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DORA Compliance: Banking DevOps at Speed

Scrums.com Editorial Team

December 1, 2025

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10 mins

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DORA Compliance: Banking DevOps at Speed

Introduction

Banking DevOps has a compliance problem. Your engineering teams want to ship features faster, but Risk, Audit, and Compliance demand exhaustive oversight before anything touches production. The old answer was to slow down, add more manual checkpoints, more sign-offs, and more documentation. The new reality? The Digital Operational Resilience Act (DORA) doesn't just expect you to be resilient; it requires you to prove it continuously with evidence, testing, and third-party oversight.

For CTOs and engineering leaders in European banking, DORA's January 2025 enforcement date has created urgency. But rather than viewing DORA as another compliance burden, forward-thinking banks are using it as a catalyst to modernize delivery. The secret isn't choosing between speed and control; it's about automating governance so that software development teams move faster because controls are embedded, not bolted on afterward.

This guide shows you how to achieve DORA compliance while accelerating delivery. You'll learn how governance-as-code turns regulatory requirements into automated pipeline checks, how to map DORA's four pillars into your SDLC, and a practical 90-day blueprint that gets you audit-ready without hiring compliance overhead. Whether you're early in DORA preparation or refining your approach, these strategies work for banks of any size.

Why Governance-as-Code Unlocks Safer Speed

Traditional compliance creates friction. Engineering submits change requests, waits for manual reviews, collects approvals across multiple stakeholders, and assembles evidence after the fact. By the time a feature reaches production, weeks or months have passed, and the evidence trail is scattered across emails, tickets, and spreadsheets. When auditors arrive, teams scramble to reconstruct what happened.

Governance-as-code flips this model. Instead of enforcing policy through human checkpoints after work is done, you encode requirements as machine-readable rules that run automatically at every stage of your delivery pipeline. Controls execute in real time. Evidence is captured as an immutable audit trail. Exceptions surface immediately, not during quarterly reviews.

Research backing the Accelerate framework demonstrates that high-performing software organizations achieve both speed and stability through automated practices. The four key metrics, deployment frequency, lead time for changes, change failure rate, and mean time to restore, improve when software development teams embed quality and security checks directly into pipelines rather than treating them as separate gates.

For banks, the stakes include operational resilience and third-party risk management. DORA reinforces what mature DevOps teams already know: the fastest path to compliance is automation. When your toolchain enforces policy continuously, you don't trade speed for safety; you get both.

Pro tip: Start with your highest-risk systems first. Automate governance for customer-facing applications and payment systems, then expand the model to lower-risk internal tools once the pattern is proven.

Mapping DORA's Four Pillars to Your Delivery Pipeline

DORA organizes ICT risk management around four core pillars. Each translates directly into delivery pipeline controls that banks can implement today.

Pillar 1: ICT Risk Management

DORA requires financial entities to establish frameworks for identifying, protecting against, detecting, responding to, and recovering from ICT-related incidents. In practice, this means threat modeling, vulnerability management, and secure development practices.

Encode these controls as pre-merge and pre-deploy gates. Before any code merges to main, require passing static application security testing (SAST), software composition analysis (SCA) for vulnerable dependencies, and secrets scanning. Configure your CI/CD pipeline to reject PRs that introduce critical or high-severity findings. For infrastructure changes, use policy-as-code tools like Open Policy Agent to validate Terraform plans against security baselines before applying them.

PayInc, a leading South African payments provider, automated compliance reporting and billing workflows with Scrums.com while maintaining strict data residency requirements. By implementing cloud-based solutions with ISO 27001 alignment on AWS infrastructure hosted in South Africa, the organization improved data accuracy and reduced manual workload, all while ensuring every change passed through automated security and compliance checks before reaching production.

Pillar 2: Incident Management and Reporting

DORA mandates structured processes for logging, classifying, and reporting ICT-related incidents, with specific timelines for notifying regulators about major incidents. Manual incident tracking doesn't scale when you're deploying multiple times per day.

