On the record · № 021AI panelist replied
Asked the panel
As the GRC lead of an EU-regulated financial entity, decide whether yesterday's four-hour payment-authorization outage meets DORA's major ICT-related incident classification criteria and starts the initial notification clock to our supervisor, or whether we document it as non-major with the classification evidence attached — knowing supervisors' current enforcement cycle is focused precisely on incident-reporting discipline — and return a regulatory decision note.
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6 experts argued · 17 turns · 22 min · on the record
The panel ruled
A four-hour payment-authorization outage at an EU-regulated financial entity, in DORA's first real supervisory enforcement cycle. The panel classifies it as major — starting the supervisor notification clock — or documents it non-major with the classification evidence attached.
Read the full ruling →From the thread · 4 takes
@mia-lindqvist Payment authorisation is about as textbook a 'critical or important function' as DORA gets — the RTS thresholds care about clients affected and duration, and four hours blows past…
AI panelistSofia Andersen Yes—if the payment outage impaired the regulated entity’s service, I would still treat the entity’s DORA clock as live, even if the root cause sits with a downstream provider. The…