DORA compliance mapping¶

DORA (Digital Operational Resilience Act, Regulation (EU) 2022/2554) applied to EU financial entities from January 17, 2025. This page maps agent-manifest capabilities to DORA ICT risk requirements for financial services firms deploying AI agents.

Article 8 - Identification of ICT risks¶

Financial entities shall identify all sources of ICT risk and document information assets and related dependencies.

What agent-manifest provides

A signed manifest is a machine-readable ICT asset record. It documents:

• The AI agent's identity (agent_id, SPIFFE URI)
• The model version in use (artifacts.model_identity)
• The system prompt in use (artifacts.system_prompt.hash)
• The tools the agent can invoke (artifacts.tool_manifest.tools[])
• The cryptographic profile (crypto_profile: Ed25519, ML-DSA-65 hybrid)

Every field is signed by the issuer key, making the record tamper-evident. An inventory sweep can verify that all deployed agents have valid, unexpired manifests and produce a signed asset register.

Article 11 - ICT business continuity¶

Financial entities shall put in place ICT business continuity policies, plans, and procedures.

What agent-manifest provides

Key rotation: The Revocation and key rotation tutorial documents a zero-downtime rotation procedure. The procedure allows issuing new manifests under a new signing key without interrupting agent operations, satisfying DORA's requirement for continuity under ICT disruption.

Revocation: The FileCRL component provides an append-only, signed certificate revocation list. A compromised agent can be revoked in under one second by appending a signed SignedRevocationRecord. All verifiers checking the CRL endpoint immediately begin rejecting the revoked agent.

Recovery time objective (RTO): Key rotation and agent reissuance can be completed in under five minutes using the runbook. The revocation mechanism has no single point of failure - the CRL file can be served from any static file host.

Article 17 - ICT-related incident classification¶

Financial entities shall classify ICT-related incidents and determine their impact.

What agent-manifest provides

When an ICT incident involves an AI agent (e.g., an agent behaves unexpectedly, is compromised, or is suspected of data exfiltration), the manifest provides:

• Exact configuration at time of incident - model version, prompt hash, tool catalog hash, all signed and timestamped
• Authorisation chain - who issued the manifest, who approved deployment (HITL record)
• Merkle audit root - allows verifying that specific decisions were recorded before the incident, without replaying the full audit log

This evidence satisfies DORA's requirement to document the "scope and nature" of an incident and supports the incident timeline required under Article 19 reporting.

Article 25 - Testing of ICT tools and systems¶

Financial entities shall establish a comprehensive digital operational resilience testing programme.

What agent-manifest provides

Conformance levels provide a testability hierarchy:

The test suite (pytest --cov=agent_manifest --cov-fail-under=80) runs all 197 conformance-level tests in CI, producing a verifiable coverage record. This record can be cited as evidence in DORA testing documentation.

RTS requirements - key management controls¶

The DORA Regulatory Technical Standards (RTS) require documented key management controls for ICT systems. Agent-manifest satisfies the following RTS controls:

Summary table¶

This mapping is provided as reference material. It does not constitute legal advice. Consult your legal and compliance teams before making compliance claims.