
The article provides an in-depth analysis of Legislative Decree No. 23 of March 10, 2025, which aligns Italian legislation with Regulation (EU) 2022/2554 DORA (Digital Operational Resilience Act), aimed at enhancing the digital operational resilience of the financial sector.
Key topics include:
- the designation of national competent authorities (Bank of Italy, Consob, IVASS, COVIP) and the allocation of supervisory responsibilities.
- the National Cybersecurity Agency (ACN)'s role in managing ICT incidents and supporting the financial regulators.
- the establishment of coordination protocols for technical support and incident response between authorities.
A central focus is the sanctions framework, divided into:
- severe violations (e.g., failure to implement risk management frameworks, insufficient backups, non-reporting of major incidents).
- lesser violations, concerning organizational and procedural obligations.
Sanctions are calibrated based on:
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- the type of financial entity (banks, insurers, investment firms, crypto providers, etc.),
- the severity of the breach,
- the annual turnover of the legal entity involved.
The decree also includes fines for individuals, non-pecuniary measures (e.g., suspension of unlawful practices), and mandatory publication of enforcement decisions by the supervising authority.
This article serves as a comprehensive legal and regulatory guide to understand the impact of Legislative Decree No. 23/2025 on digital governance, technical obligations, and regulatory risks within the banking, financial, and insurance sectors.