DORA requires annual DR testing. Build infrastructure that makes testing routine:

• Automated failover testing — scheduled, monitored, with automatic pass/fail assessment
• Backup restoration testing — monthly automated restores to validate backup integrity
• Communication testing — automated notification chains for crisis communication
• Full-scale simulation — annual exercise simulating complete primary site loss