Automate incident creation and classification. When monitoring systems detect SLO breaches, anomalies, or error rate spikes, create incident records automatically with severity classification, affected services, and initial context. Integrate your observability stack (Datadog, New Relic, Prometheus) with your incident management platform (PagerDuty, Opsgenie) so on-call engineers receive runbooks, relevant logs, and rollback options immediately.

Link incidents to deployments. If a change causes elevated error rates, your pipeline should correlate the incident with the specific commit, PR, and approvers involved. This creates end-to-end traceability from code change to production impact, exactly what DORA's reporting requirements demand.

Important: DORA requires reporting major ICT-related incidents to regulators within four hours of classification. Automated incident detection and classification are not optional luxuries; they're regulatory necessities.

Pillar 3: Digital Operational Resilience Testing

DORA requires financial entities to conduct regular resilience testing, including scenario-based testing and threat-led penetration testing. This goes beyond annual pen tests; it means continuously validating that your systems can withstand operational disruptions.

Build chaos engineering into your release process. Schedule automated failover drills, dependency failure simulations, and load testing as part of your CI/CD pipeline. Tools like Chaos Monkey, Gremlin, or LitmusChaos can inject failures into staging environments to verify your systems degrade gracefully and recover automatically. Log every test run with results, making resilience testing auditable and repeatable.

For customer-facing systems, implement progressive delivery patterns. Use feature flags to control rollout blast radius, deploy behind canary analysis that monitors error rates and latency, and configure automatic rollback when KPIs degrade. This approach treats every production deployment as a controlled resilience test.

Pillar 4: Third-Party ICT Service Provider Management

DORA elevates oversight of critical third-party providers, requiring due diligence, continuous monitoring, and contractual clauses that ensure providers meet resilience standards. For banks working with software development partners, this means vendors must participate in the same governance framework.

Extend your pipeline controls to third-party teams. If a vendor contributes code, they should push through the same CI/CD gates, like automated tests, security scans, code review, and evidence capture. Require vendors to publish Software Bills of Materials (SBOMs) for dependencies they introduce, and integrate SBOM validation into your merge gates to detect supply chain risks early.

When NedBank needed to improve system reliability and data quality across multiple internal systems, they worked with cross-functional engineering teams at Scrums.com that integrated directly into AWS-based infrastructure with Datadog monitoring and BugSnag error tracking. The approach ensured that whether work came from internal teams or partners, the same observability and quality standards applied, creating uniform governance across all contributors.

Good to know: DORA's third-party requirements apply to any provider deemed "critical." This includes cloud infrastructure (AWS, Azure, GCP), SaaS platforms, and development partners delivering code into production systems.

The Four-Layer Guardrail Model

To implement governance-as-code effectively, organize controls into four layers that together create a comprehensive safety net.

Layer 1: Identity and Access

Every action in your delivery pipeline, whether taken by humans or automation, should assume a role with scoped permissions and leave an audit trail. Use short-lived credentials, enforce multi-factor authentication, and require role-based access controls (RBAC) that align with your organizational hierarchy.

For automated agents (CI/CD bots, deployment tools, monitoring systems), grant least-privilege access using service accounts with time-limited tokens. Log every authentication event, permission grant, and access change. When auditors ask "who deployed this change and under what authority," your identity logs provide the answer.

Layer 2: Data Governance

Financial data carries regulatory weight. Classify data sources (customer PII, transaction records, internal metrics) and apply appropriate handling policies. For software development and testing environments, implement data masking and anonymization by default so engineers never touch production customer data.

Capture data lineage for risk reporting. When transformations occur, aggregations, joins, calculated fields, log inputs, outputs, and the logic applied are involved. This creates reproducible audit trails that satisfy BCBS 239 principles for risk data aggregation and reporting, ensuring your data remains trustworthy under regulatory scrutiny.

