Oliver Michelmann Michelmann DORA and LSI Banks

DORA and LSI Banks

von Oliver Michelmann

Proportionality Put to the Test

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Beschreibung

This study examines the digital operational resilience of small and medium-sized credit institutions in light of the EU's Digital Operational Resilience Act (DORA). At its core is the question of how a uniformly calibrated European ICT regulatory framework can be reconciled with the limited resources and business models of German Less Significant Institutions (LSI banks), and where tensions arise between regulatory expectations and practical implementation.

Based on a systematic analysis of the existing supervisory framework and an empirical survey of German LSI institutions, the study identifies the key areas of regulatory burden in ICT risk management, incident reporting, digital resilience testing, and the management of ICT third-party providers. The findings reveal where DORA effectively places disproportionate demands on smaller institutions and how the principle of proportionality would need to be further specified in order to achieve a sustainable balance between digital stability, operational efficiency, and competitiveness in the European banking sector.

About the Author

The author is employed as a civil servant at Deutsche Bundesbank and completed a Master’s degree in Finance with a specialization in Risk Management in Banking at Allensbach University alongside his professional responsibilities. As a banking supervisory examiner, he participates in on-site supervisory inspections, primarily focusing on enterprise-wide risk management and IT governance.

The translation was done with the help of artificial intelligence. A subsequent human revision was done primarily in terms of content.

 

 


This study examines the digital operational resilience of small and medium-sized credit institutions in light of the EU's Digital Operational Resilience Act (DORA). At its core is the question of how a uniformly calibrated European ICT regulatory framework can be reconciled with the limited resources and business models of German Less Significant Institutions (LSI banks), and where tensions arise between regulatory expectations and practical implementation.

Based on a systematic analysis of the existing supervisory framework and an empirical survey of German LSI institutions, the study identifies the key areas of regulatory burden in ICT risk management, incident reporting, digital resilience testing, and the management of ICT third-party providers. The findings reveal where DORA effectively places disproportionate demands on smaller institutions and how the principle of proportionality would need to be further specified in order to achieve a sustainable balance between digital stability, operational efficiency, and competitiveness in the European banking sector.


Academic Work Proportionality SME Banking Perspective

Autor*in

Oliver Michelmann

Themen in »DORA and LSI Banks«

ICT Risk Management and Information Security EU Financial Market and Banking Regulation Digital Operational Resilience Act (DORA) Small and Medium-Sized Credit Institutions (LSI Banks) ICT Third-Party Providers (Outsourcing Arrangements) The Principle of Proportionality in Banking Supervision

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Details

ISBN: 9783658528966
Verlag: Springer Fachmedien Wiesbaden GmbH
Erscheinung: 04.08.2026

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