DORA compliance: What it means for communications recording

In practice, that means:

• Conducting mandatory resilience testing
• Ensuring third-party provider oversight
• Increased emphasis on incident reporting, supply chain risk, and cybersecurity preparedness

It also means that firms now need to integrate real-time monitoring, automated threat detection, and clear governance structures to meet high expectations of resilience--all while aligning operational resilience with business continuity and regulatory reporting obligations.

Clearly, then, DORA is all about making companies stay proactive and continuously update policies, staff training, and technical safeguards to avoid significant penalties.  This has clear implications for compliance operations.

DORA Compliance and Communications Recording

While a lot of the discussion around DORA has focused on cybersecurity, operational resilience, and third-party risk management, the regulation also has important implications for how organisations manage and secure recorded communications.

For compliance and IT teams responsible for communications recording, DORA introduced a whole new level of scrutiny around the resilience, security, and governance of the systems that capture and store business communications.

That means that for you and your call recording team, a full understanding of these implications is critical—and that applies not just for financial institutions but also for organisations in other regulated industries that are increasingly adopting similar operational resilience standards. For example, the NIS2 Directive covers both healthcare and the public sector in the EU zone.

Understanding DORA’s Purpose

To see why, it’s instructive to back up a little and see why DORA came about. The intent is to ensure that European financial institutions can withstand, respond to, and recover from digital disruptions. But in fact, its scope is broad, covering banks, investment firms, insurance companies, payment providers, and a range of technology and service providers that support them.

The regulation focuses on five key pillars:

• ICT risk management
• Incident reporting
• Digital operational resilience testing
• Third-party risk management
• Information sharing.

While DORA does not specifically target communications recording technologies, the platforms and infrastructures used to record calls, video meetings, and digital communications fall squarely within the ICT environment that the regulation seeks to strengthen.

In practice, this means that communications recording solutions must now meet higher expectations around reliability, security, and operational resilience. So, what can we do to strengthen these defences?

Why Communications Recording Matters Under DORA

Communications recording plays a central role in regulatory compliance across financial markets. Regulations such as MiFID, market abuse frameworks, and internal governance policies require firms to capture and retain communications related to trading, investment advice, and other regulated activities.

These recordings serve as critical evidence in the event of disputes, audits, investigations, or regulatory reviews.

Under DORA, the question shifts from simply recording communications to ensuring that the systems responsible for capturing and storing those records are operationally resilient. If a disruption prevents communications from being recorded, accessed, or preserved securely, the organisation could face both compliance and operational risks.

This creates a direct link between communications recording infrastructure and the broader resilience objectives defined by DORA.

Strengthening the Resilience of Recording Systems

One of DORA’s core requirements is that firms implement robust ICT risk management frameworks. For communications recording, this means you must evaluate whether your recording systems can continue operating reliably even during technical disruptions or cyber incidents.

Key questions you need the DORA answers to include:

Where are we on system availability? Recording platforms must remain operational even during infrastructure failures, network outages, or service interruptions.

And redundancy and failover? Organisations may need backup recording capabilities or geographically distributed infrastructure to ensure communications continue to be captured during disruptions.

How quickly can we recover? Firms should ensure that recorded data can be recovered quickly if systems fail or data is compromised. In other words, how up to date is that business continuity contract and plan?

Monitoring and incident detection. Recording systems should be monitored for performance issues, security risks, and unexpected interruptions in recording activity.

In essence, communications recording can no longer be treated as a standalone compliance tool. It must now be integrated into the organisation’s broader resilience strategy.

Data Integrity and Security

Another key focus of DORA is protecting the integrity and confidentiality of digital systems and data. Recorded communications often contain highly sensitive information, including financial transactions, trading discussions, client instructions, and personal data.

Compliance and IT teams must therefore ensure that recordings are protected against tampering, unauthorised access, or loss. Again, the good news is there are practical ways to break that down into manageable parts, like ensuring that:

• Recordings always get fully encrypted, both in transit and at rest
• Strict access controls and authentication policies are always implemented, too
• Maintaining of audit trails that show who accessed or modified recordings
• Working only with secure storage environments that meet regulatory standards.

Maintaining the integrity of recorded communications is especially important because regulators rely on these records as evidence. Any indication that recordings could be altered or compromised may undermine their reliability during investigations.

Managing Third-Party Recording Providers

Many organisations rely on external vendors to provide communications recording platforms, particularly as more recording solutions move to the cloud.

There’s absolutely no problem with that, but DORA does place significant emphasis on third-party ICT risk management.

This means that compliance teams must examine not only their internal recording processes but also the operational resilience of the vendors supplying them.

Key areas of focus for understanding third-party ICT risk include:

• Vendor security standards and certifications
• Service availability and up-time guarantees
• Incident response capabilities
• Data protection and regulatory compliance measures.

So, if recordings are stored in the cloud or across multiple jurisdictions, then you’ll need to understand how your partners manage their infrastructure.

Incident Reporting and Operational Visibility

Finally, DORA introduces stricter requirements for reporting major ICT-related incidents to regulators. If a technical disruption affects communications recording (e.g., as a failure that prevents calls from being captured), it may fall within the scope of reportable incidents.

As a result, organisations need stronger operational visibility into their recording systems. Compliance and IT teams should be able to quickly detect when recording processes fail, identify the cause, and determine the scope of any missing or affected communications.

Automated monitoring tools and alerting systems are increasingly important in this context, ensuring that potential compliance gaps are detected and addressed quickly.

Preparing for the New Compliance Landscape

For compliance and IT teams, the key takeaway is that communications recording must now be viewed as part of your critical digital infrastructure.

Preparing for DORA means evaluating recording systems through the lens of resilience and governance. Call compliance teams should assess whether their current technologies can continue capturing and protecting communications during disruptions, whether their vendors meet resilience expectations, and whether monitoring systems can quickly detect failures.

By strengthening these capabilities, firms not only support DORA compliance but also improve the reliability and trustworthiness of one of their most important compliance safeguards: the accurate and secure recording of business communications.

If anything in this blog has raised a concern that you may not be on top of DORA as much as you should be, our team is ready to support you; contact us to see how our call recording solution helps you stay fully compliant with DORA.