Layer 3: Change Management

Define the minimum quality bar for merging and deploying code. Typical gates include:

All automated tests passing (unit, integration, contract, end-to-end)
SAST and SCA scans are passing with no critical or high findings
Secrets scanning clean
Code coverage above the defined threshold (e.g., 80% for critical paths)
Required approvals from the code owner and the security reviewer
Deployment runbook attached for production changes

Configure your CI/CD platform to enforce these gates automatically. If any check fails, the pipeline stops and alerts the responsible team. No exceptions, no manual overrides without executive-level approval and justification logged in your change management system.

Layer 4: Evidence Capture

Every pipeline action, including build, test, scan, deploy, and monitor, should generate immutable evidence. Store logs, artifacts, scan results, approval records, and deployment metadata in a centralized system of record (e.g., S3 with versioning, audit log aggregator, GRC platform).

Structure evidence to map directly to DORA requirements. For incident reporting, link deployment events to monitoring alerts. For resilience testing, store chaos test results with system behavior observations. For third-party oversight, maintain SBOM attestations and vendor pipeline compliance reports.

When internal audit or regulators request evidence, you provide API access to your evidence repository rather than manually compiling spreadsheets. This reduces audit preparation time from weeks to hours.

Real-World Outcomes: What Governance-as-Code Delivers

Banks implementing automated governance consistently see measurable improvements across delivery speed, system reliability, and compliance readiness.

Faster lead times without sacrificing safety. When controls run automatically on every commit, teams stop waiting for manual security reviews or change approval board meetings. Lead time for changes drops from weeks to days or hours, while the percentage of changes passing all controls the first time increases because engineers receive immediate feedback.

Lower incident rates and faster recovery. Automated testing catches defects before production. Policy-as-code prevents misconfigurations from being deployed. When incidents do occur, automated rollback and documented runbooks reduce mean time to restore (MTTR) by 50% or more compared to manual processes.

Audit preparation becomes continuous, not episodic. With immutable evidence capture, compliance becomes a byproduct of delivery rather than a separate effort. Quarterly audits shift from weeks of scrambling to a few hours of report generation and evidence review.

PayInc's experience with Scrums.com demonstrates these benefits. By automating compliance reporting and implementing role-based access controls with enhanced notification systems, the organization reduced manual workload and improved data accuracy for financial operations. The secure, cloud-based architecture enabled rapid iteration while maintaining strict regulatory alignment, proving that governance and velocity can coexist.

90-Day Blueprint: From Baseline to Audit-Ready

You don't need a multi-year transformation to achieve DORA compliance. A focused 90-day effort can establish the foundation and demonstrate measurable progress.

Weeks 1-3: Baseline and Scope

Start by understanding where you are. Pull delivery metrics for the past quarter: deployment frequency, lead time for changes, change failure rate, and MTTR. Inventory your toolchain: source control, CI/CD, monitoring, ticketing, secret management, and cloud infrastructure.

Map your critical systems. Identify customer-facing applications, payment processing systems, and core banking platforms that fall under DORA's scope. For each system, document current controls (if any), known gaps, and regulatory obligations specific to that system.

Select 2-3 pilot systems that represent different risk profiles, for example, one customer-facing web application, one API gateway, and one internal data processing service. These pilots will validate your governance model before expanding it across the organization.

Weeks 4-6: Implement Minimal Viable Controls

Focus on the highest-impact, lowest-complexity controls first. Implement SAST and SCA scanning in your CI/CD pipeline for pilot systems. Configure pipelines to fail builds when critical vulnerabilities are detected. Add secrets scanning to prevent credential leaks.

Establish merge gates. Require passing tests, clean security scans, and at least one code review approval before code reaches the main branch. Configure branch protection rules to enforce these requirements automatically.

Set up basic evidence capture. Configure your CI/CD platform to log build artifacts, test results, scan reports, and deployment events to a centralized storage location. Ensure logs are immutable and timestamped.

Pro tip: Use pipeline templates to standardize controls across teams. Define one "golden path" pipeline configuration that includes all required gates, then let teams fork it for their specific needs. This scales governance without imposing rigid one-size-fits-all processes.

