The Digital Operational Resilience Act extends ICT risk management requirements to a wide range of financial entities, including bond trustees and security agents operating in the EU.

This framework maps the five DORA pillars — ICT risk management, incident reporting, resilience testing, third-party risk, and information sharing — onto the day-to-day operations of a trustee desk.

We provide a control inventory, a third-party register template, and a sample incident classification matrix calibrated to trustee severity thresholds rather than generic IT taxonomy.

The framework is intended as a starting point for trustees building or upgrading their DORA programme ahead of the next supervisory cycle.