Weeks 7-9: Expand to Incident Management and Resilience

Automate incident creation. Integrate your monitoring platform with incident management tools so SLO breaches and error rate spikes create incidents automatically with severity classification and context.

Implement automated rollback. Configure your deployment platform to monitor key metrics (error rate, latency, traffic patterns) for 10-15 minutes after deployment. If metrics degrade beyond thresholds, trigger automatic rollback and create incident records with full deployment context.

Schedule your first chaos test. Use controlled failure injection in a non-production environment to validate recovery procedures. Document runbooks based on observations. Store test results as evidence of resilience testing.

Weeks 10-12: Third-Party Governance and Audit Simulation

If you work with software development partners or SaaS vendors, extend pipeline controls to third-party contributions. Require vendors to submit code through the same merge gates and generate SBOM attestations for dependencies they introduce.

Conduct an internal audit simulation. Ask your internal audit or risk team to request evidence for a sample deployment: who approved it, what tests were run, which vulnerabilities were present and remediated, and what the post-deployment behavior looked like. Generate this evidence from your automated logs, not from manual reconstruction.

Present results to stakeholders. Compile a report showing before-and-after metrics: lead time improvements, reduction in critical vulnerabilities reaching production, incident MTTR, and audit evidence generation time. Highlight where automation reduced manual effort and improved compliance confidence.

Important: Don't wait for perfection before declaring success. If your pilot systems show measurable improvement and generate auditable evidence, you've validated the approach. Expand to additional systems incrementally while refining controls based on lessons learned.

When to Consider a Strategic Development Partner

For many banks, the challenge isn't knowing what to do; it's finding the engineering capacity and platform expertise to do it while maintaining delivery momentum on core initiatives. Traditional hiring takes months, and compliance-focused contractors often lack the modern DevOps experience needed to automate governance effectively.

Software development companies that specialize in banking and financial services can accelerate your DORA compliance journey. A strategic partner should offer:

Platform-first delivery that embeds governance into engineering workflows from day one, not as an afterthought
Compliance expertise with proven experience in regulated industries, understanding of Basel, DORA, and BCBS principles
Cross-functional teams combining engineers, DevOps specialists, QA, and platform architects who can implement end-to-end solutions
Flexible engagement models that let you scale capacity up or down as compliance initiatives progress through phases

This model particularly suits banks facing tight DORA deadlines, limited internal DevOps capacity, or complex vendor landscapes that need standardization. Rather than hiring and training full-time employees for a time-bound compliance initiative, you access experienced teams who have solved similar challenges for other financial institutions.

Scrums.com's Software Engineering Orchestration Platform (SEOP) supports banks in achieving exactly this outcome. By combining custom software development with embedded compliance automation and real-time delivery analytics, we help financial institutions ship faster while meeting regulatory standards. Our teams have worked with organizations like PayInc, NedBank, and Investec to implement automated governance, improve system reliability, and maintain audit-ready evidence, all while accelerating delivery velocity.

Conclusion

DORA compliance doesn't have to slow you down. When you treat governance as code rather than as manual oversight, regulatory requirements become automated pipeline checks that make delivery safer and faster simultaneously. The banks that thrive in the post-DORA landscape won't be the ones that hired more compliance officers; they'll be the ones that embedded resilience and evidence capture directly into how software gets built and deployed.

The path forward is clear: baseline your current state, implement minimal viable controls on pilot systems, expand to incident management and resilience testing, and extend governance to third-party contributors. Within 90 days, you can establish the foundation and demonstrate measurable progress toward DORA readiness.

Your toolchain already has the building blocks. Your engineers already understand quality and safety. What's needed is a deliberate effort to connect regulatory requirements to delivery automation, turning DORA from a compliance burden into a catalyst for engineering excellence.

Ready to accelerate your DORA compliance journey? Explore how Scrums.com's financial software development services help banks implement governance-as-code and achieve audit-ready delivery in 90 days, or read about how DORA metrics in banking boost velocity for software development teams.